September 9, 2013 An Open Letter to the California Legislature on AB 484 (Bonilla) Honorable Senators and Assemblymembers: AB 484 (Bonilla), a measure setting direction for the California K-12 statewide assessment system for the next seven years, is scheduled for action on the floor of the Senate this week, and if approved it will be scheduled for concurrence in the Assembly before the end of the 2013 session this week. I would urge you not to support passage of this measure at this time. There are two major reasons this measure does not deserve your support: o The measure mandates that California use a "consortium" assessment system for the next seven years, through 2020, to measure the new Common Core standards. No one has seen the new tests yet, because the consortium tests have yet to be developed. Further, it is highly unlikely the federally funded consortium will be able to produce fully operational tests as promised for the spring 2015 testing cycle [see Attach 1, p 3 and Attach 2, pp 10-11 for details]. California's timelines for implementing instruction for the new Common Core show Mathematics will not be ready for assessment until 2016 and English / Language Arts not until 2017 [Attach 1, p 2 & 6-7]. The consortium tests call for computer-administration, and California will likely not be technology-ready for assessments until 2018 [Attach 2, pp 3-4]. Finally, there will be competitive non-consortium tests that may provide better data and services for a lower price when California is ready to fully implement new computerized tests to measure the Common Core [Attach 1, p 13]. Mandating a single source for K-12 assessments for the next seven years before we know what will be delivered or what the costs will be for expenditures in the hundreds of millions of dollars is not a smart business decision. o While it has been widely asserted that California "must" implement assessments to measure the new Common Core by 2015, the fact is there are no federal or state legislative mandates for implementation by this date, only a commitment to the Smarter Balanced Assessment Consortium to implement their tests by 2015 . . . . a commitment that without AB 484 may easily be withdrawn. AB 484 as amended September 4 includes new language in Sec 60648.5 that the first full administration of consortium tests "shall occur in 2014-15 unless the state board determines that the assessments cannot be fully implemented." This language would allow for indefinite delay for initial use of consortium tests, until all the necessary elements (tests, instruction, and technology) are in place. Under AB 484, the only option would be to continue participation in Smarter Balanced's on-going test development work, which would not have federal support but rather be on California's dime, and which would not generate valid and reliable individual student scores or statewide aggregate data. Without valid and reliable test data, California would not be able to generate the heavily used California Academic Performance Index (API) data for upwards of four years or longer [Attach 1, pp 2-3; Attach 2, p 14-17]. To have a four year hiatus from accountability data would not be well received by the California public-at-large [67 percent support the use of tests for accountability purposes, according to a UC/Stanford/USC PACE poll released just last week]. There are many additional reasons for not supporting AB 484 at this time, reasons discussed in the attachments to this letter but too detailed for lengthy discussion here. I urge you not to support AB 484 (Bonilla) at this time, but rather wait until we are collectively ready to initiate a new computerized assessment system to measure the Common Core and have more complete knowledge of assessment systems, consortium and non-consortium, available for potential use for a new California K-12 statewide assessment system to measure the Common Core. Sincerely, Douglas J. McRae, Ph.D. Educational Measurement Specialist (Retired) Monterey, California 831-484-2129 mcraedoug@comcast.net [Doug McRae is a retired educational measurement specialist living in Monterey. In his 40 years in the K-12 testing business, he has served as an educational testing company executive in charge of design and development of K-12 tests widely used across the US, as well as an adviser on the initial design and development of California's STAR assessment system. He has a PhD in Quantitative Psychology from the University of North Carolina, Chapel Hill.]