MASSACHUSETTS ASSOCIATION OF SCHOOL SUPERINTENDENTS (MASS)

Thursday, February 25, 2021

MCAS Test and ACCESS Test 2021:

A Contradiction of Purpose and Use during a pandemic

Over the past few months the Massachusetts Board of Education and the Massachusetts Department of
Elementary and Secondary Education (DESE) have insisted that both the MCAS and ACCESS are the only
assessments that will measure student learning loss due to Covid-19 and therefore school districts need to prepare to
assess students. We ask our legislators to use their “bully pulpit” to insist that DESE allow local formative and
benchmark assessments be used to measure and intervene on student learning loss in lieu of state mandated
assessments. We also ask our legislators to support recently filed HD1448 - An Act to cancel the administration of
the MCAS for the 2020-2021 school year.

Below we present the position statements from the BOE, Commissioner and/or DESE regarding the need to
administer both assessments, and our counter arguments to those ideas.

BOE, Commissioner, and DESE Position Our Counter Position

Educational use
Both MCAS and ACCESS need to be 1) School districts are better served measuring student learning loss through the
administered to measure student learning loss and use of local diagnostic assessments (formative and benchmark). MCAS is a
student language proficiency. summative assessment measuring the level of learning toward the MA
Curriculum Standards.
2) Learning loss during Covid is more nuanced and local assessments are a
better diagnostic of the missing learning progressions (missing building
blocks toward) needed to attain proficiency of a curriculum standard.
3) Both MCAS and ACCESS results arrive too late to allow for any effective
diagnostic intervention planning to be done for students. The local “real
time” assessments used by districts are far timelier and more usable on
behalf of students.
4) For many non-Title I districts who do not benefit from federal stimulus
monies the estimated $30 million cost to administer MCAS this year could
be better used to address and remediate already known learning loss.
MCAS and ACCESS will be used as a diagnostic 1) For all the reasons stated above—we believe it is misleading to state that
only by districts; results will not be used for MCAS and ACCESS may be used as a diagnostic on true student learning
accountability purposes; results will be posted. and progressions.
2) Results will not be used for accountability this year, however the mere fact
that results will be posted will mean that school districts will be compared to
each other and the shaming game will commence without the context of local
differences each district has had to deal with during this pandemic. This
comparison and shaming could result in further decline of student
enrollment.
3) Results will be invalid and unreliable as a diagnostic due to variability
district to district, school to school, household to household.
4) While the 2021 test scores are not to be used for accountability this year, we
also should not be using 2021 test scores to set future district and school
performance/accountability targets due to the lack of validity.
 Educational use (continued)
ACCESS will be used to place students in a 1) We have per DESE Guidance documents, never used ACCESS solely to
language proficiency level and to determine if the determine either of these student needs: language level nor exit criteria.
student is ready to exit the program. ACCESS has always been used as one of many local criteria – with the
English Language Learner (ELL) team making the final decision.
2) ACCESS was successfully administered to all ELLs in the state last January-
this along with local assessments and team decision making should be the
allowed guidance.
3) ELL Guidance documents from DESE recommend and provide a full list of
alternative assessments that can be used in addition to ACCESS- we support
using this list in lieu of ACCESS for this one year.
Concern for the social/emotional needs of our 1) The added stress having to enter a school, and for some it will be the
students struggling with added stressors due to the first time in 12 months, for a test; a student population deemed to be in
pandemic. crisis.
2) There will be skewed results from communities hit hardest by the
pandemic as well as skewed results from our high needs and special
populations.
Challenges
Value of student learning time as evidenced by the 1) Districts have sent home all devices that would have been used to administer
SLT surveys and BOE mandate for student MCAS and ACCESS tests.
learning time during the pandemic. 2) Districts would now need to collect the devices with enough lead time to
ensure that the devices are in full working order and have the devices ready
for test administration.
3) This will effectively result in leaving students without devices for the regular
teaching days-therefore an actual loss of instructional time; in other
words, “more testing will result in more asynchronous instruction, not less”
as DESE wants.
4) ELLs will be most adversely and disproportionately impacted because they
would need to go through this process twice thereby creating a greater
inequity of instruction to a most at-risk group.
Requirement per MCAS and ACCESS test 1) Districts are having difficulty providing enough licensed educators for daily
administration guidance for a licensed educator to instruction. The staffing capacity of school districts this year more than any
provide in-person proctoring- staffing other year is stretched and having to cover both the instructional day when it
is hybrid and remote as well as in-person testing will mean running three
school structures.
2) The cost of running three school structures will use valuable ESSER
resources that are needed for return and recovery. These funds would be
better spent providing critical instruction to address learning loss.
3) Districts who have been fully remote and/or hybrid will need to return to
collective bargaining on the impact of the change in working conditions if
teachers who have been remote or partially in person need to be fully in-
person to proctor testing.
4) The additional human resource capacity needed to provide for all legal
student testing accommodations for students with special education needs
and students with second language acquisition needs.
5) In a normal year, state testing requires all hands-on deck to provide for all
special education and ELL accommodations – to do so in the current
environment will be a staffing nightmare that may set many districts up for
failure and possible litigation if unable to fulfill individual student testing
accommodations.
 Challenges (continued)
Requirement to have all students in-person taking 1) Initial surveys in some districts show increased number of parents who are
the test. not willing to send their child to school simply to be tested- therefore lower
participation rates will skew results and any valid use of these results by the
state—again making the case for local diagnostic assessments and data use
as being the most valid and useful in these circumstances.
2) Operational difficulties of testing in an environment of social distancing and
the resulting longer testing windows needed because of limited square foot
capacities in brick and mortar school buildings.
3) The National Assessment of Educational Progress (NAEP) is postponing the
2021 assessment administration due to safety issues but also potentially
flawed valid and reliable results.
Alternative Considerations
MASS respectfully request the following 1) Allow for local diagnostic assessments (benchmark and formative) to be
alternatives to the one-size fits all state MCAS test used in lieu of MCAS.
be considered for the 2021 year. 2) If accountability is an issue—have DESE require each district to submit
student data from local assessments that will be used in lieu of MCAS
this year and/or use Student Learning Tim (SLT) data in conjunction
with local assessments in lieu of MCAS.
3) If the federal US DOE does not allow a waiver- then provide for testing
only in those grades mandated by US DOE and not the expanded grades
tested under Massachusetts statue.
4) If testing in all grades continues to be expected, provide for MCAS tests
to be taken remotely – online and at home if a school district so chooses.
5) Elongate the test administration window and allow for local districts to
administer in summer or fall if they so choose.

In closing, we know you will hear from Secretary of Education Peyser and Commissioner Riley the
decision is not theirs to make. They will explain that first, US DOE must issue a waiver before MA BOE can
address our MA statute. Both Secretary Peyser and Commissioner Riley are correct, states must request the federal
waiver and ultimately then it becomes a state decision. States like New York and Michigan have already sought out
waivers. It is important to note that waivers can cover a request for a complete moratorium to a request for
adjustment or modification in the administration tool- such as allowing for local assessments to stand in lieu of state
sanctioned tests.

Massachusetts should be “leading the way” in this area, and we are not. As superintendents, we are not
afraid of accountability and if necessary we will provide data from locally administered formative and benchmark
assessments; however, we are against traditional administration of in-person, state mandated assessments this year.
We ask then, that 1) both the Secretary and Commissioner in their roles advocate to US DOE and newly appointed
Secretary of Education Miguel Cardona to proceed with a federal waiver of both state standardized testing and state
language proficiency testing as described in the alternative considerations section listed above; and, 2) the MA BOE
prepare to vote in favor of the state waiver of both assessments.

We are educational leaders, we are the “chief child advocates” of our school districts. We are the experts,
the professionals in this area. We know best during this time how to measure learning loss and how to proceed out
of this pandemic toward addressing student learning loss without the scale of disruption in-person state mandated
testing will cause. We should not be spending our time trying to operationalize test administration of students which
ultimately will only serve to be a perfunctory compliance task that is stealing our valuable time away from efforts
toward a healthy return, recovery, and acceleration of learning for all – and for us in our school districts, the return
must start with vaccination of our educators. We respectfully ask you for your support.