The EdTrust–New York submitted the following inquiry seeking additional information about how the New York State Education Department will calculate its “Composite Performance Index:”
January 19, 2018
The Honorable Betty A. Rosa
Chancellor
Board of Regents
New York State Education Building
89 Washington Avenue
Albany, NY 12234
The Honorable MaryEllen Elia
Commissioner of Education and President of
the University of the State of New York
New York State Education Building
89 Washington Avenue
Albany, NY 12234
Dear Chancellor Rosa and Commissioner Elia:
Congratulations on the U.S. Department of Education’s approval of New York’s Every Student Succeeds Act (ESSA) accountability plan. We believe that a number of elements in the plan will advance equity for New York’s students, and we look forward to continuing to support these efforts.
We are writing to seek additional information about a new element introduced in the final approved plan – the “Composite Performance Index” – and hope that you can provide clarity.
By way of background, in its December 2017 initial response letter, the U.S. Department of Education (USDE) raised concerns with SED’s approach to calculating the academic achievement indicator, which proposed using the greater of PI-1 (based on at least 95 percent of test-eligible students) and PI-2 (based on only the number of students who were actually assessed). The USDE letter stated that: “Since only PI-1 appears to be consistent with the requirements in ESEA section 1111(c)(4)(E)(ii) for calculating the Academic Achievement indicator, only this calculation may be used for the purposes of calculating the Academic Achievement indicator for each school in the State and, as such, only this calculation may be used for purposes of school identification.”
While complex, this issue matters for a simple reason: we remain concerned that the accountability system could create an incentive for schools to discourage historically underserved groups of students – low-income students, students of color, English language learners, students with disabilities, and others – from being counted in state assessments that would shine a light on the school’s performance.
As we understand the revised and approved plan, determinations about a school’s identification for Comprehensive Support and Improvement (CSI) and Targeted Support and Improvement (TSI) would now instead be made based on a Composite Performance Index. The plan indicates that the Composite Performance Index would be created by “combin[ing]” each school’s English language arts (ELA), math, and science Performance Indices (which are based on the greater of the number of students assessed or 95 percent of test-eligible students) with the school’s Core Subject Performance Index (which is based on only the number of students who were actually assessed, similar to PI-2).
The approved plan does not appear to describe how SED will “combine” the two indices, and we seek additional information about how this will occur. Based on the clear language of the law, we specifically seek SED’s confirmation that the Performance Indices based on the greater of the number of students assessed or 95 percent of test-eligible students will always receive the majority of the weighting:
• The law requires states to include an academic indicator of student proficiency in ELA and math in their system of school accountability. Section 1111(c)(4)(B)(i) describes this required indicator as being based on “academic achievement as measured by proficiency on the annual assessments…”
• The required academic indicator must be calculated using a denominator representing at least 95 percent of test-eligible students. Specifically, ESSA states that states must: “For the purpose of measuring, calculating, and reporting on the indicator described in subparagraph (B)(i), include in the denominator the greater of— (I) 95 percent of all such students, or 95 percent of all such students in the subgroup, as the case may be; or (II) the number of students participating in the assessments.”
• The required academic indicator with at least 95 percent of test-eligible students in the denominator must be used in the identification of schools for CSI and TSI. In fact, ESSA requires that the indicator be given “substantial weight” on its own.
Therefore, in combining the two indices, it would seem to violate the law if, for example, the required indicator was given no or little weight and the Core Subject Performance Index was given all or most weight.
We look forward to your response and would be happy to provide additional information.
Sincerely,
Ian Rosenblum
Executive Director