December 1, 2016 Jo Ann Isken, Chairperson California Practitioners Advisory Group 1430 N Street, Room 5111 Sacramento CA 95814 Via email: cpag@cde.ca.gov RE: December 7, 2016 Meeting: Items 02 Dear Ms. Iksen, On behalf of the members of the Californians Together Coalition, I am forwarding our concerns regarding the following item: Item 2: Review of the Local Control Funding Formula Evaluation Rubrics State Indicators, including, but not limited to, the Academic Indicator for Small Group Activity and Large Group Discussion on Recommendations. Our concern relates to the proposed inclusion of the academic scores of the Redesignated Fluent English Proficient students in the aggregate score of English Learners for the EL Subgroup academic indicator. The state definition of ELs in Ed Code Section 306 (a) is: “English Learner” means a child who does not speak English or whose native language is not English and who is not currently able to perform ordinary classroom work in English, also known as a Limited English Proficent or LEP child.” Inclusion of RFEP students in a subgroup titled “English Learner” contradicts the Ed Code definition of an English learner. The resulting aggregation of RFEP and EL scores would make it difficult to ascertain which “English learner” sub-groups are doing poorly and which are doing well, where additional support would be needed and which schools would require additional technical assistance. Aggregated results would reflect neither RFEP nor EL student groups. We agree that districts and schools should be able to demonstrate how well their RFEPs are doing, but including their scores with the ELs does not achieve that. The effect of aggregation would be particularly eggregious in the upper grade levels populated by Long Term English Learners and Students at Risk of Becoming LTELs and large numbers of RFEPs. Here, again, the achievement and needs of LTELs and Students at Risk of Becoming LTELs would be completely obscured by RFEP achievement..The rubrics and the LCAPs will not accurately report nor will it be possible to accurately address the language, literacy, or academic needs of LTELs. It is also important to note that in every year of academic data for ELs there is cohort of students who will be designated RFEPs using that data. When data is available for three years and the indicator will be an average of the three years, three years of RFEP student data will be in the EL average (currently the scores reflect only two years). If the state then includes 4 years of 1 RFEP data into the EL indicator, this group will be over-represented the RFEP data and it will mask the current EL data. This will inflate the EL academic indicator. We recommend separate data runs for combined EL and RFEPs as well as separate data runs by K-5 and 6-8 grade spans. In grades 6-8 LTELs make up a large percentage of the EL subgroup and at the same time the numbers of RFEPs in these grades outnumbers the number of ELs. For grades 6-8 in particular, RFEPs will disguise the numbers of LTELs at grades 6-8, in essence making them invisible. The English language proficiency indicator should not be confused with the EL subgroup academic indicator. They are measuring two different skills and abilities : 1) language proficiency, and 2) academic achievement. The English Learner composite comprised of language proficiency data for ELs, reclassification rates and possibly LTEL data will demonstrate the language proficiency growth which is critical but not the same as academic achievement. Finally, it is important to look at the purpose of the data for the academic indicator. This data will translate into whether particular subgroups not meeting targets (orange or red) will be identified and populated into the LCAPs to be addressed for increased and improved services to help meet their needs. If the current English learner subgroup is more likely to be rated as “yellow”, then attention in the LCAPs, schools and districts will be focused on the other subgroups in the orange and red categories when in reality the current group of ELs should also be included in this category. This too will have a dimissing effect by not highlighting the current needs of ELs when technical assistance is available for schools and districts not meeting their subgroup targets. At its last meeting (September 2016), the State Board of Education took no action on this issue and referred it to the EL Work Group to review and provide recommendations to the Board in January 2017. We urge the CPAG to recommend against including a single item report that includes RFEP scores as part of the aggregate EL student scores for the academic indicator. , Instead, our recommendation is to report RFEP and EL in two separate cohort sets of scores and to seek additional input from the EL experts serving on the EL Work Group. Should you have questions regarding our position on this issue feel free to contact me. We look forward to a continued working relationship with you and other members of the CPAG. Sincerely, Shelly Spiegel Coleman Executive Director Cc: Vice Chair, Dr. Ed Manansala Ms. Jacqueline Mataranga 2