NJPSA Statement Concerning Proposed Notice of Substantial Change to Standards and Assessment Code N.J.A.C. 6A: 8

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Thank you for the opportunity to share the perspective of the membership of the NJ Principals and Supervisors Association (NJPSA) on proposed changes to the NJ Standards and Assessment code as contained in the proposed Notice of Substantial Change adopted on October 21, 2019. I am Karen Bingert, current President of NJPSA, the principal of Hillsborough High School in Somerset County and the Chair of NJPSA’s Critical Issues Committee, a standing committee of the association currently considering issues related to student assessment and high school graduation requirements. 

NJPSA believes that student assessment is an integral part of the instructional process that is inextricably linked to standards, a viable curriculum, and strong instructional practice that collectively comprise a high-quality learning system. State-level assessments are one component of our system that seek to measure not only student learning growth but also school system accountability under federal legal requirements. At the high school level, passage of certain state assessments is currently a state graduation requirement as well. 

Over the past year, we have all engaged in an important statewide dialogue on the issue of student assessment with the goal of transitioning to a next generation of assessments aligned to our highly-rated New Jersey State Learning Standards. This dialogue was a wide-ranging one, wherein the NJDOE and the State Board listened to the views and experiences of parents, students, teachers, administrators, board members, legislators, and the public from urban, suburban and rural areas of the state. Much of our discussion has focused on the high school level where issues of high stakes graduation requirements, over-testing, instructional time impacts, student non- participation and lack of motivation, achievement gaps, equity issues, and system accountability are magnified in impact. 

In response, the State Board of Education reached and approved a consensus regulatory proposal early last fall that NJPSA supported as an appropriate balance for students, educators and the public. This proposal maintained state testing at grades 9 and 10 in English Language Arts (ELA) and Mathematics and retained current graduation proficiency levels (ELA 10, Algebra I). 

Our forward momentum hit a major roadblock with a New Jersey court decision striking down our assessment system as inconsistent with a state statute requiring students to pass a graduation assessment in the 11th grade. Despite a Senate legislative leadership effort to modify the 11th grade testing requirement that NJPSA supported, the legislation did not pass in the Assembly and the 11th grade testing statutory requirement continuesIn this context, NJPSA supports the proposed substantive changes to N.J.A.C. 6A:8, Standards and Assessment code as adopted by the State Board on October 21, 2019, as a compromise step forward in achieving clarity in our state assessment and graduation requirements for students after several years of tumult. We believe the proposal, while not perfect, strikes an appropriate balance for students for the following reasons: 

1. A strong educational system is based upon three interconnected components; high quality academic standards, a strong and aligned curriculum and a comprehensive system of assessment. 

2. NJ has adopted high quality, rigorous academic standards and has recently made important strides to strengthen curriculum statewide. Over the past year, the NJDOE and professional educators have collaboratively developed aligned, statewide student learning objectives, derived from our learning standards, to strengthen curriculum development in every school, a strong step toward addressing educational equity. 

3. New Jersey does have a comprehensive system of state assessment that includes state standardized assessments, local benchmark assessments, and teacher- developed formative and summative assessments, supplemented by locally-chosen standardized assessments in some districts. This system provides a rich source of data on our students throughout their school careers. The Department’s proposal continues to provide important data points in English Language Arts and Mathematics, including Geometry, within the robust and comprehensive system of assessment that exists in our schools.

4. The proposed substantive change seeks to address the turmoil New Jersey has experienced on the issue of over-testing by striking the same testing time balance contained in last year’s consensus code proposal. NJPSA strongly recommends that the 11th grade test be administered in the fall (November), to provide sufficient time for educators to work with students who need additional support.

5. The proposal recognizes the individual goals and related pathways that students need to meet their post-secondary goals by providing a range of pathways for high school students to demonstrate proficiency of the high school graduation requirements. We support the continuation of the sitting requirement to access alternative assessments as a pathway in order to provide relevance to our students as well as useable data to districts. Overall, we support this continued flexibility as New Jersey’s assessment system continues to evolve to ensure that no harm is done to students during any transition.

6. We need clarity now. Forward momentum and timing are both critical to students and educators. If the State Board does not move forward with the proposed substantive change, New Jersey students will once again be deprived of fair notice of testing requirements and placed in a position of uncertainty. Additionally, our implementation efforts of the newly-developed 11th grade test could be compromised by a shortened timeline. Neither students nor educators deserve that outcome.

In closing, we wish to share several implementation recommendations from our Critical Issues Committee for NJDOE consideration if the proposal is adopted: 

1. We strongly recommend that the 11th grade assessment be given in the Fall (November) of that year in order to provide as much time as possible for student remediation efforts if needed. The junior year is a time of many challenges, academic pressures, and emotional stressors for our students and would not be the year we would select for graduation testing absent state statute.

2. We recommend that efforts be undertaken at the state level to strengthen and incorporate the portfolio process within our high school coursework to provide an equitable pathway to graduation while alleviating a separate burden on students who do not pass the 11th grade assessment.

3. NJPSA members strongly urge the NJDOE to address the timeliness of data in any new assessment contracts to ensure that teachers and other educators receive assessment data as soon as possible. In addition, we urge the NJDOE to address the issue of timely transmission of data between districts and states. Often, our members are “data blind” with respect to the past performance levels of transfer students, ELL students and out-of-state students until well into the school year.

4. We urge the collaborative development of an implementation timeline with members of NJPSA and the field to ensure a smooth transition to a new assessment.

5. We urge the continuation of our state-level discussion on assessment including an exploration of innovative approaches to assessment being explored in other states. Relatedly, issues of reciprocity between states, to permit a student’s state assessment results to follow the student, should be explored.

6. Finally, we urge the State Board of Education and the NJDOE to continue to examine our state graduation requirements and explore multiple, yet equitable pathways to graduation.

Thank you for your consideration.