INITIAL STATEMENT OF REASONS

CALIFORNIA ASSESSMENT OF STUDENT

PERFORMANCE AND PROGRESS (CAASPP)

INTRODUCTION

Pursuant to California Education Code (EC) 60640, the California Department of Education (CDE) has prepared to update the California Assessment of Student Performance and Progress (CAASPP) System to include three new assessments: the new California Science Test (CAST) aligned with the California Next Generation Science Standards (CA NGSS); the new California Alternate Assessment for Science (CAA for Science); and the California Spanish Assessment (CSA), aligned with the Common Core State Standards in Español. This requires the addition of testing procedures and policies consistent with those assessments. Additionally, the assessment consortium of which California is a member, Smarter Balanced Assessment Consortium (Consortium), recently made changes in some of its policies; changes with which the CAASPP regulations must conform by state law in order to ensure that test results are valid and reliable. Finally, the new Every Student Succeeds Act (ESSA) introduced additional requirements to the CAASPP System related to the testing of the most significantly cognitive disabled pupils. As required by EC Section 60640(q), Title 5 of the California Code of Regulations sections 850 through 859 were amended to conform the state’s testing regulations to the CAASPP System.

CAASPP test results are used to improve teaching and learning by schools and districts in California. The CAASPP tests are also developed, administered, and reported in accordance with federal requirements. The proposed amendments are designed to assure that the tests within the CAASPP are administered fairly and consistently throughout the state so that valid and reliable results are available for accountability determinations and to provide schools and educators with accurate information to improve student learning, and in so doing, prevent harm to the public peace, health, safety, and general welfare and progress of California pupils.

PROBLEM AGENCY INTENDS TO ADDRESS

The existing regulations are not fully aligned to changes as a result of the development of three new CAASPP assessments: the CAST, the CAA for Science, and the CSA. Additionally, procedures and guidance for test administration and reporting procedures need to be updated to address the findings by the CDE and its testing contractor for areas that needed improvement in order to increase efficiency and safeguard against delays and/or errors in reporting. The regulations must again be revised to accommodate the addition of the new tests (their eligibility criteria and the accessibility supports for these assessments); to add definitions for clarity; to make changes to the list of the approved resources resulting from the Consortium’s annual review process; and to address the requirements introduced by the ESSA to the CAASPP System.

The purpose of the proposed amendments is to ensure the correct, efficient, and standard administration of the CAASPP online assessments through added clarity and consistency in the procedures and requirements for their development, administration, and reporting. The proposed amendments will thereby maintain accuracy, reliability, and validity of measures.

BENEFITS ANTICIPATED FROM REGULATORY ACTION

The benefits of enacting the proposed amendments are the promotion of an optimal and fair test administration for eligible pupils. The clarification of terminology and supports introduced by the addition of the new CAASPP tests will aid local educational agencies (LEAs) and educators in selecting and activating accessibility resources to pupils who can benefit from them, including supports for English learners (ELs). Additionally, the proposed amendments support increased local control and maintain validity, reliability, and accuracy of statewide achievement scores used for the purposes for guiding instruction, gauging pupils’ readiness for career and college, and for meeting state and federal accountability requirements.

SPECIFIC PURPOSE OF EACH SECTION – GOV. CODE SECTION 11346.2(b)(1)

The specific purpose of each adoption or amendment, and the rationale for the determination that each adoption or amendment is reasonably necessary to carry out the purpose of which it is proposed, together with a description of the public problem, administrative requirement, or other condition or circumstance that each adoption or amendment is intended to address, is as follows:

General changes are made to the regulations to include grammatical edits, and renumbering and/or relettering to reflect deletions or additions. For consistency throughout the regulations, “student” has been replaced with “pupil” and “CAASPP assessment system” with “CAASPP System.”

SECTION 850

Section 850(d) is amended to align with the new Every Student Succeeds Act language. The word “most” is added to the description of pupils who are eligible to take the alternate assessments in accordance with the new ESSA law as “most significant cognitive disabilities.”

Proposed section 850(g), former Section 850(h) is amended to add “and science,” and “most” to qualify “significant cognitive disabilities.” The additions are necessary in order to add the new California Alternate Assessment for science and to bring description of the pupils who are eligible for taking it in alignment with the new ESSA law terminology.

Former section 850(i) deletes the definition for “California Alternate Performance Assessment for Science (CAPA Science).” The deletion is necessary because the CAPA Science is no longer administered.

Former section 850(j) deletes the definition for the “California Modified Assessment for Science (CMA Science).” The deletion is necessary because the CMA Science is no longer administered.

Former section 850(k) deletes the definition for “California Standards Test for Science (CST Science).” The deletion is necessary because the CST Science is no longer administered.

Proposed section 850(h) adds the definition for “California Spanish Assessment (CSA).” The definition is necessary to ensure consistent terminology because the CSA will be the new primary language assessment for Spanish to replace the STS.

Proposed section 850(i) adds the definition for “California Science Test (CAST).” The definition is necessary because the CAST is the new CAASPP test that is aligned to the state-adopted content standards for science, the California Next Generation Science Standards (NGSS). Eligibility criteria, accessibility supports and testing procedures must be added for the new test which is currently in development.

Proposed section 850(r) adds the definition for “operational.” The definition is necessary because the term clarifies that reporting and testing procedures and requirements apply to operational tests only, and not to pilot or field tests.

Section 850(s), former section 850(t)is amended to delete “a successor test” and replace it with “the CSA.” The amendments are necessary to clarify that the CSA (the California Spanish Assessment) will be the new primary language assessment for Spanish. It is also amended to delete “available” and replace with “operational”. This is necessary to clarify that the STS will be available until CSA pilot and field testing is completed. Finally, this section is also amended to add language indicating that the accessibility supports in section 854.4 do not apply to the STS. This is necessary for clarification.

Proposed section 850(u) adds the definition for “pupils with most significant cognitive disabilities” as referenced in the new Every Student Succeeds Act law. The definition includes specific description of pupils who are eligible to take the alternate assessments for added clarity.

Section 850(v) is amended to delete “on or.” The amendment is necessary to align with dates used for accountability calculations for English learners. Instead of “on or after April 15th,” it now states: “after April 15th.”

Section 850(x) is amended to correct the reference to section 853.8 to 854.9. This revision is necessary because section 853.8, regarding unlisted resources, has been deleted and incorporated into proposed section 854.9.

Section 850(aa) is amended to change “test” to “assessment” for the primary language assessment. This change is necessary in order to align with terminology used in California Education Code.

Proposed section 850(aj), former section 850(ai) is amended to correct the reference to section 854.5. This revision is necessary because the former section 853.6, regarding alternate assessment supports, has been deleted and incorporated into the proposed section 854.5.

SECTION 851

Section 851(a) is amended to replace the term ”test” with “assessment.” This amendment is necessary in order to bring regulation terminology related to the primary language assessment in alignment with the Education Code.

Section 851(b) is amended to specify when the pupil’s grade will be “locked down” for use in scoring and reporting procedures. This amendment is necessary as inconsistencies related to pupil’s tested grade level and enrolled grade level contribute to inaccurate information about pupils’ progress to pupils themselves, their parents, their teachers, and for accountability purposes. These errors have occurred with sufficient frequency to warrant a change in procedures to ensure test results match grade level tested.

SECTION 851.5

Proposed section 851.5(c), former section 851.5(d) is amended to specify content areas for California Alternate Assessments (CAAs). “ELA and mathematics” are added to designate the specific content areas for the CAAs, for clarity, in light of the introduction of CAA for science.

Proposed section 851.5(d), former section 851.5(g) is amended to include the new California Science Assessment (CAST), which is aligned to the state-adopted California Next Generation Science Standards (NGSS). The amendments are necessary to incorporate the new CAST and set forth eligibility requirements for its administration.

Section 851.5(e) is amended to replace the CAPA with the California Alternate Assessment for science (CAA for science), the successor alternate assessment to the CAPA for science. The amendments are necessary to clarify the eligibility criteria for pupils taking the CAA for science.

Former Section 851.5(f) is deleted because the California Modified Assessment Science (CMA Science) is no longer administered.

Proposed section 851.5(f) is added to specify which pupils are eligible to take the new primary language assessment. The addition is necessary to provide guidance to local educational agencies (LEAs) and to define which pupils are eligible to take this test.

Proposed section 851.5(g), former section 851.5(c) is amended to show the grade levels for eligible pupils for the optional Standards-based Test in Spanish (STS). The amendment replaces “a pupil in grades 3 through 8 and 11” with “a pupil in grades 2 through 11.” The amendment is necessary in order to bring the eligibility criteria in line with the grades for which the test is available as an optional assessment.

Section 851.5(h) is amended to add the word, “operational.” This amendment is necessary to clarify that pupil score reports are required to be issued for only the operational assessments.

SECTION 853.5

NOTE Regarding Former Sections 853.5(a) through (g): Former section 853.5 has been deleted. The deletion is necessary to allow for the reorganization of the information regarding which embedded and non-embedded accessibility resources are available for each of the CAASPP assessments. The purpose for this reorganization is to facilitate accurate and easy use of the information. The list of available embedded and non-embedded universal tools, designated supports, and accommodations included in former 853.5 will be reorganized and added under the new sections 854.1 through 854.4 with only minor changes for grammatical and organizational consistency. Any substantive changes made to any of the information contained in the deleted sections will be noted specifically for sections 854.1 through 854.4 below, by subsection.

Former Section 853.5(a) is deleted. The deletion is necessary to allow for the reorganization of the available embedded universal tools in a way which will increase clarity and ease of use. The list of embedded universal tools as they are relevant for each of the CAASPP tests is now incorporated under the following proposed sections which are dedicated to specific CAASPP tests as follows: section 854.1(a) for ELA; section 854.2(a) for mathematics; section 854.3(a) for CAST; and section 854.4(a) for primary language assessment.

Former Section 853.5(b)is deleted. The deletion is necessary to allow for the reorganization of the available non-embedded universal tools in a way which will increase clarity and ease of use. The list of non-embedded universal tools as they are relevant for each of the CAASPP tests is now incorporated under the following proposed sections which are dedicated to specific CAASPP tests as follows: section 854.1(b) for ELA; section 854.2(b) for mathematics; section 854.3(b) for CAST; and section 854.4(b) for primary language assessment.

Former Section 853.5(c)is deleted. The deletion is necessary to allow for the reorganization of the available embedded designated supports in a way which will increase clarity and ease of use. The list of embedded designated supports as they are relevant for each of the CAASPP tests is now incorporated under the following proposed sections which are dedicated to specific CAASPP tests as follows: section 854.1(c) for ELA; section 854.2(c) for mathematics; section 854.3(c) for CAST; and section 854.4(c) for primary language assessment.

Former Section 853.5(d)is deleted. The deletion is necessary to allow for the reorganization of the available non-embedded designated supports in a way which will increase clarity and ease of use. The list of non-embedded designated supports as they are relevant for each of the CAASPP tests is now incorporated under the following proposed sections which are dedicated to specific CAASPP tests as follows: section 854.1(d) for ELA; section 854.2(d) for mathematics; section 854.3(d) for CAST; and section 854.4(d) for primary language assessment.

Former Section 853.5(e)is deleted. The deletion is necessary to allow for the reorganization of the available embedded accommodations in a way which will increase clarity and ease of use. The list of embedded accommodations as they are relevant for each of the CAASPP tests is now incorporated under the following proposed sections which are dedicated to specific CAASPP tests as follows: section 854.1(e) for ELA; section 854.2(e) for mathematics; section 854.3(e) for CAST; and section 854.4(e) for primary language assessment.

Former Section 853.5(f)is deleted. The deletion is necessary to allow for the reorganization of the available non-embedded accommodations in a way which will increase clarity and ease of use. The list of non-embedded accommodations as they are relevant for each of the CAASPP tests is now incorporated under the following proposed sections which are dedicated to specific CAASPP tests as follows: section 854.1(f) for ELA; section 854.2(f) for mathematics; section 854.3(f) for CAST; and section 854.4(f) for primary language assessment.

Former Section 853.5(g) is deleted. The deletion is necessary to allow for the reorganization of the information about available accessibility resources for the CAASPP assessments in a way that increases clarity and ease of use. Former Section 853.5 (g) is now incorporated under the relevant subsections for the CAASPP tests as follows: proposed section 854.1(g) for ELA; and proposed section 854.2(g) for mathematics.

SECTION 853.6

Former Section 853.6 has been deleted. The deletion is necessary in order to reorganize the information related to CAASPP accessibility supports for each of the CAASPP tests individually. Accessibility supports for the California Alternate Assessments (CAAs) that were provided under the former section 853.6 are now shown in the proposed section 854.5.

SECTION 853.7

Former Section 853.7(a) is deleted. The amendment is necessary in order to most efficiently and clearly indicate the availability of language supports for English learners that are included in the accessibility resources for CAASPP assessments. The original intent of listing designated supportsunder a separate section (section 853.7) for English learners is preserved through revision of the introductory paragraphs for the embedded and non-embedded designated supports for each of the CAASPP tests; these now specifically state that language supports which may benefit both English learners and reclassified fluent English proficient pupils are included in the list of designated supports. This revision applies to the following proposed sections: 854.1(d); 854.2(c) and (d); 854.3 (c) and (d); and 854.4(d).

SECTION 853.8

Section 853.8 is deleted because it is no longer necessary since the information contained in it about unlisted resources is now incorporated in the proposed section 854.9.

SECTION 854.1

NOTE Regarding Sections 854.1 (a) through (g): Proposed section 854.1 lists the universal tools, designated supports, and accommodations for ELA that were included under former section 853.5 (a) through (g). Minor changes for grammatical and organizational consistency have been made. Additional changes to any of the information or lists of supports contained in the deleted sections are noted specifically under each particular subsection. The purpose for this reorganization is to facilitate clear and easy use of the information by local education agencies and other users.

Proposed Section 854.1(a) adds the list of approved embedded universal tools for the CAASPP ELA assessment. This addition is necessary in order to reinsert into regulations the information which was formerly included in the deleted section 853.5(a).

Proposed Section 854.1(b) adds the list of approved non-embedded universal tools for the CAASPP ELA. This addition is necessary because it reinserts into regulations this information which was formerly included in the deleted section 853.5(b).

Proposed section 854.1(c) adds the list of approved embedded designated supports for the CAASPP ELA assessment. This addition is necessary in order to reinsert into regulations the information which was formerly included in the deleted section 853.5(c).

Proposed Section 854.1(d) adds the list of approved non-embedded designated supports for the CAASPP ELA assessment. This addition is necessary in order to reinsert into regulations the information which was formerly included in the deleted section 853.5(d). Also added to the proposed section (not included previously) is new language informing users about the availability of non-embedded designated supports for the ELA assessment that may benefit English learners and reclassified fluent English proficient pupils. Additionally, a new support, simplified test directions, is added to conform to changes in Consortium policy per former section 853.5(g) and proposed section 854.1(g) and the current support of “bilingual dictionary” was amended to indicate its use specifically for “ELA performance task(s) - full write, not short paragraph responses, and writing” for clarity.