LONG BEACH UNIFIED SCHOOL DISTRICT S E R V IN G L O N G B E A C H , L A K E W O O D , S I GN A L H I L L A N D AVALON OFFICE OF THE SUPERINTENDENT 1515 HUGHES WAY LONG BEACH, CALIFORNIA 90810-1839 (562) 997-8242 • FAX (562) 997-8280 January 17, 2017 Dr. Michael Kirst, President California State Board of Education 1430 N Street, Room 5111 Sacramento, CA 95814 Dear Dr. Kirst, The Long Beach Unified School District requests a State of California waiver to administer the Scholastic Aptitude Test in place of the Smarter Balanced Assessment Consortium exam in the subjects of English language arts and math for all 11th graders beginning with the spring 2017 administration. Both NCLB and ESSA require 11th grade testing. We would be waiving the state’s test that meets this requirement and replacing it with a nationally-recognized test that better serves our students. In addition to accurately measuring student achievement in these subject areas, the SAT is a universally recognized measure of college readiness, and it is a key metric in the recently approved California school accountability system. While the SBAC provides college-readiness data informing only course placement for the 23 California State University schools, the SAT is used much more broadly by more than 2,400 colleges and universities, including CSU, for admission purposes. Our high school students and parents see far greater value in the SAT than the SBAC because the SAT is the main assessment affecting college admission. Student performance on the SBAC in 11th grade also correlates almost identically with performance on the SAT. Among our 11th graders, 49 percent met or exceeded standards on the SBAC, while 49 percent of the same population met or exceeded the benchmark on the SAT Evidence-Based Reading and Writing. Similarly, 28 percent of our 11th graders met or exceeded standards on SBAC in math, while 29 percent of our students met or exceeded the benchmark on SAT Math. Our high school students, staff and parents are telling me that they need relief from unnecessary, duplicative testing. In fact, many of our stakeholders say we should have long ago replaced the 11th grade SBAC with the SAT. Just as the state does not wish to administer two different science assessments, as reported by media regarding California’s opposition to such a federal mandate, we should not be administering duplicate 11th grade summative assessments. These assessments are being administered within the context of many other exams at the high school level. We will administer as many as 15,000 Advanced Placement exams this year, a new record that is a positive result of our efforts to open access to college-level coursework. Last year, students here signed up for more than 13,000 AP exams, an 82.4 percent increase in just four years. Removing the SBAC in 11th grade will allow more time to focus on this type of college readiness and planning, which reduces the need for remediation in college and can result in thousands of dollars in savings on tuition for families whose children earn as much as one year of college credit while still in high school. About 77 percent of our high school graduates enroll in college, which is an enviable figure considering our challenging demographics (roughly 70 percent of our students live in poverty). But we know that we can enroll even more students in college. For the sake of equity and college access, we owe it to our students, especially our underrepresented populations, to substitute the SAT for the SBAC in 11th grade. Administering the SAT and PSAT allows all of our students to take advantage of free, aligned and customized interventions in the form of online tutorial services through Khan Academy beginning in eighth grade. No such support is available with the SBAC. In our schools the SAT is administered during the school day and is free for all students. LBUSD would not seek reimbursement from the state for SAT administration. A greater focus on SAT interventions and related support can significantly affect students’ lives for the better. Allowing our students to retake the SAT in 12th grade last year, also at no charge and with proper interventions, resulted in an additional 119 students qualifying for admission to Cal State Long Beach (they had previously fallen just short of the 3200 Index Score required by CSULB for admission). Of these students, 89 percent were students of color. These students earned guaranteed admission to CSULB under our nationally emulated Long Beach College Promise Initiative, which has seen the number of LBUSD graduates enrolling at CSULB increase by 71 percent since its inception in 2008. Once admitted to CSULB, our students also persist in college at a greater rate than their non-LBUSD counterparts. Graduation rates at CSULB also have significantly increased for Latinos, African Americans and Asians. Likewise, our graduation rate in Long Beach continues to increase, now at 84 percent compared to the state’s 82.3 percent, even though we have a far greater percentage of students living in poverty here than the state as a whole. Our African American graduation rate of 82.5 percent also exceeds the state’s rate of 70.8 percent. With a long history of stability and consistently superior results, Long Beach is poised to successfully implement the requested waiver. Parents opt-outs will be recognized by LBUSD for the SAT. Last year, no SAT opt-outs were submitted by parents here in California’s third largest school district. By comparison, 1,300 students in 11th grade here opted not to release their SBAC results to the CSU system. Currently, four states – Colorado, Connecticut, Maine and New Hampshire – have been granted a federal waiver to administer the SAT for accountability purposes, in place of their state adopted assessment programs, as a summative measure of high school level student performance and college readiness in both subject areas. Four states also have obtained similar waivers to administer the ACT, setting additional precedent for such use of a nationally recognized test. California Education Code, Section 60602.5(a) cites that the system of assessments has the primary purpose of: • • • Assisting teachers, administrators, pupils and their parents Improving teaching and learning Promoting high-quality teaching and learning using a variety of assessment approaches and item types 2 The assessments, where applicable and valid, will produce scores that can be aggregated and disaggregated for the purpose of holding schools and local educational agencies accountable for the achievement of all their pupils in learning the California academic content standards. Further, California Education Code, Sections 60640(1) (A) and (5) stipulate that the assessment of student progress for ELA and Math be aligned with and measure the statewide academically rigorous content and performance standards, adopted by the state board. Both the ELA and Math components of the SAT are well documented to align with our performance standards at the subject, subtest and item levels. Analysis of grade 4 through 8 LBUSD student data from the 2014-15 and 2015-16 SBAC administrations indicate that previous student performance is highly predictive of future student performance on both the SBAC and SAT assessments. Integrating with analysis of grade 11 student data from the 2015-16 LBUSD district-wide SAT administration, we find that student performance on either assessment is highly predictive of performance on the other. More specifically, there is a robust relationship to benchmark achievement and college readiness across assessments – an 80 percent correlation in ELA and an 87 percent correlation in Mathematics. The implication is that the two assessments, both the SBAC and the SAT, demonstrate concordance in their measure of student performance and growth in both subjects. Upon request, we will be happy to provide full access to our findings, methodologies and datasets used for analysis, and any other information you may require in order to advance our waiver and expedite its approval. Sincerely, Christopher J. Steinhauser Superintendent of Schools c: Tom Torlakson, State Superintendent of Public Instruction Glen Price, Chief Deputy Superintendent of Public Instruction Keric Ashley, Deputy Superintendent of Public Instruction Karen Stapf Walters, Executive Director, California State Board of Education 3