ELC Statement on Proposed Use of PARCC Exams as NJ Graduation Requirement

On September 30, Acting Education Commission David Hespe issued a memo about new high school graduation requirements. The Commissioner’s Sept. 30 memo contradicts everything the Department has been saying for more than a year about suspending NJ’s high school exit test requirement during the transition to PARCC (see below). It effectively makes “passing” at least one math and one language arts PARCC exam a graduation requirement beginning with the class of 2016 (current juniors).

The Department says it will give the tests to students this year, then set “cut scores” after the fact next summer and use those scores to determine whether or not a student has satisfied the state graduation proficiency requirements in math and language arts. The fact that the Department includes “substitute” non-state assessments (e.g., SAT, ACT, ASVAB and Accuplacer) and retains an “appeals process” does not negate the fact that the Department is effectively making “passing” PARCC tests a graduation requirement. This contradicts numerous statements by the Department over the past year. For example, in September 2013, then Commissioner Cerf made a presentation to NJ superintendents. Slide #24 of this presentation says clearly: “For the initial years of PARCC testing, any student currently in high school will not be required to ‘pass’ the assessments as a requirement for graduation.”

Similarly, the Governor’s College and Career Ready Task Force report, cited in the Department’s memo as one of the sources of this new policy, also says clearly (p. 49) that during “Phase 2” of the transition to PARCC: “This phase provides the time necessary for teachers and students to prepare for the new learning requirements demanded by the different end-of-course assessments. During this phase, high school students will be required to take the end-of-course assessments, but they will not be required to pass them as a condition for graduation.” The Task Force Report further says that standard setting (i.e., setting the “passing scores”) for the 10th and 11th grade PARCC exams should take place after the 2015-2016 administration, and standard setting for the 9th grade PARCC exams should take place after the 2016-17 administration of the tests (p. 50). Instead the Department is now proposing setting retroactive passing scores after a single administration of the PARCC tests. This is a violation of federal guidelines set forth for parental/student notification of new graduation requirements in federal court cases. As NJDOE’s own Director of the Office of Assessment, Jeff Hauger, said several years ago in a Department paper about the implementation of a new Algebra I test as a graduation requirement: “As a rule of thumb, the state needs to send out due notice to the districts regarding the graduation requirement and give them a three year period to adjust.”

The Commissioner’s proposed policies are inconsistent with fairness, best practices, and previous Department policy statements. They also require revision of current assessment regulations and reconsideration of the existing graduation statute and should be reviewed by both the State Board of Education and the Legislature before going forward. These decisions should not be made by unilateral Department memo. There are numerous other unanswered implications, especially for current HS students who will suddenly face new and untested graduation policies. For example, the proposal to include “substitute” commercial tests like SAT or ACT as part of the requirements for students who do not “pass” PARCC does not address the questions of who will pay for such tests and whether this will lead to unequal access to graduation pathways for different students. It should also be noted that no other state is using the PARCC exams in this way so quickly.

–Stan Karp, Director of the Secondary Reform Project, Education Law Center, 9/30/14