Michigan 1% Waiver with approval

44
UNITED STATES DEPARTMENT OF EDUCATION OFFICE OF ELEMENTARY AND SECONDARY EDUCATION The Honorable Sheila Alles May 14, 2018 Interim State Superintendent Michigan Department of Education 608 W. Allegan Street P.O. Box 30008 Lansing, MI 48909 Dear Interim Superintendent Alles: I am writing in response to the Michigan Department of Education’s (MDE) request on January 9, 2018, for a waiver of section 1111(b)(2)(D)(i)(I) of the Elementary and Secondary Education Act of 1965 (ESEA), as amended by the Every Student Succeeds Act (ESSA), of the requirement that a State may not assess using an alternate assessment aligned with alternate academic achievement standards (AA- AAAS) more than 1.0 percent of the total number of students in the grades assessed in the State. MDE requested this waiver because, based on State data for the 2016-2017 school year, the MDE has concluded that it will need to assess more than 1.0 percent of students using an AA-AAAS in reading/language arts, mathematics, and science in the 2017-2018 school year. After reviewing MDE’s request, I am granting, pursuant to my authority under section 8401(b) of the ESEA, the following waiver for school year 20172018: A waiver of section 1111(b)(2)(D)(i)(I) of the ESEA so that the State may assess with an AA- AAAS more than 1.0 percent of the total number of students in the State who are assessed in a reading/language arts, mathematics and science. As part of this waiver, MDE assured that the State educational agency: Will continue to meet all other requirements of section 1111 of the ESEA and implementing regulations with respect to all State-determined academic standards and assessments, including reporting student achievement and school performance, disaggregated by subgroups, to parents and the public. Assessed in the prior school year (2016-2017) at least 95 percent of all students and 95 percent of students with disabilities who are enrolled in grades for which an assessment is required. Will require that a local educational agency (LEA) submit information justifying the need of the LEA to assess more than 1.0 percent of its assessed students in any such subject with an AA- AAAS. Will provide appropriate oversight of an LEA that is required to submit such information to the State, and will make such information publicly available. 400 MARYLAND AVE., SW, WASHINGTON, DC 20202 http://www.ed.gov/ The Department of Education’s mission is to promote student achievement and preparation for global competitiveness by fostering educational excellence and ensuring equal access.

Transcript of Michigan 1% Waiver with approval

UNITED STATES DEPARTMENT OF EDUCATION OFFICE OF ELEMENTARY AND SECONDARY EDUCATION

The Honorable Sheila Alles May 14 2018 Interim State Superintendent Michigan Department of Education 608 W Allegan Street PO Box 30008 Lansing MI 48909

Dear Interim Superintendent Alles

I am writing in response to the Michigan Department of Educationrsquos (MDE) request on January 9 2018 for a waiver of section 1111(b)(2)(D)(i)(I) of the Elementary and Secondary Education Act of 1965 (ESEA) as amended by the Every Student Succeeds Act (ESSA) of the requirement that a State may not assess using an alternate assessment aligned with alternate academic achievement standards (AA-AAAS) more than 10 percent of the total number of students in the grades assessed in the State MDE requested this waiver because based on State data for the 2016-2017 school year the MDE has concluded that it will need to assess more than 10 percent of students using an AA-AAAS in readinglanguage arts mathematics and science in the 2017-2018 school year

After reviewing MDErsquos request I am granting pursuant to my authority under section 8401(b) of the ESEA the following waiver for school year 2017ndash2018

bull A waiver of section 1111(b)(2)(D)(i)(I) of the ESEA so that the State may assess with an AA-AAAS more than 10 percent of the total number of students in the State who are assessed in a readinglanguage arts mathematics and science

As part of this waiver MDE assured that the State educational agency

bull Will continue to meet all other requirements of section 1111 of the ESEA and implementing regulations with respect to all State-determined academic standards and assessments including reporting student achievement and school performance disaggregated by subgroups to parents and the public

bull Assessed in the prior school year (2016-2017) at least 95 percent of all students and 95 percent of students with disabilities who are enrolled in grades for which an assessment is required

bull Will require that a local educational agency (LEA) submit information justifying the need of the LEA to assess more than 10 percent of its assessed students in any such subject with an AA-AAAS

bull Will provide appropriate oversight of an LEA that is required to submit such information to the State and will make such information publicly available

400 MARYLAND AVE SW WASHINGTON DC 20202 httpwwwedgov

The Department of Educationrsquos mission is to promote student achievement and preparation for global competitiveness by fostering educational excellence and ensuring equal access

Page 2 ndash The Honorable Sheila Alles

bull Will verify that each LEA that is required to submit such information to MDE is following all State guidelines in 34 CFR sect 2006(d) (with the exception of incorporating principles of universal design) and will address any subgroup disproportionality in the percentage of students taking an AA-AAAS

bull Will implement consistent with the plan submitted in MDErsquos waiver request system improvements and monitor future administrations of its AA-AAAS to avoid exceeding the 10 percent cap

I appreciate the work you are doing to improve your schools and provide a high-quality education for your students If you have any questions please contact Tahira Rashid of my staff at OSSMichganedgov

Sincerely

s Jason Botel Principal Deputy Assistant Secretary Delegated the Authority to Perform the Functions and Duties of the Assistant Secretary of Elementary and Secondary Education

APPENDIX A

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING RICK SNYDER GOVERNOR

BRIAN J WHISTON STATE SUPERINTENDENT

MEMORANDUM

DATE November 16 2017

TO Local and Intermediate School District Superintendents Public School Academy Directors

FROM Brian J Whiston State Superintendent Michigan Department of Education

SUBJECT Alternative assessment waiver request for the 1 cap

Michiganrsquos alternate assessment (MI-Access) is aligned to the Michigan alternate content standards in English Language Arts (ELA) mathematics science and social studies This alternate assessment is designed to allow students with the most significant cognitive disabilities to demonstrate their knowledge and skills

Under No Child Left Behind (NCLB) there was no limit to the number of students who could participate in this alternate assessment but rather there was a 1 cap on the number of proficient scores that could come from an alternate assessment as it related to the statersquos accountability system

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills However the law changed and rather than placing a cap on accountability proficiency rates for the alternate assessment the regulations for the number of students participating in the alternate assessment shall not exceed 1

This shift means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

It is important to note that decisions regarding who takes an alternate assessment continues to rest with the Individualized Education Program (IEP) team The team must follow the state guidelines for participation in the alternate assessment

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH ndash CO-PRESIDENT bull RICHARD ZEILE ndash CO-PRESIDENT MICHELLE FECTEAU ndash SECRETARY bull TOM MCMILLIN ndash TREASURER

NIKKI SNYDER ndash NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO B OX 30008 bull LANSING MICHIGAN 48909 wwwmichigangovmde bull 517-373-3324

Page 2 November 16 2017

The Michigan Department of Education (MDE) has been taking steps to ensure that educators in the state understand the assessment selection guidance to determine which assessment a student should take Enhanced training opportunities on the selection guidance will be offered via video training and at various workshops this winter

There are several provisions that accompany the state level cap on participation in the alternate assessment While ESSA does limit the total number of students in the state who are assessed using an alternate assessment based on alternate achievement standards the following provisions are also made

bull A state may not prohibit an LEA from assessing more than 10 percent of its assessed students using an alternate assessment However LEAs that exceed this participation rate must provide justification for exceeding this rate States must make this justification publicly available and provide oversight to LEAs that exceed this rate

Based on data collected from the spring 2017 testing window Michigan has calculated the current rate of students taking an alternate assessment in the state is 24 for English Language Arts 24 for mathematics and 23 for science To demonstrate our plan to bring Michigan into compliance with this regulation MDE will be applying for a waiver for the 2018 testing window as provided for by ESSA which will be submitted to the US Department of Education (US ED) MDE is seeking comments on the waiver application from all interested parties

As required Michiganrsquos waiver application will (inclusive of grades 3-8 and 11) bull Be submitted at least 90 days prior to the start of the testing window bull Provide state-level data from the 2017 testing cycle to show the number and percentage of students (including sub-groups) who took an alternate assessment of all students tested in each subject

bull Demonstrate that Michigan has tested at least 95 of all students and 95 of students with disabilities across all summative assessments and

bull Provide assurances that LEAs contributing to the state exceeding the 1 cap have adhered to the participation guidelines and address any disproportionality in any sub-group of students taking the alternate assessment

Further the waiver will include a plan and timeline by which the state will bull Improve the implementation of its guidelines on the alternate assessment bull Take additional steps to support and provide oversight to each LEA that contributes to the state exceeding the 1 cap and

bull Address any disproportionality in the percentage of students taking the alternate assessment

As we move forward to align with the requirements of ESSA as it relates to alternate assessments it is important to note how this supports MDErsquos Top 10 in 10 initiatives

bull The work is aligned across offices and with appropriate agencies The collection of data communication and technical support is a collaborative effort between the Office of Special Education (OSE) and the Office of

Page 3 November 16 2017

Educational Assessment and Accountability (OEAA) with local information and support coordinated at the ISD level

bull Beyond looking at data in isolation the work is aimed at focusing on child-centered needs ensuring that students are being assessed in ways that are most appropriate to their needs and aligned to the rigorous standards to which they are being instructed on a daily basis

For any interested party comments may be left in the following ways bull Survey httpswwwsurveymonkeycomr1percent_waiver_MI bull Email mde-oeaamichigangov (be sure to include ldquo1 alternate assessment waiverrdquo in the subject line)

bull Via mail Michigan Department of Education 608 W Allegan Street PO Box 30008 Lansing MI 48909 Attn OEAA 1 waiver ndash 2nd floor

The following resources are available on the MI-Access Web Site (wwwmichigangovmi-access) with direct links provided here

bull Michiganrsquos guidelines for participation in the alternate assessment (MI-Access) Alternate Assessment Guidelines

bull Guidelines for ISDrsquos to provide support to LEAs regarding the 1 cap 1 cap ISD Guidance

bull Michiganrsquos alternate content standards alternate content standards

For further information contact John Jaquith at jaquithjmichigangov or 517-335-1987

cc Michigan Education Alliance

Appendix B

Public Comment Responses (in exact language)

Question 1

1 Please comment on Michigans current rate of participation in the

alternate assessment (24 English Language Arts 24 mathematics

23 science)

Does anyone working in the field of education understand what this means for students You want to allow schools to not educate students This is what happens Schools use this as a loophole If you dont believe me PLEASE look at Wayne Resas Special education Plan for students with mutliple needs Segregated sent away and given up on before ever given a chance You are ruining entire life outcomes 12192017 112 PM

To limit the number of students within these subgroups that can take an alternate assessment is unfair We need to be giving our students the assessment that is appropriate for each of them individually based on IEPs 12182017 1241 PM

Students need to be assessed where there skills lieand aligned to IEP goals I dont think a percentage should determine who takes which test 12172017 1212 AM

I believe these rates of over 2 are adequate 1 participation rate is a cookie-cutter formula that defies IDEAMARSE rules and regulations giving the IEPTeam the responsibility of determining which assessment is appropriate for the student based on their individualized level of functioning and needs Participating in alternate assessments is a decision that should be made by the IEPTeam with parentguardian it should not be made because of a unrealistic 1 Cap rule 12142017 813 AM

Just by looking at the normal distribution curve one would expect 21 of the

population to fall 2 standard deviations below the mean I think we might be able to improve the participation rate and how we determine who takes which assessment

through additional training and better analysis of our existing test data IEP teams are currently making these decisions which seems consistent with the law The question i would ask is what are we hoping to gain from this type of assessment

for students with cognitive impairments What is the intent What is gained through this assessment How does it lead to better learning outcomes How does

it improve the outcome for students How does it help instruction What do these assessments (functional independence participation) add to our instructional knowledge for the student What is the intended purpose of these tests How do

they benefit the student or lead to better instruction

12132017 316 PM

Should we look at the need of each child

12132017 258 PM

I wonder if the limit should be adjusted

12132017 225 PM

I feel they are high but in relation to other states Michigan is underfunding their Special Education Programing period 12132017 130 PM

The reason our current rate over 1 in the state of michigan is due to the fact that we assess ALL students Many states only assess mild CI or those that would take Functional Independence I do not believe we would have an issue if we only included participation rates for students participating in FI-MI-Access 12132017 1052 AM

How does Michigans overall participation rate compare to other states Are other states exempting students from assessments that we are including in our alternate assessment 12132017 1014 AM

Although the percentage is much higher than maybe anticipated the assignment of the State assessment is made through an IEP decision making process I would have to believe that the IEP teams are making accurate recommendations based on students cognitive abilities 12122017 1256 PM

When evaluating participate rate in alternate assessments there are several factors that need to be considered The first is overall participation rate in statewide

assessments When reviewing MI School Data Students not Tested in Michigan it is clear that Michigans overall participation rate is incredibly high As the participation

rate increases it is logical that the percentage of students taking alternate assessments will also increase Michigans rate of participation in alternate assessments may not be that high when taking the overall participation rate into

consideration If Michigan were to decrease their overall participation rate and begin exempting groups of students from assessment it would be quite easy to

lower the participation in alternate assessments I dont believe that should be our goal but it is important that we are using data that is truly comparable if we are comparing ourselves to other states The second is the percentage of students with

Cognitive Impairments (or those that function as if they have severe cognitive impairments) in the state In 2016-2017 Michigan had 19249 students eligible as

having a Cognitive Impairment In that same year Michigan had 1532335 total students That means that 125 of our students had Cognitive Impairments While not all CI students are appropriate for alternate assessments many would be In

addition there are also students in other eligibility categories such as SXI (an

additional 2 of students) that would most likely be appropriate for an alternate assessment The eligibility of ASD would also have some students that function as if they have a severe cognitive impairment that may be appropriate for alternate assessments The third which I couldnt find easy access to the data is percentage of students participating in the various levels of our alternate assessments I do believe there are students taking the Functional Independence assessment that would be appropriate for the general assessment However I do not believe in my experience that we have students taking Supported Independence or Participation that would be appropriate for the General Assessment I think it would be valuable to look at the percentage participating in each level of our alternate assessment so we know if we need to be focusing our efforts on the FI level or if there would be a need to even look at SI or P in order to get us to the 1 level 12122017 1141 AM

This seems to be consistent with many LEAs around the state and does not seem excessive 1292017 908 AM

According to a review of our county data regarding participation in the alternate assessment we are almost to 1 just counting the number of students taking Supported Independence and Participation I would be curious about the other counties throughout state as it relates to the alternate assessment participation rates in the areas of Supported Independence and Participation Assessments Students attending programs for moderately cognitively impaired and programs for severe cognitive impairment account for 68 of the population of students with IEPs and 229 of these students are enrolled in grades 3-8 and 11 1282017 223 PM

In looking at data the SXI population alone last year was at 17 so to think that Michigan will ever be under 1 is a challenge Because Autism is such a broad spectrum it is a challenge to be at 1 if you also add in severely cognitively impaired students My point being does the state know the actual percentage of significantly impaired students in the state 1282017 1240 PM

Michigan has a higher rate of assessment participation because we assess more students than other states do 1262017 1044 AM

I feel that limiting the cap to 1 is an can be detrimental to those students who are not cognitively at the level needed to test other than with an alternate assessment A waiver is needed to go beyond 1 1242017 1249 PM

According to the American Community Survey the percentages of people with

disabilities have remained relatively unchanged since 2008 Total percentage of

people with a cognitive impairment is 48 which includes over age 65 24 taking an alternative assessment seems aligned with the data and reasonable 1242017 1111 AM

The request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform on a standardized assessment 1242017 836 AM

It is an IEP team decision for each student to take an alternative assessment It seems that if we have to stay below the 1 it is forcing IEP teams to not look at the individual students need based on data 1232017 847 PM

If these students are in fact receiving Alternate Content Standards and are accurately placed in a program that challenges their abilities then the percentages given are justified 1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt 1212017 1156 AM

Even this seems very low to me There are hundreds of children taking tests that are way beyond their ability to comprehend them I really wish I understood what we are trying to prove 1212017 1154 AM

School districts who operate regional programs for students with cognitive impairments are at a disadvantage with this cap We espouse the virtue of the IEP team making the assessment decision yet we punish districts for going over the arbitrary standard Another disadvantage is we are no longer sending scores back to home districts 11212017 139 PM

As MMC is a college preparatory curriculum and the assortment of MSTEP assessments are intended to measure this curriculum requiring all but 1 of students to demonstrate understanding of that content is inappropriate Additionally consideration of a normally distributed bell curve would suggest 2 of the population falls in the CI range Beyond that parts or all of MSTEP andor MME could be inappropriate for students with severe learning disabilities In light of these normal distributions and the nature of the MMC and its assessments Michigan assessing just over 2 with alternative measure suggests reasonable if not slightly rigid practice Put another way a valid argument MI is testing too many students with MSTEP and MME could be made 11212017 1228 PM

The decision to assess a student with an alternate assessment like MI-Access is ultimately an IEP team decision My concern with the reported percentages relates to each districts interpretation of the appropriateness for a child to be assessed using alternative tools Do we have consistency from district to district with the definition of severe cognitive impairment 11202017 1058 AM

We decide at a METIEP meeting which students have significant cognitive impairments (data cognitive scores) and which test they are able to take Our building has an high number of students who qualify to take the MIAccess because they have a cognitive impairment and they are functioning as if the they have a cognitive impairment Currently our districts participation in the MIAccess is 23 due to these students taking the test The students are in a Basic Classroom which has been labeled a High Needs Resource Room These students are not spread out into other buildings The non-participating students in the other buildings are never severe enough that there is no question that they are not counted for testing the students in the Communication Room are so low they are unable to speak The concern in our district is that these students in our building raise our percentage of participation in the MI Access testing although it is appropriate for the student The shift of concern now seems to be What is the percentage of student participation rather than What is appropriate for the whole child 11182017 723 AM

Very low numbers for high IEP numbers 11172017 1119 AM

This percentage seems to be accurate and although it exceeds the 1 cap we provide educational services to significantly impaired students across the state for whom the Mi Access assessment is the best choice for assessing these students academic knowledge 11172017 754 AM

I work in a district with a high number of students with disabilities A number of those students have or function as having a cognitive deficit Currently my district has 349 of students with IEPs taking alternate assessments As I understand the 1 cap administering Mi-Access to only those students with significant ASD impairments my district will be penalized (in some manner) if we administer the test to students with cognitive impairments 11162017 418 PM

Please look carefully at the makeup of each district and what programs are housed there I run an ISD center-based program for the county ALL of my students have significant disabilities ALL are on Mi-Access Other districts run things differently Michigan might really have that many students who require alternative assessments A deep dive is needed to investigate how alternative assessments are determined in each district 11162017 345 PM

As a special education director we have students who are in a Moderate Cognitively Impaired program and have been exposed to a modified curriculum throughout their educational career It is not in the best interest of them to expect them to participate in the MStep even if they arent considered Significant to many The MStep causes a tremendous amount of stress to students who arent in special education Our job as educators is to look at what is best for the students on an individual level not to make sure we meet a certain percentage Requiring the state to be at 1 or under isnt in the best interest of our students 11162017 310 PM

Based on MiSchool Data 2016-2017 the state of Michigan had 3500 students with a Severe Multiple Impairments (17) eligibility While this data is not reflective of the students in grades 3-8 amp 11 it does provide us with a piece of information Additionally this data does not include other students who function as if they have a significant cognitive impairment IDEA to my knowledge does not limit the number of students who may partake in an alternate assessment it is an IEP team decision I am not making excuses just stating facts Please understand we can always improve 11162017 249 PM

I would like to know the percentage of students that have an IEP that categorizes them as cognitively impaired etc 11162017 134 PM

The current Michigan rate reflects IEP team decisions regarding the appropriateness of participation for any one student IEP teams (parents included) know these students better than any legislator The overall understanding needs to exist that 24 or even 3 of all students does show that the vast majority of students who receive special education services are taking the general education assessment IEP teams have been selective with their decisions with regard to who will participate in the alternative assessment Legislators and the guidelines that are written need to have some level of flexibility for the IEP process 11162017 130 PM

22 of the population has an IQ below 70 Students with cognitive impairments are

working at the best of their ability and that includes an alternative curriculum with

an alternative assessment

Question 2

2 Please comment on what should be included in the plan and timeline for

improvement

Try inclusion real inclusion Kids with complex needs CAN LEARN They need to be provided the resources Ieprsquos need to be looked at for the students who already are not being educated look at the student when you see the amount of time a non verbal multi impaired child is getting for speech services who is attending a

segregated school Every kid in there needs these servuces Lumping the kids together is the worst thing you could do for them This system is a giant failure and nobody cares about the 1

12192017 112 PM

The plan should include monitoring the number of students that are educated using

the alternate content standards not at the assessment point

12182017 1241 PM

I think the timeline should be extended indefinitely Students should not have to

take assessments that will frustrate them unnecessarily No valuable information will be gained from students who are overwhelmed This is why we have IEPs

12172017 1212 AM

Nothing a 1 Cap rule is forcing IEPTeams to make decisions they otherwise would not have made for a student regarding participation in the regular or

alternate assessments Why should there be issued plans of improvement and timelines forced on school districts or programs who are following IDEAMARSE

rules and regulations in an attempt to do whats right for their student MDE should not be mandating additional participation rate requirements and creating more red-

tape and work for districts and staff who are already overly regulated This is part of the reason good people leave education and we are faced with educator shortages

12142017 813 AM

Maybe we should take a closer look at the existing data in comparison to other

classroom or standards based assessment to determine how these data points correlate and how we are using this data

12132017 316 PM

If support is in place for each child they will succeed We cant say what that will be

12132017 258 PM

An honest look at the value of standardized assessment

12132017 225 PM

There should be more time spent on looking at the offerring of programs and support for special education students In addition public schools need more to

support in the general education setting to be proactive to students at a younger age The funding for special education needs to be looked at across the state

12132017 130 PM

Only assess students participating in FI Mi-Access or only include participation rates for students administered FI MiAccess

12132017 1052 AM

According to MI School Data 125 of our total student population is CI This

information should be factored into the plan for improvement How does the rate of students with CI SXI or other eligibility categories compare to this 1 target

12132017 1014 AM

What should be included in the plan is the purpose of the data we are trying to gain from the assessments given There are students that will not perform well on the

assessment or students that will not be able to engage in the assessment due to lack of skills to do so If they are not allowed to access an alternate assessment

than the State will not be able to gain a true picture of where those students are

functioning The information gained from these assessments should be useful in helping students and teachers target areas of improvement through instruction

12122017 1256 PM

Data to the districts on participation rates at all three levels of our alternate

assessment so we can identify at a district and ISD level where the issues are Professional development on assessment selection guidelines It may be helpful to include performance levels on standardized assessments (ex Cognitive scores) that

would be indicative of a possible need to consider alternate assessments Comparison of overall participation rates as well as participation in alternate

assessments If not already available it would be helpful to consider a nationwide study of this data

12122017 1141 AM

Possibly an incremental change from the current 24 to 20 to 15

1292017 908 AM

While local districts need to carefully consider the decisions for students taking functional independence I believe the decision chart and intentional review of students taking alternate assessments by district will help to identify areas of

improvement

1282017 223 PM

Start with what we know the percentages of students with significant cognitive impairment Address those students who take FI specifically to discern if we are

testing to many

1282017 1240 PM

I am not sure how you can plan for students that are not cognitively able to test the regular test Many of the district schools in our county have diminishing numbers in

their student population The 1 is not realistic

1242017 1249 PM

24 seems reasonable why would we force a student to take a test that is beyond their cognitive function

1242017 1111 AM

Again the request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform

on a standardized assessment If however the student shows growth over time the IEP team should consider general assessments as well

1242017 836 AM

MDE can create an online PD but why do we need to improve if it is a team decision to take an alternate assessment Data drives this decision

1232017 847 PM

If when has your district provided training to staff and those involved in the IEP process on the guidelines for choosing the appropriate assessment for the student

training on alternate content standards training on MI-Access How many students do you serve that cross district lines county lines (School of Choice) These

districts should not be penalized for providing service to students who choose them and therefore increase special education numbers What is your percent for each

subcategory (FI SI P) Do any of these students have access to the general education curriculum content standards for the content area in which they are taking a MI-Access assessment

1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

Putting all children in rigorous programming from birth basically taking them from

the impoverished homes and parenting which robs them of the necessary tools to meet these rigorous demands Oh and eliminate birth defects while you are at it and neurological damage I guess maybe all of this by next year

1212017 1154 AM

There should be a waiver for students who are on alternate curriculum andor in

programs for students with significant disabilities

11212017 139 PM

Students who require functional life skills curricula should not be administered

MSTEP or MME Instead they should be provided an assessment (ie MiAccess) that respects their dignity and their ability to show growth in areas they have

received targeted instruction

11212017 1228 PM

To ensure there are consistent practices across the state clear definitions should be

reported to assist with determining the appropriateness of an alternate assessment

11202017 1058 AM

Special Education teachers know the students that they are working with We have already read through the IEP and have determined educational plans for each child

on our caseload If we received a transfer student with an IEP of concern we have already held an IEP and contacted former teachers regarding our concerns about goals andor MET scores and have decided as an IEP Team appropriate teaching

goals along with appropriate assessments and testing needs for these students

Several of my transfer students had MI Alternative Testing (MI Access on their IEPs) which I immediately questioned and amended to read MStep since they are

participating in the general education content standards and come to the Resource Room for intense small group instruction in reading or math The plan should be for

Special Education teachers to submit the names of students on their current caseload the name of the test that is on the students IEP and give rationale or justification for each test that has been selected These names along with the test

rationale should be sent to the Special Education Director and then submitted to the state within the next two weeks due to the shortened week next week because of

Thanksgiving break Timeline for improvement should be to make an amendment to the students IEP within that time if changes need to be made

11182017 723 AM

Educate schoolsteachercounselors let IEP teams know what is available

11172017 1119 AM

I am not sure how we improve the fact that we service students with moderate to severe cognitive impairments If I were a parent of one of these students this statement would be insulting The decision to utilize an alternative assessment is an

IEP team decision of which the parent is a part

11172017 754 AM

PLEASE look at how many kids we have in the state who have significant cognitive impairments That should give MDE an idea of the need Training in determining the

right assessments should be offered as well This could start in spring - in getting a plan Summer for the work (with educators from around the state) Roll out spring of 2019 with training in late spring and summer

11162017 345 PM

I think that if we continue to have open dialog with the IEP team then we are doing

what is best for the student The disability doesnt drive programming so as a team we need to make sure it doesnt drive testing either

11162017 310 PM

The flow chart--Should My Student Take the Alternate Assessment--s a good tool for teams to use in making decisions PD--possibly a short online video one year

timeline

11162017 249 PM

A decision tree on what assessment should be used for each student that can be used across the state

11162017 134 PM

There should be a waiver for districts specifically those districts who operate regional or center-based programs These programs often provided services and

assess students that are significantly impacted by their disability Operating these programs where other districts send their students will effectincrease the percentage of the operating districts rates

11162017 130 PM

The plan should include a realistic percentage of students taking the test

11162017 112 PM

Question 3

3 Other comments

Showing 25 responses

This is against the ADA segregating our kids

12192017 112 PM

My district was at a 11 alternate assessment participation rate last year Dont force our IEPTeams to have to pick the 1 student wholl have to take the regular

assessment if the IEPTeam has already determined that 1 student is appropriate to take the alternate assessment Special education CI and SXI Programs are also

going to be punished when it comes to alternate assessment participation rates at 100 versus the 1 Cap I dont believe a cookie-cutter 1 can realistically take into account every school district or programs population or spectrum of students

with disabilities These assessment decisions should be left to the determination of the students IEPTeam - who knows the students level of functioning and

assessment needs I would much rather see students who score meets or exceeds expectations on MI-ACCESS be required to then take the M-STEP the following year If the student scores not-proficient on the M-STEP then MI-ACCESS could

be reconsidered the following year again for that student

12142017 813 AM

I am left wondering the purpose for this type of assessment How does it aid instruction benefit the student or improve our educational system Are we simply attempting to meet some compliance standard or is this data being used in a

manner that improves outcomes for kids

12132017 316 PM

Please consider that every are has their own needs

12132017 258 PM

Other concern is the way teachers are viewed by the state and the universitys are currently losing students because teachers are not supported in the school system

12132017 130 PM

How does the participation break down for the various levels of the alternate assessment FI SI and P FI is probably where we are going to have the most

flexibility in considering whether students should be taking the general assessment I encourage the department to seek this data when moving forward with the Waiver

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
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                  38. AssuranceAdditionalTraining Off
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                  40. ResourceTA

Page 2 ndash The Honorable Sheila Alles

bull Will verify that each LEA that is required to submit such information to MDE is following all State guidelines in 34 CFR sect 2006(d) (with the exception of incorporating principles of universal design) and will address any subgroup disproportionality in the percentage of students taking an AA-AAAS

bull Will implement consistent with the plan submitted in MDErsquos waiver request system improvements and monitor future administrations of its AA-AAAS to avoid exceeding the 10 percent cap

I appreciate the work you are doing to improve your schools and provide a high-quality education for your students If you have any questions please contact Tahira Rashid of my staff at OSSMichganedgov

Sincerely

s Jason Botel Principal Deputy Assistant Secretary Delegated the Authority to Perform the Functions and Duties of the Assistant Secretary of Elementary and Secondary Education

APPENDIX A

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING RICK SNYDER GOVERNOR

BRIAN J WHISTON STATE SUPERINTENDENT

MEMORANDUM

DATE November 16 2017

TO Local and Intermediate School District Superintendents Public School Academy Directors

FROM Brian J Whiston State Superintendent Michigan Department of Education

SUBJECT Alternative assessment waiver request for the 1 cap

Michiganrsquos alternate assessment (MI-Access) is aligned to the Michigan alternate content standards in English Language Arts (ELA) mathematics science and social studies This alternate assessment is designed to allow students with the most significant cognitive disabilities to demonstrate their knowledge and skills

Under No Child Left Behind (NCLB) there was no limit to the number of students who could participate in this alternate assessment but rather there was a 1 cap on the number of proficient scores that could come from an alternate assessment as it related to the statersquos accountability system

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills However the law changed and rather than placing a cap on accountability proficiency rates for the alternate assessment the regulations for the number of students participating in the alternate assessment shall not exceed 1

This shift means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

It is important to note that decisions regarding who takes an alternate assessment continues to rest with the Individualized Education Program (IEP) team The team must follow the state guidelines for participation in the alternate assessment

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH ndash CO-PRESIDENT bull RICHARD ZEILE ndash CO-PRESIDENT MICHELLE FECTEAU ndash SECRETARY bull TOM MCMILLIN ndash TREASURER

NIKKI SNYDER ndash NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO B OX 30008 bull LANSING MICHIGAN 48909 wwwmichigangovmde bull 517-373-3324

Page 2 November 16 2017

The Michigan Department of Education (MDE) has been taking steps to ensure that educators in the state understand the assessment selection guidance to determine which assessment a student should take Enhanced training opportunities on the selection guidance will be offered via video training and at various workshops this winter

There are several provisions that accompany the state level cap on participation in the alternate assessment While ESSA does limit the total number of students in the state who are assessed using an alternate assessment based on alternate achievement standards the following provisions are also made

bull A state may not prohibit an LEA from assessing more than 10 percent of its assessed students using an alternate assessment However LEAs that exceed this participation rate must provide justification for exceeding this rate States must make this justification publicly available and provide oversight to LEAs that exceed this rate

Based on data collected from the spring 2017 testing window Michigan has calculated the current rate of students taking an alternate assessment in the state is 24 for English Language Arts 24 for mathematics and 23 for science To demonstrate our plan to bring Michigan into compliance with this regulation MDE will be applying for a waiver for the 2018 testing window as provided for by ESSA which will be submitted to the US Department of Education (US ED) MDE is seeking comments on the waiver application from all interested parties

As required Michiganrsquos waiver application will (inclusive of grades 3-8 and 11) bull Be submitted at least 90 days prior to the start of the testing window bull Provide state-level data from the 2017 testing cycle to show the number and percentage of students (including sub-groups) who took an alternate assessment of all students tested in each subject

bull Demonstrate that Michigan has tested at least 95 of all students and 95 of students with disabilities across all summative assessments and

bull Provide assurances that LEAs contributing to the state exceeding the 1 cap have adhered to the participation guidelines and address any disproportionality in any sub-group of students taking the alternate assessment

Further the waiver will include a plan and timeline by which the state will bull Improve the implementation of its guidelines on the alternate assessment bull Take additional steps to support and provide oversight to each LEA that contributes to the state exceeding the 1 cap and

bull Address any disproportionality in the percentage of students taking the alternate assessment

As we move forward to align with the requirements of ESSA as it relates to alternate assessments it is important to note how this supports MDErsquos Top 10 in 10 initiatives

bull The work is aligned across offices and with appropriate agencies The collection of data communication and technical support is a collaborative effort between the Office of Special Education (OSE) and the Office of

Page 3 November 16 2017

Educational Assessment and Accountability (OEAA) with local information and support coordinated at the ISD level

bull Beyond looking at data in isolation the work is aimed at focusing on child-centered needs ensuring that students are being assessed in ways that are most appropriate to their needs and aligned to the rigorous standards to which they are being instructed on a daily basis

For any interested party comments may be left in the following ways bull Survey httpswwwsurveymonkeycomr1percent_waiver_MI bull Email mde-oeaamichigangov (be sure to include ldquo1 alternate assessment waiverrdquo in the subject line)

bull Via mail Michigan Department of Education 608 W Allegan Street PO Box 30008 Lansing MI 48909 Attn OEAA 1 waiver ndash 2nd floor

The following resources are available on the MI-Access Web Site (wwwmichigangovmi-access) with direct links provided here

bull Michiganrsquos guidelines for participation in the alternate assessment (MI-Access) Alternate Assessment Guidelines

bull Guidelines for ISDrsquos to provide support to LEAs regarding the 1 cap 1 cap ISD Guidance

bull Michiganrsquos alternate content standards alternate content standards

For further information contact John Jaquith at jaquithjmichigangov or 517-335-1987

cc Michigan Education Alliance

Appendix B

Public Comment Responses (in exact language)

Question 1

1 Please comment on Michigans current rate of participation in the

alternate assessment (24 English Language Arts 24 mathematics

23 science)

Does anyone working in the field of education understand what this means for students You want to allow schools to not educate students This is what happens Schools use this as a loophole If you dont believe me PLEASE look at Wayne Resas Special education Plan for students with mutliple needs Segregated sent away and given up on before ever given a chance You are ruining entire life outcomes 12192017 112 PM

To limit the number of students within these subgroups that can take an alternate assessment is unfair We need to be giving our students the assessment that is appropriate for each of them individually based on IEPs 12182017 1241 PM

Students need to be assessed where there skills lieand aligned to IEP goals I dont think a percentage should determine who takes which test 12172017 1212 AM

I believe these rates of over 2 are adequate 1 participation rate is a cookie-cutter formula that defies IDEAMARSE rules and regulations giving the IEPTeam the responsibility of determining which assessment is appropriate for the student based on their individualized level of functioning and needs Participating in alternate assessments is a decision that should be made by the IEPTeam with parentguardian it should not be made because of a unrealistic 1 Cap rule 12142017 813 AM

Just by looking at the normal distribution curve one would expect 21 of the

population to fall 2 standard deviations below the mean I think we might be able to improve the participation rate and how we determine who takes which assessment

through additional training and better analysis of our existing test data IEP teams are currently making these decisions which seems consistent with the law The question i would ask is what are we hoping to gain from this type of assessment

for students with cognitive impairments What is the intent What is gained through this assessment How does it lead to better learning outcomes How does

it improve the outcome for students How does it help instruction What do these assessments (functional independence participation) add to our instructional knowledge for the student What is the intended purpose of these tests How do

they benefit the student or lead to better instruction

12132017 316 PM

Should we look at the need of each child

12132017 258 PM

I wonder if the limit should be adjusted

12132017 225 PM

I feel they are high but in relation to other states Michigan is underfunding their Special Education Programing period 12132017 130 PM

The reason our current rate over 1 in the state of michigan is due to the fact that we assess ALL students Many states only assess mild CI or those that would take Functional Independence I do not believe we would have an issue if we only included participation rates for students participating in FI-MI-Access 12132017 1052 AM

How does Michigans overall participation rate compare to other states Are other states exempting students from assessments that we are including in our alternate assessment 12132017 1014 AM

Although the percentage is much higher than maybe anticipated the assignment of the State assessment is made through an IEP decision making process I would have to believe that the IEP teams are making accurate recommendations based on students cognitive abilities 12122017 1256 PM

When evaluating participate rate in alternate assessments there are several factors that need to be considered The first is overall participation rate in statewide

assessments When reviewing MI School Data Students not Tested in Michigan it is clear that Michigans overall participation rate is incredibly high As the participation

rate increases it is logical that the percentage of students taking alternate assessments will also increase Michigans rate of participation in alternate assessments may not be that high when taking the overall participation rate into

consideration If Michigan were to decrease their overall participation rate and begin exempting groups of students from assessment it would be quite easy to

lower the participation in alternate assessments I dont believe that should be our goal but it is important that we are using data that is truly comparable if we are comparing ourselves to other states The second is the percentage of students with

Cognitive Impairments (or those that function as if they have severe cognitive impairments) in the state In 2016-2017 Michigan had 19249 students eligible as

having a Cognitive Impairment In that same year Michigan had 1532335 total students That means that 125 of our students had Cognitive Impairments While not all CI students are appropriate for alternate assessments many would be In

addition there are also students in other eligibility categories such as SXI (an

additional 2 of students) that would most likely be appropriate for an alternate assessment The eligibility of ASD would also have some students that function as if they have a severe cognitive impairment that may be appropriate for alternate assessments The third which I couldnt find easy access to the data is percentage of students participating in the various levels of our alternate assessments I do believe there are students taking the Functional Independence assessment that would be appropriate for the general assessment However I do not believe in my experience that we have students taking Supported Independence or Participation that would be appropriate for the General Assessment I think it would be valuable to look at the percentage participating in each level of our alternate assessment so we know if we need to be focusing our efforts on the FI level or if there would be a need to even look at SI or P in order to get us to the 1 level 12122017 1141 AM

This seems to be consistent with many LEAs around the state and does not seem excessive 1292017 908 AM

According to a review of our county data regarding participation in the alternate assessment we are almost to 1 just counting the number of students taking Supported Independence and Participation I would be curious about the other counties throughout state as it relates to the alternate assessment participation rates in the areas of Supported Independence and Participation Assessments Students attending programs for moderately cognitively impaired and programs for severe cognitive impairment account for 68 of the population of students with IEPs and 229 of these students are enrolled in grades 3-8 and 11 1282017 223 PM

In looking at data the SXI population alone last year was at 17 so to think that Michigan will ever be under 1 is a challenge Because Autism is such a broad spectrum it is a challenge to be at 1 if you also add in severely cognitively impaired students My point being does the state know the actual percentage of significantly impaired students in the state 1282017 1240 PM

Michigan has a higher rate of assessment participation because we assess more students than other states do 1262017 1044 AM

I feel that limiting the cap to 1 is an can be detrimental to those students who are not cognitively at the level needed to test other than with an alternate assessment A waiver is needed to go beyond 1 1242017 1249 PM

According to the American Community Survey the percentages of people with

disabilities have remained relatively unchanged since 2008 Total percentage of

people with a cognitive impairment is 48 which includes over age 65 24 taking an alternative assessment seems aligned with the data and reasonable 1242017 1111 AM

The request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform on a standardized assessment 1242017 836 AM

It is an IEP team decision for each student to take an alternative assessment It seems that if we have to stay below the 1 it is forcing IEP teams to not look at the individual students need based on data 1232017 847 PM

If these students are in fact receiving Alternate Content Standards and are accurately placed in a program that challenges their abilities then the percentages given are justified 1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt 1212017 1156 AM

Even this seems very low to me There are hundreds of children taking tests that are way beyond their ability to comprehend them I really wish I understood what we are trying to prove 1212017 1154 AM

School districts who operate regional programs for students with cognitive impairments are at a disadvantage with this cap We espouse the virtue of the IEP team making the assessment decision yet we punish districts for going over the arbitrary standard Another disadvantage is we are no longer sending scores back to home districts 11212017 139 PM

As MMC is a college preparatory curriculum and the assortment of MSTEP assessments are intended to measure this curriculum requiring all but 1 of students to demonstrate understanding of that content is inappropriate Additionally consideration of a normally distributed bell curve would suggest 2 of the population falls in the CI range Beyond that parts or all of MSTEP andor MME could be inappropriate for students with severe learning disabilities In light of these normal distributions and the nature of the MMC and its assessments Michigan assessing just over 2 with alternative measure suggests reasonable if not slightly rigid practice Put another way a valid argument MI is testing too many students with MSTEP and MME could be made 11212017 1228 PM

The decision to assess a student with an alternate assessment like MI-Access is ultimately an IEP team decision My concern with the reported percentages relates to each districts interpretation of the appropriateness for a child to be assessed using alternative tools Do we have consistency from district to district with the definition of severe cognitive impairment 11202017 1058 AM

We decide at a METIEP meeting which students have significant cognitive impairments (data cognitive scores) and which test they are able to take Our building has an high number of students who qualify to take the MIAccess because they have a cognitive impairment and they are functioning as if the they have a cognitive impairment Currently our districts participation in the MIAccess is 23 due to these students taking the test The students are in a Basic Classroom which has been labeled a High Needs Resource Room These students are not spread out into other buildings The non-participating students in the other buildings are never severe enough that there is no question that they are not counted for testing the students in the Communication Room are so low they are unable to speak The concern in our district is that these students in our building raise our percentage of participation in the MI Access testing although it is appropriate for the student The shift of concern now seems to be What is the percentage of student participation rather than What is appropriate for the whole child 11182017 723 AM

Very low numbers for high IEP numbers 11172017 1119 AM

This percentage seems to be accurate and although it exceeds the 1 cap we provide educational services to significantly impaired students across the state for whom the Mi Access assessment is the best choice for assessing these students academic knowledge 11172017 754 AM

I work in a district with a high number of students with disabilities A number of those students have or function as having a cognitive deficit Currently my district has 349 of students with IEPs taking alternate assessments As I understand the 1 cap administering Mi-Access to only those students with significant ASD impairments my district will be penalized (in some manner) if we administer the test to students with cognitive impairments 11162017 418 PM

Please look carefully at the makeup of each district and what programs are housed there I run an ISD center-based program for the county ALL of my students have significant disabilities ALL are on Mi-Access Other districts run things differently Michigan might really have that many students who require alternative assessments A deep dive is needed to investigate how alternative assessments are determined in each district 11162017 345 PM

As a special education director we have students who are in a Moderate Cognitively Impaired program and have been exposed to a modified curriculum throughout their educational career It is not in the best interest of them to expect them to participate in the MStep even if they arent considered Significant to many The MStep causes a tremendous amount of stress to students who arent in special education Our job as educators is to look at what is best for the students on an individual level not to make sure we meet a certain percentage Requiring the state to be at 1 or under isnt in the best interest of our students 11162017 310 PM

Based on MiSchool Data 2016-2017 the state of Michigan had 3500 students with a Severe Multiple Impairments (17) eligibility While this data is not reflective of the students in grades 3-8 amp 11 it does provide us with a piece of information Additionally this data does not include other students who function as if they have a significant cognitive impairment IDEA to my knowledge does not limit the number of students who may partake in an alternate assessment it is an IEP team decision I am not making excuses just stating facts Please understand we can always improve 11162017 249 PM

I would like to know the percentage of students that have an IEP that categorizes them as cognitively impaired etc 11162017 134 PM

The current Michigan rate reflects IEP team decisions regarding the appropriateness of participation for any one student IEP teams (parents included) know these students better than any legislator The overall understanding needs to exist that 24 or even 3 of all students does show that the vast majority of students who receive special education services are taking the general education assessment IEP teams have been selective with their decisions with regard to who will participate in the alternative assessment Legislators and the guidelines that are written need to have some level of flexibility for the IEP process 11162017 130 PM

22 of the population has an IQ below 70 Students with cognitive impairments are

working at the best of their ability and that includes an alternative curriculum with

an alternative assessment

Question 2

2 Please comment on what should be included in the plan and timeline for

improvement

Try inclusion real inclusion Kids with complex needs CAN LEARN They need to be provided the resources Ieprsquos need to be looked at for the students who already are not being educated look at the student when you see the amount of time a non verbal multi impaired child is getting for speech services who is attending a

segregated school Every kid in there needs these servuces Lumping the kids together is the worst thing you could do for them This system is a giant failure and nobody cares about the 1

12192017 112 PM

The plan should include monitoring the number of students that are educated using

the alternate content standards not at the assessment point

12182017 1241 PM

I think the timeline should be extended indefinitely Students should not have to

take assessments that will frustrate them unnecessarily No valuable information will be gained from students who are overwhelmed This is why we have IEPs

12172017 1212 AM

Nothing a 1 Cap rule is forcing IEPTeams to make decisions they otherwise would not have made for a student regarding participation in the regular or

alternate assessments Why should there be issued plans of improvement and timelines forced on school districts or programs who are following IDEAMARSE

rules and regulations in an attempt to do whats right for their student MDE should not be mandating additional participation rate requirements and creating more red-

tape and work for districts and staff who are already overly regulated This is part of the reason good people leave education and we are faced with educator shortages

12142017 813 AM

Maybe we should take a closer look at the existing data in comparison to other

classroom or standards based assessment to determine how these data points correlate and how we are using this data

12132017 316 PM

If support is in place for each child they will succeed We cant say what that will be

12132017 258 PM

An honest look at the value of standardized assessment

12132017 225 PM

There should be more time spent on looking at the offerring of programs and support for special education students In addition public schools need more to

support in the general education setting to be proactive to students at a younger age The funding for special education needs to be looked at across the state

12132017 130 PM

Only assess students participating in FI Mi-Access or only include participation rates for students administered FI MiAccess

12132017 1052 AM

According to MI School Data 125 of our total student population is CI This

information should be factored into the plan for improvement How does the rate of students with CI SXI or other eligibility categories compare to this 1 target

12132017 1014 AM

What should be included in the plan is the purpose of the data we are trying to gain from the assessments given There are students that will not perform well on the

assessment or students that will not be able to engage in the assessment due to lack of skills to do so If they are not allowed to access an alternate assessment

than the State will not be able to gain a true picture of where those students are

functioning The information gained from these assessments should be useful in helping students and teachers target areas of improvement through instruction

12122017 1256 PM

Data to the districts on participation rates at all three levels of our alternate

assessment so we can identify at a district and ISD level where the issues are Professional development on assessment selection guidelines It may be helpful to include performance levels on standardized assessments (ex Cognitive scores) that

would be indicative of a possible need to consider alternate assessments Comparison of overall participation rates as well as participation in alternate

assessments If not already available it would be helpful to consider a nationwide study of this data

12122017 1141 AM

Possibly an incremental change from the current 24 to 20 to 15

1292017 908 AM

While local districts need to carefully consider the decisions for students taking functional independence I believe the decision chart and intentional review of students taking alternate assessments by district will help to identify areas of

improvement

1282017 223 PM

Start with what we know the percentages of students with significant cognitive impairment Address those students who take FI specifically to discern if we are

testing to many

1282017 1240 PM

I am not sure how you can plan for students that are not cognitively able to test the regular test Many of the district schools in our county have diminishing numbers in

their student population The 1 is not realistic

1242017 1249 PM

24 seems reasonable why would we force a student to take a test that is beyond their cognitive function

1242017 1111 AM

Again the request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform

on a standardized assessment If however the student shows growth over time the IEP team should consider general assessments as well

1242017 836 AM

MDE can create an online PD but why do we need to improve if it is a team decision to take an alternate assessment Data drives this decision

1232017 847 PM

If when has your district provided training to staff and those involved in the IEP process on the guidelines for choosing the appropriate assessment for the student

training on alternate content standards training on MI-Access How many students do you serve that cross district lines county lines (School of Choice) These

districts should not be penalized for providing service to students who choose them and therefore increase special education numbers What is your percent for each

subcategory (FI SI P) Do any of these students have access to the general education curriculum content standards for the content area in which they are taking a MI-Access assessment

1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

Putting all children in rigorous programming from birth basically taking them from

the impoverished homes and parenting which robs them of the necessary tools to meet these rigorous demands Oh and eliminate birth defects while you are at it and neurological damage I guess maybe all of this by next year

1212017 1154 AM

There should be a waiver for students who are on alternate curriculum andor in

programs for students with significant disabilities

11212017 139 PM

Students who require functional life skills curricula should not be administered

MSTEP or MME Instead they should be provided an assessment (ie MiAccess) that respects their dignity and their ability to show growth in areas they have

received targeted instruction

11212017 1228 PM

To ensure there are consistent practices across the state clear definitions should be

reported to assist with determining the appropriateness of an alternate assessment

11202017 1058 AM

Special Education teachers know the students that they are working with We have already read through the IEP and have determined educational plans for each child

on our caseload If we received a transfer student with an IEP of concern we have already held an IEP and contacted former teachers regarding our concerns about goals andor MET scores and have decided as an IEP Team appropriate teaching

goals along with appropriate assessments and testing needs for these students

Several of my transfer students had MI Alternative Testing (MI Access on their IEPs) which I immediately questioned and amended to read MStep since they are

participating in the general education content standards and come to the Resource Room for intense small group instruction in reading or math The plan should be for

Special Education teachers to submit the names of students on their current caseload the name of the test that is on the students IEP and give rationale or justification for each test that has been selected These names along with the test

rationale should be sent to the Special Education Director and then submitted to the state within the next two weeks due to the shortened week next week because of

Thanksgiving break Timeline for improvement should be to make an amendment to the students IEP within that time if changes need to be made

11182017 723 AM

Educate schoolsteachercounselors let IEP teams know what is available

11172017 1119 AM

I am not sure how we improve the fact that we service students with moderate to severe cognitive impairments If I were a parent of one of these students this statement would be insulting The decision to utilize an alternative assessment is an

IEP team decision of which the parent is a part

11172017 754 AM

PLEASE look at how many kids we have in the state who have significant cognitive impairments That should give MDE an idea of the need Training in determining the

right assessments should be offered as well This could start in spring - in getting a plan Summer for the work (with educators from around the state) Roll out spring of 2019 with training in late spring and summer

11162017 345 PM

I think that if we continue to have open dialog with the IEP team then we are doing

what is best for the student The disability doesnt drive programming so as a team we need to make sure it doesnt drive testing either

11162017 310 PM

The flow chart--Should My Student Take the Alternate Assessment--s a good tool for teams to use in making decisions PD--possibly a short online video one year

timeline

11162017 249 PM

A decision tree on what assessment should be used for each student that can be used across the state

11162017 134 PM

There should be a waiver for districts specifically those districts who operate regional or center-based programs These programs often provided services and

assess students that are significantly impacted by their disability Operating these programs where other districts send their students will effectincrease the percentage of the operating districts rates

11162017 130 PM

The plan should include a realistic percentage of students taking the test

11162017 112 PM

Question 3

3 Other comments

Showing 25 responses

This is against the ADA segregating our kids

12192017 112 PM

My district was at a 11 alternate assessment participation rate last year Dont force our IEPTeams to have to pick the 1 student wholl have to take the regular

assessment if the IEPTeam has already determined that 1 student is appropriate to take the alternate assessment Special education CI and SXI Programs are also

going to be punished when it comes to alternate assessment participation rates at 100 versus the 1 Cap I dont believe a cookie-cutter 1 can realistically take into account every school district or programs population or spectrum of students

with disabilities These assessment decisions should be left to the determination of the students IEPTeam - who knows the students level of functioning and

assessment needs I would much rather see students who score meets or exceeds expectations on MI-ACCESS be required to then take the M-STEP the following year If the student scores not-proficient on the M-STEP then MI-ACCESS could

be reconsidered the following year again for that student

12142017 813 AM

I am left wondering the purpose for this type of assessment How does it aid instruction benefit the student or improve our educational system Are we simply attempting to meet some compliance standard or is this data being used in a

manner that improves outcomes for kids

12132017 316 PM

Please consider that every are has their own needs

12132017 258 PM

Other concern is the way teachers are viewed by the state and the universitys are currently losing students because teachers are not supported in the school system

12132017 130 PM

How does the participation break down for the various levels of the alternate assessment FI SI and P FI is probably where we are going to have the most

flexibility in considering whether students should be taking the general assessment I encourage the department to seek this data when moving forward with the Waiver

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 ESP 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 ETI ltFEFF004b00610073007500740061006700650020006e0065006900640020007300e400740074006500690064002c0020006500740020006c0075007500610020005000440046002d0064006f006b0075006d0065006e00740065002c0020006d0069007300200073006f00620069007600610064002000e4007200690064006f006b0075006d0065006e00740069006400650020007500730061006c006400750073007600e400e4007200730065006b0073002000760061006100740061006d006900730065006b00730020006a00610020007000720069006e00740069006d006900730065006b0073002e00200020004c006f006f0064007500640020005000440046002d0064006f006b0075006d0065006e0074006500200073006100610062002000610076006100640061002000760061006900640020004100630072006f0062006100740020006a0061002000410064006f00620065002000520065006100640065007200200036002e00300020006a00610020007500750065006d006100740065002000760065007200730069006f006f006e00690064006500670061002egt13 FRA 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 GRE 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 HEB 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 HRV 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 HUN ltFEFF0045007a0065006b006b0065006c0020006100200062006500e1006c006c00ed007400e10073006f006b006b0061006c002000fc007a006c00650074006900200064006f006b0075006d0065006e00740075006d006f006b0020006d00650067006200ed007a00680061007400f30020006d00650067006a0065006c0065006e00ed007400e9007300e900720065002000e900730020006e0079006f006d00740061007400e1007300e10072006100200061006c006b0061006c006d00610073002000410064006f006200650020005000440046002d0064006f006b0075006d0065006e00740075006d006f006b006100740020006b00e90073007a00ed0074006800650074002e002000200041007a002000ed006700790020006c00e90074007200650068006f007a006f007400740020005000440046002d0064006f006b0075006d0065006e00740075006d006f006b00200061007a0020004100630072006f006200610074002000e9007300200061007a002000410064006f00620065002000520065006100640065007200200036002c0030002d0073002000e900730020006b00e9007301510062006200690020007600650072007a006900f3006900760061006c0020006e00790069007400680061007400f3006b0020006d00650067002egt13 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN ltFEFF30d330b830cd30b9658766f8306e8868793a304a3088307353705237306b90693057305f002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200036002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a3067306f30d530a930f330c8306e57cb30818fbc307f3092884c3044307e30593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020be44c988b2c8c2a40020bb38c11cb97c0020c548c815c801c73cb85c0020bcf4ace00020c778c1c4d558b2940020b3700020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200036002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL 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 PTB ltFEFF005500740069006c0069007a006500200065007300730061007300200063006f006e00660069006700750072006100e700f50065007300200064006500200066006f0072006d00610020006100200063007200690061007200200064006f00630075006d0065006e0074006f0073002000410064006f00620065002000500044004600200061006400650071007500610064006f00730020007000610072006100200061002000760069007300750061006c0069007a006100e700e3006f002000650020006100200069006d0070007200650073007300e3006f00200063006f006e0066006900e1007600650069007300200064006500200064006f00630075006d0065006e0074006f007300200063006f006d0065007200630069006100690073002e0020004f007300200064006f00630075006d0065006e0074006f00730020005000440046002000630072006900610064006f007300200070006f00640065006d0020007300650072002000610062006500720074006f007300200063006f006d0020006f0020004100630072006f006200610074002000650020006f002000410064006f00620065002000520065006100640065007200200036002e0030002000650020007600650072007300f50065007300200070006f00730074006500720069006f007200650073002egt13 RUM ltFEFF005500740069006C0069007A00610163006900200061006300650073007400650020007300650074010300720069002000700065006E007400720075002000610020006300720065006100200064006F00630075006D0065006E00740065002000410064006F006200650020005000440046002000610064006500630076006100740065002000700065006E007400720075002000760069007A00750061006C0069007A006100720065002000640065002000EE006E00630072006500640065007200650020015F0069002000700065006E00740072007500200069006D007000720069006D006100720065006100200064006F00630075006D0065006E00740065006C006F007200200064006500200061006600610063006500720069002E00200044006F00630075006D0065006E00740065006C00650020005000440046002000630072006500610074006500200070006F00740020006600690020006400650073006300680069007300650020006300750020004100630072006F0062006100740020015F0069002000410064006F00620065002000520065006100640065007200200036002E003000200073006100750020007600650072007300690075006E006900200075006C0074006500720069006F006100720065002Egt13 RUS 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 SKY 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 UKR 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 ENU (Use these settings to create Adobe PDF documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
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                  21. NoTrainAdmin Off
                  22. NoTrainSpecialEdStaff Off
                  23. NoTrainParents Off
                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
                  26. OtherSpecialEdStaff Off
                  27. OtherParents Off
                  28. OtherRelServStaff Off
                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

APPENDIX A

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING RICK SNYDER GOVERNOR

BRIAN J WHISTON STATE SUPERINTENDENT

MEMORANDUM

DATE November 16 2017

TO Local and Intermediate School District Superintendents Public School Academy Directors

FROM Brian J Whiston State Superintendent Michigan Department of Education

SUBJECT Alternative assessment waiver request for the 1 cap

Michiganrsquos alternate assessment (MI-Access) is aligned to the Michigan alternate content standards in English Language Arts (ELA) mathematics science and social studies This alternate assessment is designed to allow students with the most significant cognitive disabilities to demonstrate their knowledge and skills

Under No Child Left Behind (NCLB) there was no limit to the number of students who could participate in this alternate assessment but rather there was a 1 cap on the number of proficient scores that could come from an alternate assessment as it related to the statersquos accountability system

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills However the law changed and rather than placing a cap on accountability proficiency rates for the alternate assessment the regulations for the number of students participating in the alternate assessment shall not exceed 1

This shift means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

It is important to note that decisions regarding who takes an alternate assessment continues to rest with the Individualized Education Program (IEP) team The team must follow the state guidelines for participation in the alternate assessment

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH ndash CO-PRESIDENT bull RICHARD ZEILE ndash CO-PRESIDENT MICHELLE FECTEAU ndash SECRETARY bull TOM MCMILLIN ndash TREASURER

NIKKI SNYDER ndash NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO B OX 30008 bull LANSING MICHIGAN 48909 wwwmichigangovmde bull 517-373-3324

Page 2 November 16 2017

The Michigan Department of Education (MDE) has been taking steps to ensure that educators in the state understand the assessment selection guidance to determine which assessment a student should take Enhanced training opportunities on the selection guidance will be offered via video training and at various workshops this winter

There are several provisions that accompany the state level cap on participation in the alternate assessment While ESSA does limit the total number of students in the state who are assessed using an alternate assessment based on alternate achievement standards the following provisions are also made

bull A state may not prohibit an LEA from assessing more than 10 percent of its assessed students using an alternate assessment However LEAs that exceed this participation rate must provide justification for exceeding this rate States must make this justification publicly available and provide oversight to LEAs that exceed this rate

Based on data collected from the spring 2017 testing window Michigan has calculated the current rate of students taking an alternate assessment in the state is 24 for English Language Arts 24 for mathematics and 23 for science To demonstrate our plan to bring Michigan into compliance with this regulation MDE will be applying for a waiver for the 2018 testing window as provided for by ESSA which will be submitted to the US Department of Education (US ED) MDE is seeking comments on the waiver application from all interested parties

As required Michiganrsquos waiver application will (inclusive of grades 3-8 and 11) bull Be submitted at least 90 days prior to the start of the testing window bull Provide state-level data from the 2017 testing cycle to show the number and percentage of students (including sub-groups) who took an alternate assessment of all students tested in each subject

bull Demonstrate that Michigan has tested at least 95 of all students and 95 of students with disabilities across all summative assessments and

bull Provide assurances that LEAs contributing to the state exceeding the 1 cap have adhered to the participation guidelines and address any disproportionality in any sub-group of students taking the alternate assessment

Further the waiver will include a plan and timeline by which the state will bull Improve the implementation of its guidelines on the alternate assessment bull Take additional steps to support and provide oversight to each LEA that contributes to the state exceeding the 1 cap and

bull Address any disproportionality in the percentage of students taking the alternate assessment

As we move forward to align with the requirements of ESSA as it relates to alternate assessments it is important to note how this supports MDErsquos Top 10 in 10 initiatives

bull The work is aligned across offices and with appropriate agencies The collection of data communication and technical support is a collaborative effort between the Office of Special Education (OSE) and the Office of

Page 3 November 16 2017

Educational Assessment and Accountability (OEAA) with local information and support coordinated at the ISD level

bull Beyond looking at data in isolation the work is aimed at focusing on child-centered needs ensuring that students are being assessed in ways that are most appropriate to their needs and aligned to the rigorous standards to which they are being instructed on a daily basis

For any interested party comments may be left in the following ways bull Survey httpswwwsurveymonkeycomr1percent_waiver_MI bull Email mde-oeaamichigangov (be sure to include ldquo1 alternate assessment waiverrdquo in the subject line)

bull Via mail Michigan Department of Education 608 W Allegan Street PO Box 30008 Lansing MI 48909 Attn OEAA 1 waiver ndash 2nd floor

The following resources are available on the MI-Access Web Site (wwwmichigangovmi-access) with direct links provided here

bull Michiganrsquos guidelines for participation in the alternate assessment (MI-Access) Alternate Assessment Guidelines

bull Guidelines for ISDrsquos to provide support to LEAs regarding the 1 cap 1 cap ISD Guidance

bull Michiganrsquos alternate content standards alternate content standards

For further information contact John Jaquith at jaquithjmichigangov or 517-335-1987

cc Michigan Education Alliance

Appendix B

Public Comment Responses (in exact language)

Question 1

1 Please comment on Michigans current rate of participation in the

alternate assessment (24 English Language Arts 24 mathematics

23 science)

Does anyone working in the field of education understand what this means for students You want to allow schools to not educate students This is what happens Schools use this as a loophole If you dont believe me PLEASE look at Wayne Resas Special education Plan for students with mutliple needs Segregated sent away and given up on before ever given a chance You are ruining entire life outcomes 12192017 112 PM

To limit the number of students within these subgroups that can take an alternate assessment is unfair We need to be giving our students the assessment that is appropriate for each of them individually based on IEPs 12182017 1241 PM

Students need to be assessed where there skills lieand aligned to IEP goals I dont think a percentage should determine who takes which test 12172017 1212 AM

I believe these rates of over 2 are adequate 1 participation rate is a cookie-cutter formula that defies IDEAMARSE rules and regulations giving the IEPTeam the responsibility of determining which assessment is appropriate for the student based on their individualized level of functioning and needs Participating in alternate assessments is a decision that should be made by the IEPTeam with parentguardian it should not be made because of a unrealistic 1 Cap rule 12142017 813 AM

Just by looking at the normal distribution curve one would expect 21 of the

population to fall 2 standard deviations below the mean I think we might be able to improve the participation rate and how we determine who takes which assessment

through additional training and better analysis of our existing test data IEP teams are currently making these decisions which seems consistent with the law The question i would ask is what are we hoping to gain from this type of assessment

for students with cognitive impairments What is the intent What is gained through this assessment How does it lead to better learning outcomes How does

it improve the outcome for students How does it help instruction What do these assessments (functional independence participation) add to our instructional knowledge for the student What is the intended purpose of these tests How do

they benefit the student or lead to better instruction

12132017 316 PM

Should we look at the need of each child

12132017 258 PM

I wonder if the limit should be adjusted

12132017 225 PM

I feel they are high but in relation to other states Michigan is underfunding their Special Education Programing period 12132017 130 PM

The reason our current rate over 1 in the state of michigan is due to the fact that we assess ALL students Many states only assess mild CI or those that would take Functional Independence I do not believe we would have an issue if we only included participation rates for students participating in FI-MI-Access 12132017 1052 AM

How does Michigans overall participation rate compare to other states Are other states exempting students from assessments that we are including in our alternate assessment 12132017 1014 AM

Although the percentage is much higher than maybe anticipated the assignment of the State assessment is made through an IEP decision making process I would have to believe that the IEP teams are making accurate recommendations based on students cognitive abilities 12122017 1256 PM

When evaluating participate rate in alternate assessments there are several factors that need to be considered The first is overall participation rate in statewide

assessments When reviewing MI School Data Students not Tested in Michigan it is clear that Michigans overall participation rate is incredibly high As the participation

rate increases it is logical that the percentage of students taking alternate assessments will also increase Michigans rate of participation in alternate assessments may not be that high when taking the overall participation rate into

consideration If Michigan were to decrease their overall participation rate and begin exempting groups of students from assessment it would be quite easy to

lower the participation in alternate assessments I dont believe that should be our goal but it is important that we are using data that is truly comparable if we are comparing ourselves to other states The second is the percentage of students with

Cognitive Impairments (or those that function as if they have severe cognitive impairments) in the state In 2016-2017 Michigan had 19249 students eligible as

having a Cognitive Impairment In that same year Michigan had 1532335 total students That means that 125 of our students had Cognitive Impairments While not all CI students are appropriate for alternate assessments many would be In

addition there are also students in other eligibility categories such as SXI (an

additional 2 of students) that would most likely be appropriate for an alternate assessment The eligibility of ASD would also have some students that function as if they have a severe cognitive impairment that may be appropriate for alternate assessments The third which I couldnt find easy access to the data is percentage of students participating in the various levels of our alternate assessments I do believe there are students taking the Functional Independence assessment that would be appropriate for the general assessment However I do not believe in my experience that we have students taking Supported Independence or Participation that would be appropriate for the General Assessment I think it would be valuable to look at the percentage participating in each level of our alternate assessment so we know if we need to be focusing our efforts on the FI level or if there would be a need to even look at SI or P in order to get us to the 1 level 12122017 1141 AM

This seems to be consistent with many LEAs around the state and does not seem excessive 1292017 908 AM

According to a review of our county data regarding participation in the alternate assessment we are almost to 1 just counting the number of students taking Supported Independence and Participation I would be curious about the other counties throughout state as it relates to the alternate assessment participation rates in the areas of Supported Independence and Participation Assessments Students attending programs for moderately cognitively impaired and programs for severe cognitive impairment account for 68 of the population of students with IEPs and 229 of these students are enrolled in grades 3-8 and 11 1282017 223 PM

In looking at data the SXI population alone last year was at 17 so to think that Michigan will ever be under 1 is a challenge Because Autism is such a broad spectrum it is a challenge to be at 1 if you also add in severely cognitively impaired students My point being does the state know the actual percentage of significantly impaired students in the state 1282017 1240 PM

Michigan has a higher rate of assessment participation because we assess more students than other states do 1262017 1044 AM

I feel that limiting the cap to 1 is an can be detrimental to those students who are not cognitively at the level needed to test other than with an alternate assessment A waiver is needed to go beyond 1 1242017 1249 PM

According to the American Community Survey the percentages of people with

disabilities have remained relatively unchanged since 2008 Total percentage of

people with a cognitive impairment is 48 which includes over age 65 24 taking an alternative assessment seems aligned with the data and reasonable 1242017 1111 AM

The request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform on a standardized assessment 1242017 836 AM

It is an IEP team decision for each student to take an alternative assessment It seems that if we have to stay below the 1 it is forcing IEP teams to not look at the individual students need based on data 1232017 847 PM

If these students are in fact receiving Alternate Content Standards and are accurately placed in a program that challenges their abilities then the percentages given are justified 1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt 1212017 1156 AM

Even this seems very low to me There are hundreds of children taking tests that are way beyond their ability to comprehend them I really wish I understood what we are trying to prove 1212017 1154 AM

School districts who operate regional programs for students with cognitive impairments are at a disadvantage with this cap We espouse the virtue of the IEP team making the assessment decision yet we punish districts for going over the arbitrary standard Another disadvantage is we are no longer sending scores back to home districts 11212017 139 PM

As MMC is a college preparatory curriculum and the assortment of MSTEP assessments are intended to measure this curriculum requiring all but 1 of students to demonstrate understanding of that content is inappropriate Additionally consideration of a normally distributed bell curve would suggest 2 of the population falls in the CI range Beyond that parts or all of MSTEP andor MME could be inappropriate for students with severe learning disabilities In light of these normal distributions and the nature of the MMC and its assessments Michigan assessing just over 2 with alternative measure suggests reasonable if not slightly rigid practice Put another way a valid argument MI is testing too many students with MSTEP and MME could be made 11212017 1228 PM

The decision to assess a student with an alternate assessment like MI-Access is ultimately an IEP team decision My concern with the reported percentages relates to each districts interpretation of the appropriateness for a child to be assessed using alternative tools Do we have consistency from district to district with the definition of severe cognitive impairment 11202017 1058 AM

We decide at a METIEP meeting which students have significant cognitive impairments (data cognitive scores) and which test they are able to take Our building has an high number of students who qualify to take the MIAccess because they have a cognitive impairment and they are functioning as if the they have a cognitive impairment Currently our districts participation in the MIAccess is 23 due to these students taking the test The students are in a Basic Classroom which has been labeled a High Needs Resource Room These students are not spread out into other buildings The non-participating students in the other buildings are never severe enough that there is no question that they are not counted for testing the students in the Communication Room are so low they are unable to speak The concern in our district is that these students in our building raise our percentage of participation in the MI Access testing although it is appropriate for the student The shift of concern now seems to be What is the percentage of student participation rather than What is appropriate for the whole child 11182017 723 AM

Very low numbers for high IEP numbers 11172017 1119 AM

This percentage seems to be accurate and although it exceeds the 1 cap we provide educational services to significantly impaired students across the state for whom the Mi Access assessment is the best choice for assessing these students academic knowledge 11172017 754 AM

I work in a district with a high number of students with disabilities A number of those students have or function as having a cognitive deficit Currently my district has 349 of students with IEPs taking alternate assessments As I understand the 1 cap administering Mi-Access to only those students with significant ASD impairments my district will be penalized (in some manner) if we administer the test to students with cognitive impairments 11162017 418 PM

Please look carefully at the makeup of each district and what programs are housed there I run an ISD center-based program for the county ALL of my students have significant disabilities ALL are on Mi-Access Other districts run things differently Michigan might really have that many students who require alternative assessments A deep dive is needed to investigate how alternative assessments are determined in each district 11162017 345 PM

As a special education director we have students who are in a Moderate Cognitively Impaired program and have been exposed to a modified curriculum throughout their educational career It is not in the best interest of them to expect them to participate in the MStep even if they arent considered Significant to many The MStep causes a tremendous amount of stress to students who arent in special education Our job as educators is to look at what is best for the students on an individual level not to make sure we meet a certain percentage Requiring the state to be at 1 or under isnt in the best interest of our students 11162017 310 PM

Based on MiSchool Data 2016-2017 the state of Michigan had 3500 students with a Severe Multiple Impairments (17) eligibility While this data is not reflective of the students in grades 3-8 amp 11 it does provide us with a piece of information Additionally this data does not include other students who function as if they have a significant cognitive impairment IDEA to my knowledge does not limit the number of students who may partake in an alternate assessment it is an IEP team decision I am not making excuses just stating facts Please understand we can always improve 11162017 249 PM

I would like to know the percentage of students that have an IEP that categorizes them as cognitively impaired etc 11162017 134 PM

The current Michigan rate reflects IEP team decisions regarding the appropriateness of participation for any one student IEP teams (parents included) know these students better than any legislator The overall understanding needs to exist that 24 or even 3 of all students does show that the vast majority of students who receive special education services are taking the general education assessment IEP teams have been selective with their decisions with regard to who will participate in the alternative assessment Legislators and the guidelines that are written need to have some level of flexibility for the IEP process 11162017 130 PM

22 of the population has an IQ below 70 Students with cognitive impairments are

working at the best of their ability and that includes an alternative curriculum with

an alternative assessment

Question 2

2 Please comment on what should be included in the plan and timeline for

improvement

Try inclusion real inclusion Kids with complex needs CAN LEARN They need to be provided the resources Ieprsquos need to be looked at for the students who already are not being educated look at the student when you see the amount of time a non verbal multi impaired child is getting for speech services who is attending a

segregated school Every kid in there needs these servuces Lumping the kids together is the worst thing you could do for them This system is a giant failure and nobody cares about the 1

12192017 112 PM

The plan should include monitoring the number of students that are educated using

the alternate content standards not at the assessment point

12182017 1241 PM

I think the timeline should be extended indefinitely Students should not have to

take assessments that will frustrate them unnecessarily No valuable information will be gained from students who are overwhelmed This is why we have IEPs

12172017 1212 AM

Nothing a 1 Cap rule is forcing IEPTeams to make decisions they otherwise would not have made for a student regarding participation in the regular or

alternate assessments Why should there be issued plans of improvement and timelines forced on school districts or programs who are following IDEAMARSE

rules and regulations in an attempt to do whats right for their student MDE should not be mandating additional participation rate requirements and creating more red-

tape and work for districts and staff who are already overly regulated This is part of the reason good people leave education and we are faced with educator shortages

12142017 813 AM

Maybe we should take a closer look at the existing data in comparison to other

classroom or standards based assessment to determine how these data points correlate and how we are using this data

12132017 316 PM

If support is in place for each child they will succeed We cant say what that will be

12132017 258 PM

An honest look at the value of standardized assessment

12132017 225 PM

There should be more time spent on looking at the offerring of programs and support for special education students In addition public schools need more to

support in the general education setting to be proactive to students at a younger age The funding for special education needs to be looked at across the state

12132017 130 PM

Only assess students participating in FI Mi-Access or only include participation rates for students administered FI MiAccess

12132017 1052 AM

According to MI School Data 125 of our total student population is CI This

information should be factored into the plan for improvement How does the rate of students with CI SXI or other eligibility categories compare to this 1 target

12132017 1014 AM

What should be included in the plan is the purpose of the data we are trying to gain from the assessments given There are students that will not perform well on the

assessment or students that will not be able to engage in the assessment due to lack of skills to do so If they are not allowed to access an alternate assessment

than the State will not be able to gain a true picture of where those students are

functioning The information gained from these assessments should be useful in helping students and teachers target areas of improvement through instruction

12122017 1256 PM

Data to the districts on participation rates at all three levels of our alternate

assessment so we can identify at a district and ISD level where the issues are Professional development on assessment selection guidelines It may be helpful to include performance levels on standardized assessments (ex Cognitive scores) that

would be indicative of a possible need to consider alternate assessments Comparison of overall participation rates as well as participation in alternate

assessments If not already available it would be helpful to consider a nationwide study of this data

12122017 1141 AM

Possibly an incremental change from the current 24 to 20 to 15

1292017 908 AM

While local districts need to carefully consider the decisions for students taking functional independence I believe the decision chart and intentional review of students taking alternate assessments by district will help to identify areas of

improvement

1282017 223 PM

Start with what we know the percentages of students with significant cognitive impairment Address those students who take FI specifically to discern if we are

testing to many

1282017 1240 PM

I am not sure how you can plan for students that are not cognitively able to test the regular test Many of the district schools in our county have diminishing numbers in

their student population The 1 is not realistic

1242017 1249 PM

24 seems reasonable why would we force a student to take a test that is beyond their cognitive function

1242017 1111 AM

Again the request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform

on a standardized assessment If however the student shows growth over time the IEP team should consider general assessments as well

1242017 836 AM

MDE can create an online PD but why do we need to improve if it is a team decision to take an alternate assessment Data drives this decision

1232017 847 PM

If when has your district provided training to staff and those involved in the IEP process on the guidelines for choosing the appropriate assessment for the student

training on alternate content standards training on MI-Access How many students do you serve that cross district lines county lines (School of Choice) These

districts should not be penalized for providing service to students who choose them and therefore increase special education numbers What is your percent for each

subcategory (FI SI P) Do any of these students have access to the general education curriculum content standards for the content area in which they are taking a MI-Access assessment

1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

Putting all children in rigorous programming from birth basically taking them from

the impoverished homes and parenting which robs them of the necessary tools to meet these rigorous demands Oh and eliminate birth defects while you are at it and neurological damage I guess maybe all of this by next year

1212017 1154 AM

There should be a waiver for students who are on alternate curriculum andor in

programs for students with significant disabilities

11212017 139 PM

Students who require functional life skills curricula should not be administered

MSTEP or MME Instead they should be provided an assessment (ie MiAccess) that respects their dignity and their ability to show growth in areas they have

received targeted instruction

11212017 1228 PM

To ensure there are consistent practices across the state clear definitions should be

reported to assist with determining the appropriateness of an alternate assessment

11202017 1058 AM

Special Education teachers know the students that they are working with We have already read through the IEP and have determined educational plans for each child

on our caseload If we received a transfer student with an IEP of concern we have already held an IEP and contacted former teachers regarding our concerns about goals andor MET scores and have decided as an IEP Team appropriate teaching

goals along with appropriate assessments and testing needs for these students

Several of my transfer students had MI Alternative Testing (MI Access on their IEPs) which I immediately questioned and amended to read MStep since they are

participating in the general education content standards and come to the Resource Room for intense small group instruction in reading or math The plan should be for

Special Education teachers to submit the names of students on their current caseload the name of the test that is on the students IEP and give rationale or justification for each test that has been selected These names along with the test

rationale should be sent to the Special Education Director and then submitted to the state within the next two weeks due to the shortened week next week because of

Thanksgiving break Timeline for improvement should be to make an amendment to the students IEP within that time if changes need to be made

11182017 723 AM

Educate schoolsteachercounselors let IEP teams know what is available

11172017 1119 AM

I am not sure how we improve the fact that we service students with moderate to severe cognitive impairments If I were a parent of one of these students this statement would be insulting The decision to utilize an alternative assessment is an

IEP team decision of which the parent is a part

11172017 754 AM

PLEASE look at how many kids we have in the state who have significant cognitive impairments That should give MDE an idea of the need Training in determining the

right assessments should be offered as well This could start in spring - in getting a plan Summer for the work (with educators from around the state) Roll out spring of 2019 with training in late spring and summer

11162017 345 PM

I think that if we continue to have open dialog with the IEP team then we are doing

what is best for the student The disability doesnt drive programming so as a team we need to make sure it doesnt drive testing either

11162017 310 PM

The flow chart--Should My Student Take the Alternate Assessment--s a good tool for teams to use in making decisions PD--possibly a short online video one year

timeline

11162017 249 PM

A decision tree on what assessment should be used for each student that can be used across the state

11162017 134 PM

There should be a waiver for districts specifically those districts who operate regional or center-based programs These programs often provided services and

assess students that are significantly impacted by their disability Operating these programs where other districts send their students will effectincrease the percentage of the operating districts rates

11162017 130 PM

The plan should include a realistic percentage of students taking the test

11162017 112 PM

Question 3

3 Other comments

Showing 25 responses

This is against the ADA segregating our kids

12192017 112 PM

My district was at a 11 alternate assessment participation rate last year Dont force our IEPTeams to have to pick the 1 student wholl have to take the regular

assessment if the IEPTeam has already determined that 1 student is appropriate to take the alternate assessment Special education CI and SXI Programs are also

going to be punished when it comes to alternate assessment participation rates at 100 versus the 1 Cap I dont believe a cookie-cutter 1 can realistically take into account every school district or programs population or spectrum of students

with disabilities These assessment decisions should be left to the determination of the students IEPTeam - who knows the students level of functioning and

assessment needs I would much rather see students who score meets or exceeds expectations on MI-ACCESS be required to then take the M-STEP the following year If the student scores not-proficient on the M-STEP then MI-ACCESS could

be reconsidered the following year again for that student

12142017 813 AM

I am left wondering the purpose for this type of assessment How does it aid instruction benefit the student or improve our educational system Are we simply attempting to meet some compliance standard or is this data being used in a

manner that improves outcomes for kids

12132017 316 PM

Please consider that every are has their own needs

12132017 258 PM

Other concern is the way teachers are viewed by the state and the universitys are currently losing students because teachers are not supported in the school system

12132017 130 PM

How does the participation break down for the various levels of the alternate assessment FI SI and P FI is probably where we are going to have the most

flexibility in considering whether students should be taking the general assessment I encourage the department to seek this data when moving forward with the Waiver

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR 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PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL 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 UKR 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documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
                  20. GuideDocsRelServStaff Off
                  21. NoTrainAdmin Off
                  22. NoTrainSpecialEdStaff Off
                  23. NoTrainParents Off
                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
                  26. OtherSpecialEdStaff Off
                  27. OtherParents Off
                  28. OtherRelServStaff Off
                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

Page 2 November 16 2017

The Michigan Department of Education (MDE) has been taking steps to ensure that educators in the state understand the assessment selection guidance to determine which assessment a student should take Enhanced training opportunities on the selection guidance will be offered via video training and at various workshops this winter

There are several provisions that accompany the state level cap on participation in the alternate assessment While ESSA does limit the total number of students in the state who are assessed using an alternate assessment based on alternate achievement standards the following provisions are also made

bull A state may not prohibit an LEA from assessing more than 10 percent of its assessed students using an alternate assessment However LEAs that exceed this participation rate must provide justification for exceeding this rate States must make this justification publicly available and provide oversight to LEAs that exceed this rate

Based on data collected from the spring 2017 testing window Michigan has calculated the current rate of students taking an alternate assessment in the state is 24 for English Language Arts 24 for mathematics and 23 for science To demonstrate our plan to bring Michigan into compliance with this regulation MDE will be applying for a waiver for the 2018 testing window as provided for by ESSA which will be submitted to the US Department of Education (US ED) MDE is seeking comments on the waiver application from all interested parties

As required Michiganrsquos waiver application will (inclusive of grades 3-8 and 11) bull Be submitted at least 90 days prior to the start of the testing window bull Provide state-level data from the 2017 testing cycle to show the number and percentage of students (including sub-groups) who took an alternate assessment of all students tested in each subject

bull Demonstrate that Michigan has tested at least 95 of all students and 95 of students with disabilities across all summative assessments and

bull Provide assurances that LEAs contributing to the state exceeding the 1 cap have adhered to the participation guidelines and address any disproportionality in any sub-group of students taking the alternate assessment

Further the waiver will include a plan and timeline by which the state will bull Improve the implementation of its guidelines on the alternate assessment bull Take additional steps to support and provide oversight to each LEA that contributes to the state exceeding the 1 cap and

bull Address any disproportionality in the percentage of students taking the alternate assessment

As we move forward to align with the requirements of ESSA as it relates to alternate assessments it is important to note how this supports MDErsquos Top 10 in 10 initiatives

bull The work is aligned across offices and with appropriate agencies The collection of data communication and technical support is a collaborative effort between the Office of Special Education (OSE) and the Office of

Page 3 November 16 2017

Educational Assessment and Accountability (OEAA) with local information and support coordinated at the ISD level

bull Beyond looking at data in isolation the work is aimed at focusing on child-centered needs ensuring that students are being assessed in ways that are most appropriate to their needs and aligned to the rigorous standards to which they are being instructed on a daily basis

For any interested party comments may be left in the following ways bull Survey httpswwwsurveymonkeycomr1percent_waiver_MI bull Email mde-oeaamichigangov (be sure to include ldquo1 alternate assessment waiverrdquo in the subject line)

bull Via mail Michigan Department of Education 608 W Allegan Street PO Box 30008 Lansing MI 48909 Attn OEAA 1 waiver ndash 2nd floor

The following resources are available on the MI-Access Web Site (wwwmichigangovmi-access) with direct links provided here

bull Michiganrsquos guidelines for participation in the alternate assessment (MI-Access) Alternate Assessment Guidelines

bull Guidelines for ISDrsquos to provide support to LEAs regarding the 1 cap 1 cap ISD Guidance

bull Michiganrsquos alternate content standards alternate content standards

For further information contact John Jaquith at jaquithjmichigangov or 517-335-1987

cc Michigan Education Alliance

Appendix B

Public Comment Responses (in exact language)

Question 1

1 Please comment on Michigans current rate of participation in the

alternate assessment (24 English Language Arts 24 mathematics

23 science)

Does anyone working in the field of education understand what this means for students You want to allow schools to not educate students This is what happens Schools use this as a loophole If you dont believe me PLEASE look at Wayne Resas Special education Plan for students with mutliple needs Segregated sent away and given up on before ever given a chance You are ruining entire life outcomes 12192017 112 PM

To limit the number of students within these subgroups that can take an alternate assessment is unfair We need to be giving our students the assessment that is appropriate for each of them individually based on IEPs 12182017 1241 PM

Students need to be assessed where there skills lieand aligned to IEP goals I dont think a percentage should determine who takes which test 12172017 1212 AM

I believe these rates of over 2 are adequate 1 participation rate is a cookie-cutter formula that defies IDEAMARSE rules and regulations giving the IEPTeam the responsibility of determining which assessment is appropriate for the student based on their individualized level of functioning and needs Participating in alternate assessments is a decision that should be made by the IEPTeam with parentguardian it should not be made because of a unrealistic 1 Cap rule 12142017 813 AM

Just by looking at the normal distribution curve one would expect 21 of the

population to fall 2 standard deviations below the mean I think we might be able to improve the participation rate and how we determine who takes which assessment

through additional training and better analysis of our existing test data IEP teams are currently making these decisions which seems consistent with the law The question i would ask is what are we hoping to gain from this type of assessment

for students with cognitive impairments What is the intent What is gained through this assessment How does it lead to better learning outcomes How does

it improve the outcome for students How does it help instruction What do these assessments (functional independence participation) add to our instructional knowledge for the student What is the intended purpose of these tests How do

they benefit the student or lead to better instruction

12132017 316 PM

Should we look at the need of each child

12132017 258 PM

I wonder if the limit should be adjusted

12132017 225 PM

I feel they are high but in relation to other states Michigan is underfunding their Special Education Programing period 12132017 130 PM

The reason our current rate over 1 in the state of michigan is due to the fact that we assess ALL students Many states only assess mild CI or those that would take Functional Independence I do not believe we would have an issue if we only included participation rates for students participating in FI-MI-Access 12132017 1052 AM

How does Michigans overall participation rate compare to other states Are other states exempting students from assessments that we are including in our alternate assessment 12132017 1014 AM

Although the percentage is much higher than maybe anticipated the assignment of the State assessment is made through an IEP decision making process I would have to believe that the IEP teams are making accurate recommendations based on students cognitive abilities 12122017 1256 PM

When evaluating participate rate in alternate assessments there are several factors that need to be considered The first is overall participation rate in statewide

assessments When reviewing MI School Data Students not Tested in Michigan it is clear that Michigans overall participation rate is incredibly high As the participation

rate increases it is logical that the percentage of students taking alternate assessments will also increase Michigans rate of participation in alternate assessments may not be that high when taking the overall participation rate into

consideration If Michigan were to decrease their overall participation rate and begin exempting groups of students from assessment it would be quite easy to

lower the participation in alternate assessments I dont believe that should be our goal but it is important that we are using data that is truly comparable if we are comparing ourselves to other states The second is the percentage of students with

Cognitive Impairments (or those that function as if they have severe cognitive impairments) in the state In 2016-2017 Michigan had 19249 students eligible as

having a Cognitive Impairment In that same year Michigan had 1532335 total students That means that 125 of our students had Cognitive Impairments While not all CI students are appropriate for alternate assessments many would be In

addition there are also students in other eligibility categories such as SXI (an

additional 2 of students) that would most likely be appropriate for an alternate assessment The eligibility of ASD would also have some students that function as if they have a severe cognitive impairment that may be appropriate for alternate assessments The third which I couldnt find easy access to the data is percentage of students participating in the various levels of our alternate assessments I do believe there are students taking the Functional Independence assessment that would be appropriate for the general assessment However I do not believe in my experience that we have students taking Supported Independence or Participation that would be appropriate for the General Assessment I think it would be valuable to look at the percentage participating in each level of our alternate assessment so we know if we need to be focusing our efforts on the FI level or if there would be a need to even look at SI or P in order to get us to the 1 level 12122017 1141 AM

This seems to be consistent with many LEAs around the state and does not seem excessive 1292017 908 AM

According to a review of our county data regarding participation in the alternate assessment we are almost to 1 just counting the number of students taking Supported Independence and Participation I would be curious about the other counties throughout state as it relates to the alternate assessment participation rates in the areas of Supported Independence and Participation Assessments Students attending programs for moderately cognitively impaired and programs for severe cognitive impairment account for 68 of the population of students with IEPs and 229 of these students are enrolled in grades 3-8 and 11 1282017 223 PM

In looking at data the SXI population alone last year was at 17 so to think that Michigan will ever be under 1 is a challenge Because Autism is such a broad spectrum it is a challenge to be at 1 if you also add in severely cognitively impaired students My point being does the state know the actual percentage of significantly impaired students in the state 1282017 1240 PM

Michigan has a higher rate of assessment participation because we assess more students than other states do 1262017 1044 AM

I feel that limiting the cap to 1 is an can be detrimental to those students who are not cognitively at the level needed to test other than with an alternate assessment A waiver is needed to go beyond 1 1242017 1249 PM

According to the American Community Survey the percentages of people with

disabilities have remained relatively unchanged since 2008 Total percentage of

people with a cognitive impairment is 48 which includes over age 65 24 taking an alternative assessment seems aligned with the data and reasonable 1242017 1111 AM

The request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform on a standardized assessment 1242017 836 AM

It is an IEP team decision for each student to take an alternative assessment It seems that if we have to stay below the 1 it is forcing IEP teams to not look at the individual students need based on data 1232017 847 PM

If these students are in fact receiving Alternate Content Standards and are accurately placed in a program that challenges their abilities then the percentages given are justified 1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt 1212017 1156 AM

Even this seems very low to me There are hundreds of children taking tests that are way beyond their ability to comprehend them I really wish I understood what we are trying to prove 1212017 1154 AM

School districts who operate regional programs for students with cognitive impairments are at a disadvantage with this cap We espouse the virtue of the IEP team making the assessment decision yet we punish districts for going over the arbitrary standard Another disadvantage is we are no longer sending scores back to home districts 11212017 139 PM

As MMC is a college preparatory curriculum and the assortment of MSTEP assessments are intended to measure this curriculum requiring all but 1 of students to demonstrate understanding of that content is inappropriate Additionally consideration of a normally distributed bell curve would suggest 2 of the population falls in the CI range Beyond that parts or all of MSTEP andor MME could be inappropriate for students with severe learning disabilities In light of these normal distributions and the nature of the MMC and its assessments Michigan assessing just over 2 with alternative measure suggests reasonable if not slightly rigid practice Put another way a valid argument MI is testing too many students with MSTEP and MME could be made 11212017 1228 PM

The decision to assess a student with an alternate assessment like MI-Access is ultimately an IEP team decision My concern with the reported percentages relates to each districts interpretation of the appropriateness for a child to be assessed using alternative tools Do we have consistency from district to district with the definition of severe cognitive impairment 11202017 1058 AM

We decide at a METIEP meeting which students have significant cognitive impairments (data cognitive scores) and which test they are able to take Our building has an high number of students who qualify to take the MIAccess because they have a cognitive impairment and they are functioning as if the they have a cognitive impairment Currently our districts participation in the MIAccess is 23 due to these students taking the test The students are in a Basic Classroom which has been labeled a High Needs Resource Room These students are not spread out into other buildings The non-participating students in the other buildings are never severe enough that there is no question that they are not counted for testing the students in the Communication Room are so low they are unable to speak The concern in our district is that these students in our building raise our percentage of participation in the MI Access testing although it is appropriate for the student The shift of concern now seems to be What is the percentage of student participation rather than What is appropriate for the whole child 11182017 723 AM

Very low numbers for high IEP numbers 11172017 1119 AM

This percentage seems to be accurate and although it exceeds the 1 cap we provide educational services to significantly impaired students across the state for whom the Mi Access assessment is the best choice for assessing these students academic knowledge 11172017 754 AM

I work in a district with a high number of students with disabilities A number of those students have or function as having a cognitive deficit Currently my district has 349 of students with IEPs taking alternate assessments As I understand the 1 cap administering Mi-Access to only those students with significant ASD impairments my district will be penalized (in some manner) if we administer the test to students with cognitive impairments 11162017 418 PM

Please look carefully at the makeup of each district and what programs are housed there I run an ISD center-based program for the county ALL of my students have significant disabilities ALL are on Mi-Access Other districts run things differently Michigan might really have that many students who require alternative assessments A deep dive is needed to investigate how alternative assessments are determined in each district 11162017 345 PM

As a special education director we have students who are in a Moderate Cognitively Impaired program and have been exposed to a modified curriculum throughout their educational career It is not in the best interest of them to expect them to participate in the MStep even if they arent considered Significant to many The MStep causes a tremendous amount of stress to students who arent in special education Our job as educators is to look at what is best for the students on an individual level not to make sure we meet a certain percentage Requiring the state to be at 1 or under isnt in the best interest of our students 11162017 310 PM

Based on MiSchool Data 2016-2017 the state of Michigan had 3500 students with a Severe Multiple Impairments (17) eligibility While this data is not reflective of the students in grades 3-8 amp 11 it does provide us with a piece of information Additionally this data does not include other students who function as if they have a significant cognitive impairment IDEA to my knowledge does not limit the number of students who may partake in an alternate assessment it is an IEP team decision I am not making excuses just stating facts Please understand we can always improve 11162017 249 PM

I would like to know the percentage of students that have an IEP that categorizes them as cognitively impaired etc 11162017 134 PM

The current Michigan rate reflects IEP team decisions regarding the appropriateness of participation for any one student IEP teams (parents included) know these students better than any legislator The overall understanding needs to exist that 24 or even 3 of all students does show that the vast majority of students who receive special education services are taking the general education assessment IEP teams have been selective with their decisions with regard to who will participate in the alternative assessment Legislators and the guidelines that are written need to have some level of flexibility for the IEP process 11162017 130 PM

22 of the population has an IQ below 70 Students with cognitive impairments are

working at the best of their ability and that includes an alternative curriculum with

an alternative assessment

Question 2

2 Please comment on what should be included in the plan and timeline for

improvement

Try inclusion real inclusion Kids with complex needs CAN LEARN They need to be provided the resources Ieprsquos need to be looked at for the students who already are not being educated look at the student when you see the amount of time a non verbal multi impaired child is getting for speech services who is attending a

segregated school Every kid in there needs these servuces Lumping the kids together is the worst thing you could do for them This system is a giant failure and nobody cares about the 1

12192017 112 PM

The plan should include monitoring the number of students that are educated using

the alternate content standards not at the assessment point

12182017 1241 PM

I think the timeline should be extended indefinitely Students should not have to

take assessments that will frustrate them unnecessarily No valuable information will be gained from students who are overwhelmed This is why we have IEPs

12172017 1212 AM

Nothing a 1 Cap rule is forcing IEPTeams to make decisions they otherwise would not have made for a student regarding participation in the regular or

alternate assessments Why should there be issued plans of improvement and timelines forced on school districts or programs who are following IDEAMARSE

rules and regulations in an attempt to do whats right for their student MDE should not be mandating additional participation rate requirements and creating more red-

tape and work for districts and staff who are already overly regulated This is part of the reason good people leave education and we are faced with educator shortages

12142017 813 AM

Maybe we should take a closer look at the existing data in comparison to other

classroom or standards based assessment to determine how these data points correlate and how we are using this data

12132017 316 PM

If support is in place for each child they will succeed We cant say what that will be

12132017 258 PM

An honest look at the value of standardized assessment

12132017 225 PM

There should be more time spent on looking at the offerring of programs and support for special education students In addition public schools need more to

support in the general education setting to be proactive to students at a younger age The funding for special education needs to be looked at across the state

12132017 130 PM

Only assess students participating in FI Mi-Access or only include participation rates for students administered FI MiAccess

12132017 1052 AM

According to MI School Data 125 of our total student population is CI This

information should be factored into the plan for improvement How does the rate of students with CI SXI or other eligibility categories compare to this 1 target

12132017 1014 AM

What should be included in the plan is the purpose of the data we are trying to gain from the assessments given There are students that will not perform well on the

assessment or students that will not be able to engage in the assessment due to lack of skills to do so If they are not allowed to access an alternate assessment

than the State will not be able to gain a true picture of where those students are

functioning The information gained from these assessments should be useful in helping students and teachers target areas of improvement through instruction

12122017 1256 PM

Data to the districts on participation rates at all three levels of our alternate

assessment so we can identify at a district and ISD level where the issues are Professional development on assessment selection guidelines It may be helpful to include performance levels on standardized assessments (ex Cognitive scores) that

would be indicative of a possible need to consider alternate assessments Comparison of overall participation rates as well as participation in alternate

assessments If not already available it would be helpful to consider a nationwide study of this data

12122017 1141 AM

Possibly an incremental change from the current 24 to 20 to 15

1292017 908 AM

While local districts need to carefully consider the decisions for students taking functional independence I believe the decision chart and intentional review of students taking alternate assessments by district will help to identify areas of

improvement

1282017 223 PM

Start with what we know the percentages of students with significant cognitive impairment Address those students who take FI specifically to discern if we are

testing to many

1282017 1240 PM

I am not sure how you can plan for students that are not cognitively able to test the regular test Many of the district schools in our county have diminishing numbers in

their student population The 1 is not realistic

1242017 1249 PM

24 seems reasonable why would we force a student to take a test that is beyond their cognitive function

1242017 1111 AM

Again the request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform

on a standardized assessment If however the student shows growth over time the IEP team should consider general assessments as well

1242017 836 AM

MDE can create an online PD but why do we need to improve if it is a team decision to take an alternate assessment Data drives this decision

1232017 847 PM

If when has your district provided training to staff and those involved in the IEP process on the guidelines for choosing the appropriate assessment for the student

training on alternate content standards training on MI-Access How many students do you serve that cross district lines county lines (School of Choice) These

districts should not be penalized for providing service to students who choose them and therefore increase special education numbers What is your percent for each

subcategory (FI SI P) Do any of these students have access to the general education curriculum content standards for the content area in which they are taking a MI-Access assessment

1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

Putting all children in rigorous programming from birth basically taking them from

the impoverished homes and parenting which robs them of the necessary tools to meet these rigorous demands Oh and eliminate birth defects while you are at it and neurological damage I guess maybe all of this by next year

1212017 1154 AM

There should be a waiver for students who are on alternate curriculum andor in

programs for students with significant disabilities

11212017 139 PM

Students who require functional life skills curricula should not be administered

MSTEP or MME Instead they should be provided an assessment (ie MiAccess) that respects their dignity and their ability to show growth in areas they have

received targeted instruction

11212017 1228 PM

To ensure there are consistent practices across the state clear definitions should be

reported to assist with determining the appropriateness of an alternate assessment

11202017 1058 AM

Special Education teachers know the students that they are working with We have already read through the IEP and have determined educational plans for each child

on our caseload If we received a transfer student with an IEP of concern we have already held an IEP and contacted former teachers regarding our concerns about goals andor MET scores and have decided as an IEP Team appropriate teaching

goals along with appropriate assessments and testing needs for these students

Several of my transfer students had MI Alternative Testing (MI Access on their IEPs) which I immediately questioned and amended to read MStep since they are

participating in the general education content standards and come to the Resource Room for intense small group instruction in reading or math The plan should be for

Special Education teachers to submit the names of students on their current caseload the name of the test that is on the students IEP and give rationale or justification for each test that has been selected These names along with the test

rationale should be sent to the Special Education Director and then submitted to the state within the next two weeks due to the shortened week next week because of

Thanksgiving break Timeline for improvement should be to make an amendment to the students IEP within that time if changes need to be made

11182017 723 AM

Educate schoolsteachercounselors let IEP teams know what is available

11172017 1119 AM

I am not sure how we improve the fact that we service students with moderate to severe cognitive impairments If I were a parent of one of these students this statement would be insulting The decision to utilize an alternative assessment is an

IEP team decision of which the parent is a part

11172017 754 AM

PLEASE look at how many kids we have in the state who have significant cognitive impairments That should give MDE an idea of the need Training in determining the

right assessments should be offered as well This could start in spring - in getting a plan Summer for the work (with educators from around the state) Roll out spring of 2019 with training in late spring and summer

11162017 345 PM

I think that if we continue to have open dialog with the IEP team then we are doing

what is best for the student The disability doesnt drive programming so as a team we need to make sure it doesnt drive testing either

11162017 310 PM

The flow chart--Should My Student Take the Alternate Assessment--s a good tool for teams to use in making decisions PD--possibly a short online video one year

timeline

11162017 249 PM

A decision tree on what assessment should be used for each student that can be used across the state

11162017 134 PM

There should be a waiver for districts specifically those districts who operate regional or center-based programs These programs often provided services and

assess students that are significantly impacted by their disability Operating these programs where other districts send their students will effectincrease the percentage of the operating districts rates

11162017 130 PM

The plan should include a realistic percentage of students taking the test

11162017 112 PM

Question 3

3 Other comments

Showing 25 responses

This is against the ADA segregating our kids

12192017 112 PM

My district was at a 11 alternate assessment participation rate last year Dont force our IEPTeams to have to pick the 1 student wholl have to take the regular

assessment if the IEPTeam has already determined that 1 student is appropriate to take the alternate assessment Special education CI and SXI Programs are also

going to be punished when it comes to alternate assessment participation rates at 100 versus the 1 Cap I dont believe a cookie-cutter 1 can realistically take into account every school district or programs population or spectrum of students

with disabilities These assessment decisions should be left to the determination of the students IEPTeam - who knows the students level of functioning and

assessment needs I would much rather see students who score meets or exceeds expectations on MI-ACCESS be required to then take the M-STEP the following year If the student scores not-proficient on the M-STEP then MI-ACCESS could

be reconsidered the following year again for that student

12142017 813 AM

I am left wondering the purpose for this type of assessment How does it aid instruction benefit the student or improve our educational system Are we simply attempting to meet some compliance standard or is this data being used in a

manner that improves outcomes for kids

12132017 316 PM

Please consider that every are has their own needs

12132017 258 PM

Other concern is the way teachers are viewed by the state and the universitys are currently losing students because teachers are not supported in the school system

12132017 130 PM

How does the participation break down for the various levels of the alternate assessment FI SI and P FI is probably where we are going to have the most

flexibility in considering whether students should be taking the general assessment I encourage the department to seek this data when moving forward with the Waiver

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR 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PTB 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RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
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                  40. ResourceTA

Page 3 November 16 2017

Educational Assessment and Accountability (OEAA) with local information and support coordinated at the ISD level

bull Beyond looking at data in isolation the work is aimed at focusing on child-centered needs ensuring that students are being assessed in ways that are most appropriate to their needs and aligned to the rigorous standards to which they are being instructed on a daily basis

For any interested party comments may be left in the following ways bull Survey httpswwwsurveymonkeycomr1percent_waiver_MI bull Email mde-oeaamichigangov (be sure to include ldquo1 alternate assessment waiverrdquo in the subject line)

bull Via mail Michigan Department of Education 608 W Allegan Street PO Box 30008 Lansing MI 48909 Attn OEAA 1 waiver ndash 2nd floor

The following resources are available on the MI-Access Web Site (wwwmichigangovmi-access) with direct links provided here

bull Michiganrsquos guidelines for participation in the alternate assessment (MI-Access) Alternate Assessment Guidelines

bull Guidelines for ISDrsquos to provide support to LEAs regarding the 1 cap 1 cap ISD Guidance

bull Michiganrsquos alternate content standards alternate content standards

For further information contact John Jaquith at jaquithjmichigangov or 517-335-1987

cc Michigan Education Alliance

Appendix B

Public Comment Responses (in exact language)

Question 1

1 Please comment on Michigans current rate of participation in the

alternate assessment (24 English Language Arts 24 mathematics

23 science)

Does anyone working in the field of education understand what this means for students You want to allow schools to not educate students This is what happens Schools use this as a loophole If you dont believe me PLEASE look at Wayne Resas Special education Plan for students with mutliple needs Segregated sent away and given up on before ever given a chance You are ruining entire life outcomes 12192017 112 PM

To limit the number of students within these subgroups that can take an alternate assessment is unfair We need to be giving our students the assessment that is appropriate for each of them individually based on IEPs 12182017 1241 PM

Students need to be assessed where there skills lieand aligned to IEP goals I dont think a percentage should determine who takes which test 12172017 1212 AM

I believe these rates of over 2 are adequate 1 participation rate is a cookie-cutter formula that defies IDEAMARSE rules and regulations giving the IEPTeam the responsibility of determining which assessment is appropriate for the student based on their individualized level of functioning and needs Participating in alternate assessments is a decision that should be made by the IEPTeam with parentguardian it should not be made because of a unrealistic 1 Cap rule 12142017 813 AM

Just by looking at the normal distribution curve one would expect 21 of the

population to fall 2 standard deviations below the mean I think we might be able to improve the participation rate and how we determine who takes which assessment

through additional training and better analysis of our existing test data IEP teams are currently making these decisions which seems consistent with the law The question i would ask is what are we hoping to gain from this type of assessment

for students with cognitive impairments What is the intent What is gained through this assessment How does it lead to better learning outcomes How does

it improve the outcome for students How does it help instruction What do these assessments (functional independence participation) add to our instructional knowledge for the student What is the intended purpose of these tests How do

they benefit the student or lead to better instruction

12132017 316 PM

Should we look at the need of each child

12132017 258 PM

I wonder if the limit should be adjusted

12132017 225 PM

I feel they are high but in relation to other states Michigan is underfunding their Special Education Programing period 12132017 130 PM

The reason our current rate over 1 in the state of michigan is due to the fact that we assess ALL students Many states only assess mild CI or those that would take Functional Independence I do not believe we would have an issue if we only included participation rates for students participating in FI-MI-Access 12132017 1052 AM

How does Michigans overall participation rate compare to other states Are other states exempting students from assessments that we are including in our alternate assessment 12132017 1014 AM

Although the percentage is much higher than maybe anticipated the assignment of the State assessment is made through an IEP decision making process I would have to believe that the IEP teams are making accurate recommendations based on students cognitive abilities 12122017 1256 PM

When evaluating participate rate in alternate assessments there are several factors that need to be considered The first is overall participation rate in statewide

assessments When reviewing MI School Data Students not Tested in Michigan it is clear that Michigans overall participation rate is incredibly high As the participation

rate increases it is logical that the percentage of students taking alternate assessments will also increase Michigans rate of participation in alternate assessments may not be that high when taking the overall participation rate into

consideration If Michigan were to decrease their overall participation rate and begin exempting groups of students from assessment it would be quite easy to

lower the participation in alternate assessments I dont believe that should be our goal but it is important that we are using data that is truly comparable if we are comparing ourselves to other states The second is the percentage of students with

Cognitive Impairments (or those that function as if they have severe cognitive impairments) in the state In 2016-2017 Michigan had 19249 students eligible as

having a Cognitive Impairment In that same year Michigan had 1532335 total students That means that 125 of our students had Cognitive Impairments While not all CI students are appropriate for alternate assessments many would be In

addition there are also students in other eligibility categories such as SXI (an

additional 2 of students) that would most likely be appropriate for an alternate assessment The eligibility of ASD would also have some students that function as if they have a severe cognitive impairment that may be appropriate for alternate assessments The third which I couldnt find easy access to the data is percentage of students participating in the various levels of our alternate assessments I do believe there are students taking the Functional Independence assessment that would be appropriate for the general assessment However I do not believe in my experience that we have students taking Supported Independence or Participation that would be appropriate for the General Assessment I think it would be valuable to look at the percentage participating in each level of our alternate assessment so we know if we need to be focusing our efforts on the FI level or if there would be a need to even look at SI or P in order to get us to the 1 level 12122017 1141 AM

This seems to be consistent with many LEAs around the state and does not seem excessive 1292017 908 AM

According to a review of our county data regarding participation in the alternate assessment we are almost to 1 just counting the number of students taking Supported Independence and Participation I would be curious about the other counties throughout state as it relates to the alternate assessment participation rates in the areas of Supported Independence and Participation Assessments Students attending programs for moderately cognitively impaired and programs for severe cognitive impairment account for 68 of the population of students with IEPs and 229 of these students are enrolled in grades 3-8 and 11 1282017 223 PM

In looking at data the SXI population alone last year was at 17 so to think that Michigan will ever be under 1 is a challenge Because Autism is such a broad spectrum it is a challenge to be at 1 if you also add in severely cognitively impaired students My point being does the state know the actual percentage of significantly impaired students in the state 1282017 1240 PM

Michigan has a higher rate of assessment participation because we assess more students than other states do 1262017 1044 AM

I feel that limiting the cap to 1 is an can be detrimental to those students who are not cognitively at the level needed to test other than with an alternate assessment A waiver is needed to go beyond 1 1242017 1249 PM

According to the American Community Survey the percentages of people with

disabilities have remained relatively unchanged since 2008 Total percentage of

people with a cognitive impairment is 48 which includes over age 65 24 taking an alternative assessment seems aligned with the data and reasonable 1242017 1111 AM

The request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform on a standardized assessment 1242017 836 AM

It is an IEP team decision for each student to take an alternative assessment It seems that if we have to stay below the 1 it is forcing IEP teams to not look at the individual students need based on data 1232017 847 PM

If these students are in fact receiving Alternate Content Standards and are accurately placed in a program that challenges their abilities then the percentages given are justified 1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt 1212017 1156 AM

Even this seems very low to me There are hundreds of children taking tests that are way beyond their ability to comprehend them I really wish I understood what we are trying to prove 1212017 1154 AM

School districts who operate regional programs for students with cognitive impairments are at a disadvantage with this cap We espouse the virtue of the IEP team making the assessment decision yet we punish districts for going over the arbitrary standard Another disadvantage is we are no longer sending scores back to home districts 11212017 139 PM

As MMC is a college preparatory curriculum and the assortment of MSTEP assessments are intended to measure this curriculum requiring all but 1 of students to demonstrate understanding of that content is inappropriate Additionally consideration of a normally distributed bell curve would suggest 2 of the population falls in the CI range Beyond that parts or all of MSTEP andor MME could be inappropriate for students with severe learning disabilities In light of these normal distributions and the nature of the MMC and its assessments Michigan assessing just over 2 with alternative measure suggests reasonable if not slightly rigid practice Put another way a valid argument MI is testing too many students with MSTEP and MME could be made 11212017 1228 PM

The decision to assess a student with an alternate assessment like MI-Access is ultimately an IEP team decision My concern with the reported percentages relates to each districts interpretation of the appropriateness for a child to be assessed using alternative tools Do we have consistency from district to district with the definition of severe cognitive impairment 11202017 1058 AM

We decide at a METIEP meeting which students have significant cognitive impairments (data cognitive scores) and which test they are able to take Our building has an high number of students who qualify to take the MIAccess because they have a cognitive impairment and they are functioning as if the they have a cognitive impairment Currently our districts participation in the MIAccess is 23 due to these students taking the test The students are in a Basic Classroom which has been labeled a High Needs Resource Room These students are not spread out into other buildings The non-participating students in the other buildings are never severe enough that there is no question that they are not counted for testing the students in the Communication Room are so low they are unable to speak The concern in our district is that these students in our building raise our percentage of participation in the MI Access testing although it is appropriate for the student The shift of concern now seems to be What is the percentage of student participation rather than What is appropriate for the whole child 11182017 723 AM

Very low numbers for high IEP numbers 11172017 1119 AM

This percentage seems to be accurate and although it exceeds the 1 cap we provide educational services to significantly impaired students across the state for whom the Mi Access assessment is the best choice for assessing these students academic knowledge 11172017 754 AM

I work in a district with a high number of students with disabilities A number of those students have or function as having a cognitive deficit Currently my district has 349 of students with IEPs taking alternate assessments As I understand the 1 cap administering Mi-Access to only those students with significant ASD impairments my district will be penalized (in some manner) if we administer the test to students with cognitive impairments 11162017 418 PM

Please look carefully at the makeup of each district and what programs are housed there I run an ISD center-based program for the county ALL of my students have significant disabilities ALL are on Mi-Access Other districts run things differently Michigan might really have that many students who require alternative assessments A deep dive is needed to investigate how alternative assessments are determined in each district 11162017 345 PM

As a special education director we have students who are in a Moderate Cognitively Impaired program and have been exposed to a modified curriculum throughout their educational career It is not in the best interest of them to expect them to participate in the MStep even if they arent considered Significant to many The MStep causes a tremendous amount of stress to students who arent in special education Our job as educators is to look at what is best for the students on an individual level not to make sure we meet a certain percentage Requiring the state to be at 1 or under isnt in the best interest of our students 11162017 310 PM

Based on MiSchool Data 2016-2017 the state of Michigan had 3500 students with a Severe Multiple Impairments (17) eligibility While this data is not reflective of the students in grades 3-8 amp 11 it does provide us with a piece of information Additionally this data does not include other students who function as if they have a significant cognitive impairment IDEA to my knowledge does not limit the number of students who may partake in an alternate assessment it is an IEP team decision I am not making excuses just stating facts Please understand we can always improve 11162017 249 PM

I would like to know the percentage of students that have an IEP that categorizes them as cognitively impaired etc 11162017 134 PM

The current Michigan rate reflects IEP team decisions regarding the appropriateness of participation for any one student IEP teams (parents included) know these students better than any legislator The overall understanding needs to exist that 24 or even 3 of all students does show that the vast majority of students who receive special education services are taking the general education assessment IEP teams have been selective with their decisions with regard to who will participate in the alternative assessment Legislators and the guidelines that are written need to have some level of flexibility for the IEP process 11162017 130 PM

22 of the population has an IQ below 70 Students with cognitive impairments are

working at the best of their ability and that includes an alternative curriculum with

an alternative assessment

Question 2

2 Please comment on what should be included in the plan and timeline for

improvement

Try inclusion real inclusion Kids with complex needs CAN LEARN They need to be provided the resources Ieprsquos need to be looked at for the students who already are not being educated look at the student when you see the amount of time a non verbal multi impaired child is getting for speech services who is attending a

segregated school Every kid in there needs these servuces Lumping the kids together is the worst thing you could do for them This system is a giant failure and nobody cares about the 1

12192017 112 PM

The plan should include monitoring the number of students that are educated using

the alternate content standards not at the assessment point

12182017 1241 PM

I think the timeline should be extended indefinitely Students should not have to

take assessments that will frustrate them unnecessarily No valuable information will be gained from students who are overwhelmed This is why we have IEPs

12172017 1212 AM

Nothing a 1 Cap rule is forcing IEPTeams to make decisions they otherwise would not have made for a student regarding participation in the regular or

alternate assessments Why should there be issued plans of improvement and timelines forced on school districts or programs who are following IDEAMARSE

rules and regulations in an attempt to do whats right for their student MDE should not be mandating additional participation rate requirements and creating more red-

tape and work for districts and staff who are already overly regulated This is part of the reason good people leave education and we are faced with educator shortages

12142017 813 AM

Maybe we should take a closer look at the existing data in comparison to other

classroom or standards based assessment to determine how these data points correlate and how we are using this data

12132017 316 PM

If support is in place for each child they will succeed We cant say what that will be

12132017 258 PM

An honest look at the value of standardized assessment

12132017 225 PM

There should be more time spent on looking at the offerring of programs and support for special education students In addition public schools need more to

support in the general education setting to be proactive to students at a younger age The funding for special education needs to be looked at across the state

12132017 130 PM

Only assess students participating in FI Mi-Access or only include participation rates for students administered FI MiAccess

12132017 1052 AM

According to MI School Data 125 of our total student population is CI This

information should be factored into the plan for improvement How does the rate of students with CI SXI or other eligibility categories compare to this 1 target

12132017 1014 AM

What should be included in the plan is the purpose of the data we are trying to gain from the assessments given There are students that will not perform well on the

assessment or students that will not be able to engage in the assessment due to lack of skills to do so If they are not allowed to access an alternate assessment

than the State will not be able to gain a true picture of where those students are

functioning The information gained from these assessments should be useful in helping students and teachers target areas of improvement through instruction

12122017 1256 PM

Data to the districts on participation rates at all three levels of our alternate

assessment so we can identify at a district and ISD level where the issues are Professional development on assessment selection guidelines It may be helpful to include performance levels on standardized assessments (ex Cognitive scores) that

would be indicative of a possible need to consider alternate assessments Comparison of overall participation rates as well as participation in alternate

assessments If not already available it would be helpful to consider a nationwide study of this data

12122017 1141 AM

Possibly an incremental change from the current 24 to 20 to 15

1292017 908 AM

While local districts need to carefully consider the decisions for students taking functional independence I believe the decision chart and intentional review of students taking alternate assessments by district will help to identify areas of

improvement

1282017 223 PM

Start with what we know the percentages of students with significant cognitive impairment Address those students who take FI specifically to discern if we are

testing to many

1282017 1240 PM

I am not sure how you can plan for students that are not cognitively able to test the regular test Many of the district schools in our county have diminishing numbers in

their student population The 1 is not realistic

1242017 1249 PM

24 seems reasonable why would we force a student to take a test that is beyond their cognitive function

1242017 1111 AM

Again the request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform

on a standardized assessment If however the student shows growth over time the IEP team should consider general assessments as well

1242017 836 AM

MDE can create an online PD but why do we need to improve if it is a team decision to take an alternate assessment Data drives this decision

1232017 847 PM

If when has your district provided training to staff and those involved in the IEP process on the guidelines for choosing the appropriate assessment for the student

training on alternate content standards training on MI-Access How many students do you serve that cross district lines county lines (School of Choice) These

districts should not be penalized for providing service to students who choose them and therefore increase special education numbers What is your percent for each

subcategory (FI SI P) Do any of these students have access to the general education curriculum content standards for the content area in which they are taking a MI-Access assessment

1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

Putting all children in rigorous programming from birth basically taking them from

the impoverished homes and parenting which robs them of the necessary tools to meet these rigorous demands Oh and eliminate birth defects while you are at it and neurological damage I guess maybe all of this by next year

1212017 1154 AM

There should be a waiver for students who are on alternate curriculum andor in

programs for students with significant disabilities

11212017 139 PM

Students who require functional life skills curricula should not be administered

MSTEP or MME Instead they should be provided an assessment (ie MiAccess) that respects their dignity and their ability to show growth in areas they have

received targeted instruction

11212017 1228 PM

To ensure there are consistent practices across the state clear definitions should be

reported to assist with determining the appropriateness of an alternate assessment

11202017 1058 AM

Special Education teachers know the students that they are working with We have already read through the IEP and have determined educational plans for each child

on our caseload If we received a transfer student with an IEP of concern we have already held an IEP and contacted former teachers regarding our concerns about goals andor MET scores and have decided as an IEP Team appropriate teaching

goals along with appropriate assessments and testing needs for these students

Several of my transfer students had MI Alternative Testing (MI Access on their IEPs) which I immediately questioned and amended to read MStep since they are

participating in the general education content standards and come to the Resource Room for intense small group instruction in reading or math The plan should be for

Special Education teachers to submit the names of students on their current caseload the name of the test that is on the students IEP and give rationale or justification for each test that has been selected These names along with the test

rationale should be sent to the Special Education Director and then submitted to the state within the next two weeks due to the shortened week next week because of

Thanksgiving break Timeline for improvement should be to make an amendment to the students IEP within that time if changes need to be made

11182017 723 AM

Educate schoolsteachercounselors let IEP teams know what is available

11172017 1119 AM

I am not sure how we improve the fact that we service students with moderate to severe cognitive impairments If I were a parent of one of these students this statement would be insulting The decision to utilize an alternative assessment is an

IEP team decision of which the parent is a part

11172017 754 AM

PLEASE look at how many kids we have in the state who have significant cognitive impairments That should give MDE an idea of the need Training in determining the

right assessments should be offered as well This could start in spring - in getting a plan Summer for the work (with educators from around the state) Roll out spring of 2019 with training in late spring and summer

11162017 345 PM

I think that if we continue to have open dialog with the IEP team then we are doing

what is best for the student The disability doesnt drive programming so as a team we need to make sure it doesnt drive testing either

11162017 310 PM

The flow chart--Should My Student Take the Alternate Assessment--s a good tool for teams to use in making decisions PD--possibly a short online video one year

timeline

11162017 249 PM

A decision tree on what assessment should be used for each student that can be used across the state

11162017 134 PM

There should be a waiver for districts specifically those districts who operate regional or center-based programs These programs often provided services and

assess students that are significantly impacted by their disability Operating these programs where other districts send their students will effectincrease the percentage of the operating districts rates

11162017 130 PM

The plan should include a realistic percentage of students taking the test

11162017 112 PM

Question 3

3 Other comments

Showing 25 responses

This is against the ADA segregating our kids

12192017 112 PM

My district was at a 11 alternate assessment participation rate last year Dont force our IEPTeams to have to pick the 1 student wholl have to take the regular

assessment if the IEPTeam has already determined that 1 student is appropriate to take the alternate assessment Special education CI and SXI Programs are also

going to be punished when it comes to alternate assessment participation rates at 100 versus the 1 Cap I dont believe a cookie-cutter 1 can realistically take into account every school district or programs population or spectrum of students

with disabilities These assessment decisions should be left to the determination of the students IEPTeam - who knows the students level of functioning and

assessment needs I would much rather see students who score meets or exceeds expectations on MI-ACCESS be required to then take the M-STEP the following year If the student scores not-proficient on the M-STEP then MI-ACCESS could

be reconsidered the following year again for that student

12142017 813 AM

I am left wondering the purpose for this type of assessment How does it aid instruction benefit the student or improve our educational system Are we simply attempting to meet some compliance standard or is this data being used in a

manner that improves outcomes for kids

12132017 316 PM

Please consider that every are has their own needs

12132017 258 PM

Other concern is the way teachers are viewed by the state and the universitys are currently losing students because teachers are not supported in the school system

12132017 130 PM

How does the participation break down for the various levels of the alternate assessment FI SI and P FI is probably where we are going to have the most

flexibility in considering whether students should be taking the general assessment I encourage the department to seek this data when moving forward with the Waiver

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR 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PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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RUM 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 RUS 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
                  20. GuideDocsRelServStaff Off
                  21. NoTrainAdmin Off
                  22. NoTrainSpecialEdStaff Off
                  23. NoTrainParents Off
                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
                  26. OtherSpecialEdStaff Off
                  27. OtherParents Off
                  28. OtherRelServStaff Off
                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

Appendix B

Public Comment Responses (in exact language)

Question 1

1 Please comment on Michigans current rate of participation in the

alternate assessment (24 English Language Arts 24 mathematics

23 science)

Does anyone working in the field of education understand what this means for students You want to allow schools to not educate students This is what happens Schools use this as a loophole If you dont believe me PLEASE look at Wayne Resas Special education Plan for students with mutliple needs Segregated sent away and given up on before ever given a chance You are ruining entire life outcomes 12192017 112 PM

To limit the number of students within these subgroups that can take an alternate assessment is unfair We need to be giving our students the assessment that is appropriate for each of them individually based on IEPs 12182017 1241 PM

Students need to be assessed where there skills lieand aligned to IEP goals I dont think a percentage should determine who takes which test 12172017 1212 AM

I believe these rates of over 2 are adequate 1 participation rate is a cookie-cutter formula that defies IDEAMARSE rules and regulations giving the IEPTeam the responsibility of determining which assessment is appropriate for the student based on their individualized level of functioning and needs Participating in alternate assessments is a decision that should be made by the IEPTeam with parentguardian it should not be made because of a unrealistic 1 Cap rule 12142017 813 AM

Just by looking at the normal distribution curve one would expect 21 of the

population to fall 2 standard deviations below the mean I think we might be able to improve the participation rate and how we determine who takes which assessment

through additional training and better analysis of our existing test data IEP teams are currently making these decisions which seems consistent with the law The question i would ask is what are we hoping to gain from this type of assessment

for students with cognitive impairments What is the intent What is gained through this assessment How does it lead to better learning outcomes How does

it improve the outcome for students How does it help instruction What do these assessments (functional independence participation) add to our instructional knowledge for the student What is the intended purpose of these tests How do

they benefit the student or lead to better instruction

12132017 316 PM

Should we look at the need of each child

12132017 258 PM

I wonder if the limit should be adjusted

12132017 225 PM

I feel they are high but in relation to other states Michigan is underfunding their Special Education Programing period 12132017 130 PM

The reason our current rate over 1 in the state of michigan is due to the fact that we assess ALL students Many states only assess mild CI or those that would take Functional Independence I do not believe we would have an issue if we only included participation rates for students participating in FI-MI-Access 12132017 1052 AM

How does Michigans overall participation rate compare to other states Are other states exempting students from assessments that we are including in our alternate assessment 12132017 1014 AM

Although the percentage is much higher than maybe anticipated the assignment of the State assessment is made through an IEP decision making process I would have to believe that the IEP teams are making accurate recommendations based on students cognitive abilities 12122017 1256 PM

When evaluating participate rate in alternate assessments there are several factors that need to be considered The first is overall participation rate in statewide

assessments When reviewing MI School Data Students not Tested in Michigan it is clear that Michigans overall participation rate is incredibly high As the participation

rate increases it is logical that the percentage of students taking alternate assessments will also increase Michigans rate of participation in alternate assessments may not be that high when taking the overall participation rate into

consideration If Michigan were to decrease their overall participation rate and begin exempting groups of students from assessment it would be quite easy to

lower the participation in alternate assessments I dont believe that should be our goal but it is important that we are using data that is truly comparable if we are comparing ourselves to other states The second is the percentage of students with

Cognitive Impairments (or those that function as if they have severe cognitive impairments) in the state In 2016-2017 Michigan had 19249 students eligible as

having a Cognitive Impairment In that same year Michigan had 1532335 total students That means that 125 of our students had Cognitive Impairments While not all CI students are appropriate for alternate assessments many would be In

addition there are also students in other eligibility categories such as SXI (an

additional 2 of students) that would most likely be appropriate for an alternate assessment The eligibility of ASD would also have some students that function as if they have a severe cognitive impairment that may be appropriate for alternate assessments The third which I couldnt find easy access to the data is percentage of students participating in the various levels of our alternate assessments I do believe there are students taking the Functional Independence assessment that would be appropriate for the general assessment However I do not believe in my experience that we have students taking Supported Independence or Participation that would be appropriate for the General Assessment I think it would be valuable to look at the percentage participating in each level of our alternate assessment so we know if we need to be focusing our efforts on the FI level or if there would be a need to even look at SI or P in order to get us to the 1 level 12122017 1141 AM

This seems to be consistent with many LEAs around the state and does not seem excessive 1292017 908 AM

According to a review of our county data regarding participation in the alternate assessment we are almost to 1 just counting the number of students taking Supported Independence and Participation I would be curious about the other counties throughout state as it relates to the alternate assessment participation rates in the areas of Supported Independence and Participation Assessments Students attending programs for moderately cognitively impaired and programs for severe cognitive impairment account for 68 of the population of students with IEPs and 229 of these students are enrolled in grades 3-8 and 11 1282017 223 PM

In looking at data the SXI population alone last year was at 17 so to think that Michigan will ever be under 1 is a challenge Because Autism is such a broad spectrum it is a challenge to be at 1 if you also add in severely cognitively impaired students My point being does the state know the actual percentage of significantly impaired students in the state 1282017 1240 PM

Michigan has a higher rate of assessment participation because we assess more students than other states do 1262017 1044 AM

I feel that limiting the cap to 1 is an can be detrimental to those students who are not cognitively at the level needed to test other than with an alternate assessment A waiver is needed to go beyond 1 1242017 1249 PM

According to the American Community Survey the percentages of people with

disabilities have remained relatively unchanged since 2008 Total percentage of

people with a cognitive impairment is 48 which includes over age 65 24 taking an alternative assessment seems aligned with the data and reasonable 1242017 1111 AM

The request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform on a standardized assessment 1242017 836 AM

It is an IEP team decision for each student to take an alternative assessment It seems that if we have to stay below the 1 it is forcing IEP teams to not look at the individual students need based on data 1232017 847 PM

If these students are in fact receiving Alternate Content Standards and are accurately placed in a program that challenges their abilities then the percentages given are justified 1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt 1212017 1156 AM

Even this seems very low to me There are hundreds of children taking tests that are way beyond their ability to comprehend them I really wish I understood what we are trying to prove 1212017 1154 AM

School districts who operate regional programs for students with cognitive impairments are at a disadvantage with this cap We espouse the virtue of the IEP team making the assessment decision yet we punish districts for going over the arbitrary standard Another disadvantage is we are no longer sending scores back to home districts 11212017 139 PM

As MMC is a college preparatory curriculum and the assortment of MSTEP assessments are intended to measure this curriculum requiring all but 1 of students to demonstrate understanding of that content is inappropriate Additionally consideration of a normally distributed bell curve would suggest 2 of the population falls in the CI range Beyond that parts or all of MSTEP andor MME could be inappropriate for students with severe learning disabilities In light of these normal distributions and the nature of the MMC and its assessments Michigan assessing just over 2 with alternative measure suggests reasonable if not slightly rigid practice Put another way a valid argument MI is testing too many students with MSTEP and MME could be made 11212017 1228 PM

The decision to assess a student with an alternate assessment like MI-Access is ultimately an IEP team decision My concern with the reported percentages relates to each districts interpretation of the appropriateness for a child to be assessed using alternative tools Do we have consistency from district to district with the definition of severe cognitive impairment 11202017 1058 AM

We decide at a METIEP meeting which students have significant cognitive impairments (data cognitive scores) and which test they are able to take Our building has an high number of students who qualify to take the MIAccess because they have a cognitive impairment and they are functioning as if the they have a cognitive impairment Currently our districts participation in the MIAccess is 23 due to these students taking the test The students are in a Basic Classroom which has been labeled a High Needs Resource Room These students are not spread out into other buildings The non-participating students in the other buildings are never severe enough that there is no question that they are not counted for testing the students in the Communication Room are so low they are unable to speak The concern in our district is that these students in our building raise our percentage of participation in the MI Access testing although it is appropriate for the student The shift of concern now seems to be What is the percentage of student participation rather than What is appropriate for the whole child 11182017 723 AM

Very low numbers for high IEP numbers 11172017 1119 AM

This percentage seems to be accurate and although it exceeds the 1 cap we provide educational services to significantly impaired students across the state for whom the Mi Access assessment is the best choice for assessing these students academic knowledge 11172017 754 AM

I work in a district with a high number of students with disabilities A number of those students have or function as having a cognitive deficit Currently my district has 349 of students with IEPs taking alternate assessments As I understand the 1 cap administering Mi-Access to only those students with significant ASD impairments my district will be penalized (in some manner) if we administer the test to students with cognitive impairments 11162017 418 PM

Please look carefully at the makeup of each district and what programs are housed there I run an ISD center-based program for the county ALL of my students have significant disabilities ALL are on Mi-Access Other districts run things differently Michigan might really have that many students who require alternative assessments A deep dive is needed to investigate how alternative assessments are determined in each district 11162017 345 PM

As a special education director we have students who are in a Moderate Cognitively Impaired program and have been exposed to a modified curriculum throughout their educational career It is not in the best interest of them to expect them to participate in the MStep even if they arent considered Significant to many The MStep causes a tremendous amount of stress to students who arent in special education Our job as educators is to look at what is best for the students on an individual level not to make sure we meet a certain percentage Requiring the state to be at 1 or under isnt in the best interest of our students 11162017 310 PM

Based on MiSchool Data 2016-2017 the state of Michigan had 3500 students with a Severe Multiple Impairments (17) eligibility While this data is not reflective of the students in grades 3-8 amp 11 it does provide us with a piece of information Additionally this data does not include other students who function as if they have a significant cognitive impairment IDEA to my knowledge does not limit the number of students who may partake in an alternate assessment it is an IEP team decision I am not making excuses just stating facts Please understand we can always improve 11162017 249 PM

I would like to know the percentage of students that have an IEP that categorizes them as cognitively impaired etc 11162017 134 PM

The current Michigan rate reflects IEP team decisions regarding the appropriateness of participation for any one student IEP teams (parents included) know these students better than any legislator The overall understanding needs to exist that 24 or even 3 of all students does show that the vast majority of students who receive special education services are taking the general education assessment IEP teams have been selective with their decisions with regard to who will participate in the alternative assessment Legislators and the guidelines that are written need to have some level of flexibility for the IEP process 11162017 130 PM

22 of the population has an IQ below 70 Students with cognitive impairments are

working at the best of their ability and that includes an alternative curriculum with

an alternative assessment

Question 2

2 Please comment on what should be included in the plan and timeline for

improvement

Try inclusion real inclusion Kids with complex needs CAN LEARN They need to be provided the resources Ieprsquos need to be looked at for the students who already are not being educated look at the student when you see the amount of time a non verbal multi impaired child is getting for speech services who is attending a

segregated school Every kid in there needs these servuces Lumping the kids together is the worst thing you could do for them This system is a giant failure and nobody cares about the 1

12192017 112 PM

The plan should include monitoring the number of students that are educated using

the alternate content standards not at the assessment point

12182017 1241 PM

I think the timeline should be extended indefinitely Students should not have to

take assessments that will frustrate them unnecessarily No valuable information will be gained from students who are overwhelmed This is why we have IEPs

12172017 1212 AM

Nothing a 1 Cap rule is forcing IEPTeams to make decisions they otherwise would not have made for a student regarding participation in the regular or

alternate assessments Why should there be issued plans of improvement and timelines forced on school districts or programs who are following IDEAMARSE

rules and regulations in an attempt to do whats right for their student MDE should not be mandating additional participation rate requirements and creating more red-

tape and work for districts and staff who are already overly regulated This is part of the reason good people leave education and we are faced with educator shortages

12142017 813 AM

Maybe we should take a closer look at the existing data in comparison to other

classroom or standards based assessment to determine how these data points correlate and how we are using this data

12132017 316 PM

If support is in place for each child they will succeed We cant say what that will be

12132017 258 PM

An honest look at the value of standardized assessment

12132017 225 PM

There should be more time spent on looking at the offerring of programs and support for special education students In addition public schools need more to

support in the general education setting to be proactive to students at a younger age The funding for special education needs to be looked at across the state

12132017 130 PM

Only assess students participating in FI Mi-Access or only include participation rates for students administered FI MiAccess

12132017 1052 AM

According to MI School Data 125 of our total student population is CI This

information should be factored into the plan for improvement How does the rate of students with CI SXI or other eligibility categories compare to this 1 target

12132017 1014 AM

What should be included in the plan is the purpose of the data we are trying to gain from the assessments given There are students that will not perform well on the

assessment or students that will not be able to engage in the assessment due to lack of skills to do so If they are not allowed to access an alternate assessment

than the State will not be able to gain a true picture of where those students are

functioning The information gained from these assessments should be useful in helping students and teachers target areas of improvement through instruction

12122017 1256 PM

Data to the districts on participation rates at all three levels of our alternate

assessment so we can identify at a district and ISD level where the issues are Professional development on assessment selection guidelines It may be helpful to include performance levels on standardized assessments (ex Cognitive scores) that

would be indicative of a possible need to consider alternate assessments Comparison of overall participation rates as well as participation in alternate

assessments If not already available it would be helpful to consider a nationwide study of this data

12122017 1141 AM

Possibly an incremental change from the current 24 to 20 to 15

1292017 908 AM

While local districts need to carefully consider the decisions for students taking functional independence I believe the decision chart and intentional review of students taking alternate assessments by district will help to identify areas of

improvement

1282017 223 PM

Start with what we know the percentages of students with significant cognitive impairment Address those students who take FI specifically to discern if we are

testing to many

1282017 1240 PM

I am not sure how you can plan for students that are not cognitively able to test the regular test Many of the district schools in our county have diminishing numbers in

their student population The 1 is not realistic

1242017 1249 PM

24 seems reasonable why would we force a student to take a test that is beyond their cognitive function

1242017 1111 AM

Again the request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform

on a standardized assessment If however the student shows growth over time the IEP team should consider general assessments as well

1242017 836 AM

MDE can create an online PD but why do we need to improve if it is a team decision to take an alternate assessment Data drives this decision

1232017 847 PM

If when has your district provided training to staff and those involved in the IEP process on the guidelines for choosing the appropriate assessment for the student

training on alternate content standards training on MI-Access How many students do you serve that cross district lines county lines (School of Choice) These

districts should not be penalized for providing service to students who choose them and therefore increase special education numbers What is your percent for each

subcategory (FI SI P) Do any of these students have access to the general education curriculum content standards for the content area in which they are taking a MI-Access assessment

1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

Putting all children in rigorous programming from birth basically taking them from

the impoverished homes and parenting which robs them of the necessary tools to meet these rigorous demands Oh and eliminate birth defects while you are at it and neurological damage I guess maybe all of this by next year

1212017 1154 AM

There should be a waiver for students who are on alternate curriculum andor in

programs for students with significant disabilities

11212017 139 PM

Students who require functional life skills curricula should not be administered

MSTEP or MME Instead they should be provided an assessment (ie MiAccess) that respects their dignity and their ability to show growth in areas they have

received targeted instruction

11212017 1228 PM

To ensure there are consistent practices across the state clear definitions should be

reported to assist with determining the appropriateness of an alternate assessment

11202017 1058 AM

Special Education teachers know the students that they are working with We have already read through the IEP and have determined educational plans for each child

on our caseload If we received a transfer student with an IEP of concern we have already held an IEP and contacted former teachers regarding our concerns about goals andor MET scores and have decided as an IEP Team appropriate teaching

goals along with appropriate assessments and testing needs for these students

Several of my transfer students had MI Alternative Testing (MI Access on their IEPs) which I immediately questioned and amended to read MStep since they are

participating in the general education content standards and come to the Resource Room for intense small group instruction in reading or math The plan should be for

Special Education teachers to submit the names of students on their current caseload the name of the test that is on the students IEP and give rationale or justification for each test that has been selected These names along with the test

rationale should be sent to the Special Education Director and then submitted to the state within the next two weeks due to the shortened week next week because of

Thanksgiving break Timeline for improvement should be to make an amendment to the students IEP within that time if changes need to be made

11182017 723 AM

Educate schoolsteachercounselors let IEP teams know what is available

11172017 1119 AM

I am not sure how we improve the fact that we service students with moderate to severe cognitive impairments If I were a parent of one of these students this statement would be insulting The decision to utilize an alternative assessment is an

IEP team decision of which the parent is a part

11172017 754 AM

PLEASE look at how many kids we have in the state who have significant cognitive impairments That should give MDE an idea of the need Training in determining the

right assessments should be offered as well This could start in spring - in getting a plan Summer for the work (with educators from around the state) Roll out spring of 2019 with training in late spring and summer

11162017 345 PM

I think that if we continue to have open dialog with the IEP team then we are doing

what is best for the student The disability doesnt drive programming so as a team we need to make sure it doesnt drive testing either

11162017 310 PM

The flow chart--Should My Student Take the Alternate Assessment--s a good tool for teams to use in making decisions PD--possibly a short online video one year

timeline

11162017 249 PM

A decision tree on what assessment should be used for each student that can be used across the state

11162017 134 PM

There should be a waiver for districts specifically those districts who operate regional or center-based programs These programs often provided services and

assess students that are significantly impacted by their disability Operating these programs where other districts send their students will effectincrease the percentage of the operating districts rates

11162017 130 PM

The plan should include a realistic percentage of students taking the test

11162017 112 PM

Question 3

3 Other comments

Showing 25 responses

This is against the ADA segregating our kids

12192017 112 PM

My district was at a 11 alternate assessment participation rate last year Dont force our IEPTeams to have to pick the 1 student wholl have to take the regular

assessment if the IEPTeam has already determined that 1 student is appropriate to take the alternate assessment Special education CI and SXI Programs are also

going to be punished when it comes to alternate assessment participation rates at 100 versus the 1 Cap I dont believe a cookie-cutter 1 can realistically take into account every school district or programs population or spectrum of students

with disabilities These assessment decisions should be left to the determination of the students IEPTeam - who knows the students level of functioning and

assessment needs I would much rather see students who score meets or exceeds expectations on MI-ACCESS be required to then take the M-STEP the following year If the student scores not-proficient on the M-STEP then MI-ACCESS could

be reconsidered the following year again for that student

12142017 813 AM

I am left wondering the purpose for this type of assessment How does it aid instruction benefit the student or improve our educational system Are we simply attempting to meet some compliance standard or is this data being used in a

manner that improves outcomes for kids

12132017 316 PM

Please consider that every are has their own needs

12132017 258 PM

Other concern is the way teachers are viewed by the state and the universitys are currently losing students because teachers are not supported in the school system

12132017 130 PM

How does the participation break down for the various levels of the alternate assessment FI SI and P FI is probably where we are going to have the most

flexibility in considering whether students should be taking the general assessment I encourage the department to seek this data when moving forward with the Waiver

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 DEU 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 ESP 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 FRA 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 GRE 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 HEB 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 HRV 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020be44c988b2c8c2a40020bb38c11cb97c0020c548c815c801c73cb85c0020bcf4ace00020c778c1c4d558b2940020b3700020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200036002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL 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 PTB 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RUM 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 RUS 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                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
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                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
                  26. OtherSpecialEdStaff Off
                  27. OtherParents Off
                  28. OtherRelServStaff Off
                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

12132017 316 PM

Should we look at the need of each child

12132017 258 PM

I wonder if the limit should be adjusted

12132017 225 PM

I feel they are high but in relation to other states Michigan is underfunding their Special Education Programing period 12132017 130 PM

The reason our current rate over 1 in the state of michigan is due to the fact that we assess ALL students Many states only assess mild CI or those that would take Functional Independence I do not believe we would have an issue if we only included participation rates for students participating in FI-MI-Access 12132017 1052 AM

How does Michigans overall participation rate compare to other states Are other states exempting students from assessments that we are including in our alternate assessment 12132017 1014 AM

Although the percentage is much higher than maybe anticipated the assignment of the State assessment is made through an IEP decision making process I would have to believe that the IEP teams are making accurate recommendations based on students cognitive abilities 12122017 1256 PM

When evaluating participate rate in alternate assessments there are several factors that need to be considered The first is overall participation rate in statewide

assessments When reviewing MI School Data Students not Tested in Michigan it is clear that Michigans overall participation rate is incredibly high As the participation

rate increases it is logical that the percentage of students taking alternate assessments will also increase Michigans rate of participation in alternate assessments may not be that high when taking the overall participation rate into

consideration If Michigan were to decrease their overall participation rate and begin exempting groups of students from assessment it would be quite easy to

lower the participation in alternate assessments I dont believe that should be our goal but it is important that we are using data that is truly comparable if we are comparing ourselves to other states The second is the percentage of students with

Cognitive Impairments (or those that function as if they have severe cognitive impairments) in the state In 2016-2017 Michigan had 19249 students eligible as

having a Cognitive Impairment In that same year Michigan had 1532335 total students That means that 125 of our students had Cognitive Impairments While not all CI students are appropriate for alternate assessments many would be In

addition there are also students in other eligibility categories such as SXI (an

additional 2 of students) that would most likely be appropriate for an alternate assessment The eligibility of ASD would also have some students that function as if they have a severe cognitive impairment that may be appropriate for alternate assessments The third which I couldnt find easy access to the data is percentage of students participating in the various levels of our alternate assessments I do believe there are students taking the Functional Independence assessment that would be appropriate for the general assessment However I do not believe in my experience that we have students taking Supported Independence or Participation that would be appropriate for the General Assessment I think it would be valuable to look at the percentage participating in each level of our alternate assessment so we know if we need to be focusing our efforts on the FI level or if there would be a need to even look at SI or P in order to get us to the 1 level 12122017 1141 AM

This seems to be consistent with many LEAs around the state and does not seem excessive 1292017 908 AM

According to a review of our county data regarding participation in the alternate assessment we are almost to 1 just counting the number of students taking Supported Independence and Participation I would be curious about the other counties throughout state as it relates to the alternate assessment participation rates in the areas of Supported Independence and Participation Assessments Students attending programs for moderately cognitively impaired and programs for severe cognitive impairment account for 68 of the population of students with IEPs and 229 of these students are enrolled in grades 3-8 and 11 1282017 223 PM

In looking at data the SXI population alone last year was at 17 so to think that Michigan will ever be under 1 is a challenge Because Autism is such a broad spectrum it is a challenge to be at 1 if you also add in severely cognitively impaired students My point being does the state know the actual percentage of significantly impaired students in the state 1282017 1240 PM

Michigan has a higher rate of assessment participation because we assess more students than other states do 1262017 1044 AM

I feel that limiting the cap to 1 is an can be detrimental to those students who are not cognitively at the level needed to test other than with an alternate assessment A waiver is needed to go beyond 1 1242017 1249 PM

According to the American Community Survey the percentages of people with

disabilities have remained relatively unchanged since 2008 Total percentage of

people with a cognitive impairment is 48 which includes over age 65 24 taking an alternative assessment seems aligned with the data and reasonable 1242017 1111 AM

The request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform on a standardized assessment 1242017 836 AM

It is an IEP team decision for each student to take an alternative assessment It seems that if we have to stay below the 1 it is forcing IEP teams to not look at the individual students need based on data 1232017 847 PM

If these students are in fact receiving Alternate Content Standards and are accurately placed in a program that challenges their abilities then the percentages given are justified 1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt 1212017 1156 AM

Even this seems very low to me There are hundreds of children taking tests that are way beyond their ability to comprehend them I really wish I understood what we are trying to prove 1212017 1154 AM

School districts who operate regional programs for students with cognitive impairments are at a disadvantage with this cap We espouse the virtue of the IEP team making the assessment decision yet we punish districts for going over the arbitrary standard Another disadvantage is we are no longer sending scores back to home districts 11212017 139 PM

As MMC is a college preparatory curriculum and the assortment of MSTEP assessments are intended to measure this curriculum requiring all but 1 of students to demonstrate understanding of that content is inappropriate Additionally consideration of a normally distributed bell curve would suggest 2 of the population falls in the CI range Beyond that parts or all of MSTEP andor MME could be inappropriate for students with severe learning disabilities In light of these normal distributions and the nature of the MMC and its assessments Michigan assessing just over 2 with alternative measure suggests reasonable if not slightly rigid practice Put another way a valid argument MI is testing too many students with MSTEP and MME could be made 11212017 1228 PM

The decision to assess a student with an alternate assessment like MI-Access is ultimately an IEP team decision My concern with the reported percentages relates to each districts interpretation of the appropriateness for a child to be assessed using alternative tools Do we have consistency from district to district with the definition of severe cognitive impairment 11202017 1058 AM

We decide at a METIEP meeting which students have significant cognitive impairments (data cognitive scores) and which test they are able to take Our building has an high number of students who qualify to take the MIAccess because they have a cognitive impairment and they are functioning as if the they have a cognitive impairment Currently our districts participation in the MIAccess is 23 due to these students taking the test The students are in a Basic Classroom which has been labeled a High Needs Resource Room These students are not spread out into other buildings The non-participating students in the other buildings are never severe enough that there is no question that they are not counted for testing the students in the Communication Room are so low they are unable to speak The concern in our district is that these students in our building raise our percentage of participation in the MI Access testing although it is appropriate for the student The shift of concern now seems to be What is the percentage of student participation rather than What is appropriate for the whole child 11182017 723 AM

Very low numbers for high IEP numbers 11172017 1119 AM

This percentage seems to be accurate and although it exceeds the 1 cap we provide educational services to significantly impaired students across the state for whom the Mi Access assessment is the best choice for assessing these students academic knowledge 11172017 754 AM

I work in a district with a high number of students with disabilities A number of those students have or function as having a cognitive deficit Currently my district has 349 of students with IEPs taking alternate assessments As I understand the 1 cap administering Mi-Access to only those students with significant ASD impairments my district will be penalized (in some manner) if we administer the test to students with cognitive impairments 11162017 418 PM

Please look carefully at the makeup of each district and what programs are housed there I run an ISD center-based program for the county ALL of my students have significant disabilities ALL are on Mi-Access Other districts run things differently Michigan might really have that many students who require alternative assessments A deep dive is needed to investigate how alternative assessments are determined in each district 11162017 345 PM

As a special education director we have students who are in a Moderate Cognitively Impaired program and have been exposed to a modified curriculum throughout their educational career It is not in the best interest of them to expect them to participate in the MStep even if they arent considered Significant to many The MStep causes a tremendous amount of stress to students who arent in special education Our job as educators is to look at what is best for the students on an individual level not to make sure we meet a certain percentage Requiring the state to be at 1 or under isnt in the best interest of our students 11162017 310 PM

Based on MiSchool Data 2016-2017 the state of Michigan had 3500 students with a Severe Multiple Impairments (17) eligibility While this data is not reflective of the students in grades 3-8 amp 11 it does provide us with a piece of information Additionally this data does not include other students who function as if they have a significant cognitive impairment IDEA to my knowledge does not limit the number of students who may partake in an alternate assessment it is an IEP team decision I am not making excuses just stating facts Please understand we can always improve 11162017 249 PM

I would like to know the percentage of students that have an IEP that categorizes them as cognitively impaired etc 11162017 134 PM

The current Michigan rate reflects IEP team decisions regarding the appropriateness of participation for any one student IEP teams (parents included) know these students better than any legislator The overall understanding needs to exist that 24 or even 3 of all students does show that the vast majority of students who receive special education services are taking the general education assessment IEP teams have been selective with their decisions with regard to who will participate in the alternative assessment Legislators and the guidelines that are written need to have some level of flexibility for the IEP process 11162017 130 PM

22 of the population has an IQ below 70 Students with cognitive impairments are

working at the best of their ability and that includes an alternative curriculum with

an alternative assessment

Question 2

2 Please comment on what should be included in the plan and timeline for

improvement

Try inclusion real inclusion Kids with complex needs CAN LEARN They need to be provided the resources Ieprsquos need to be looked at for the students who already are not being educated look at the student when you see the amount of time a non verbal multi impaired child is getting for speech services who is attending a

segregated school Every kid in there needs these servuces Lumping the kids together is the worst thing you could do for them This system is a giant failure and nobody cares about the 1

12192017 112 PM

The plan should include monitoring the number of students that are educated using

the alternate content standards not at the assessment point

12182017 1241 PM

I think the timeline should be extended indefinitely Students should not have to

take assessments that will frustrate them unnecessarily No valuable information will be gained from students who are overwhelmed This is why we have IEPs

12172017 1212 AM

Nothing a 1 Cap rule is forcing IEPTeams to make decisions they otherwise would not have made for a student regarding participation in the regular or

alternate assessments Why should there be issued plans of improvement and timelines forced on school districts or programs who are following IDEAMARSE

rules and regulations in an attempt to do whats right for their student MDE should not be mandating additional participation rate requirements and creating more red-

tape and work for districts and staff who are already overly regulated This is part of the reason good people leave education and we are faced with educator shortages

12142017 813 AM

Maybe we should take a closer look at the existing data in comparison to other

classroom or standards based assessment to determine how these data points correlate and how we are using this data

12132017 316 PM

If support is in place for each child they will succeed We cant say what that will be

12132017 258 PM

An honest look at the value of standardized assessment

12132017 225 PM

There should be more time spent on looking at the offerring of programs and support for special education students In addition public schools need more to

support in the general education setting to be proactive to students at a younger age The funding for special education needs to be looked at across the state

12132017 130 PM

Only assess students participating in FI Mi-Access or only include participation rates for students administered FI MiAccess

12132017 1052 AM

According to MI School Data 125 of our total student population is CI This

information should be factored into the plan for improvement How does the rate of students with CI SXI or other eligibility categories compare to this 1 target

12132017 1014 AM

What should be included in the plan is the purpose of the data we are trying to gain from the assessments given There are students that will not perform well on the

assessment or students that will not be able to engage in the assessment due to lack of skills to do so If they are not allowed to access an alternate assessment

than the State will not be able to gain a true picture of where those students are

functioning The information gained from these assessments should be useful in helping students and teachers target areas of improvement through instruction

12122017 1256 PM

Data to the districts on participation rates at all three levels of our alternate

assessment so we can identify at a district and ISD level where the issues are Professional development on assessment selection guidelines It may be helpful to include performance levels on standardized assessments (ex Cognitive scores) that

would be indicative of a possible need to consider alternate assessments Comparison of overall participation rates as well as participation in alternate

assessments If not already available it would be helpful to consider a nationwide study of this data

12122017 1141 AM

Possibly an incremental change from the current 24 to 20 to 15

1292017 908 AM

While local districts need to carefully consider the decisions for students taking functional independence I believe the decision chart and intentional review of students taking alternate assessments by district will help to identify areas of

improvement

1282017 223 PM

Start with what we know the percentages of students with significant cognitive impairment Address those students who take FI specifically to discern if we are

testing to many

1282017 1240 PM

I am not sure how you can plan for students that are not cognitively able to test the regular test Many of the district schools in our county have diminishing numbers in

their student population The 1 is not realistic

1242017 1249 PM

24 seems reasonable why would we force a student to take a test that is beyond their cognitive function

1242017 1111 AM

Again the request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform

on a standardized assessment If however the student shows growth over time the IEP team should consider general assessments as well

1242017 836 AM

MDE can create an online PD but why do we need to improve if it is a team decision to take an alternate assessment Data drives this decision

1232017 847 PM

If when has your district provided training to staff and those involved in the IEP process on the guidelines for choosing the appropriate assessment for the student

training on alternate content standards training on MI-Access How many students do you serve that cross district lines county lines (School of Choice) These

districts should not be penalized for providing service to students who choose them and therefore increase special education numbers What is your percent for each

subcategory (FI SI P) Do any of these students have access to the general education curriculum content standards for the content area in which they are taking a MI-Access assessment

1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

Putting all children in rigorous programming from birth basically taking them from

the impoverished homes and parenting which robs them of the necessary tools to meet these rigorous demands Oh and eliminate birth defects while you are at it and neurological damage I guess maybe all of this by next year

1212017 1154 AM

There should be a waiver for students who are on alternate curriculum andor in

programs for students with significant disabilities

11212017 139 PM

Students who require functional life skills curricula should not be administered

MSTEP or MME Instead they should be provided an assessment (ie MiAccess) that respects their dignity and their ability to show growth in areas they have

received targeted instruction

11212017 1228 PM

To ensure there are consistent practices across the state clear definitions should be

reported to assist with determining the appropriateness of an alternate assessment

11202017 1058 AM

Special Education teachers know the students that they are working with We have already read through the IEP and have determined educational plans for each child

on our caseload If we received a transfer student with an IEP of concern we have already held an IEP and contacted former teachers regarding our concerns about goals andor MET scores and have decided as an IEP Team appropriate teaching

goals along with appropriate assessments and testing needs for these students

Several of my transfer students had MI Alternative Testing (MI Access on their IEPs) which I immediately questioned and amended to read MStep since they are

participating in the general education content standards and come to the Resource Room for intense small group instruction in reading or math The plan should be for

Special Education teachers to submit the names of students on their current caseload the name of the test that is on the students IEP and give rationale or justification for each test that has been selected These names along with the test

rationale should be sent to the Special Education Director and then submitted to the state within the next two weeks due to the shortened week next week because of

Thanksgiving break Timeline for improvement should be to make an amendment to the students IEP within that time if changes need to be made

11182017 723 AM

Educate schoolsteachercounselors let IEP teams know what is available

11172017 1119 AM

I am not sure how we improve the fact that we service students with moderate to severe cognitive impairments If I were a parent of one of these students this statement would be insulting The decision to utilize an alternative assessment is an

IEP team decision of which the parent is a part

11172017 754 AM

PLEASE look at how many kids we have in the state who have significant cognitive impairments That should give MDE an idea of the need Training in determining the

right assessments should be offered as well This could start in spring - in getting a plan Summer for the work (with educators from around the state) Roll out spring of 2019 with training in late spring and summer

11162017 345 PM

I think that if we continue to have open dialog with the IEP team then we are doing

what is best for the student The disability doesnt drive programming so as a team we need to make sure it doesnt drive testing either

11162017 310 PM

The flow chart--Should My Student Take the Alternate Assessment--s a good tool for teams to use in making decisions PD--possibly a short online video one year

timeline

11162017 249 PM

A decision tree on what assessment should be used for each student that can be used across the state

11162017 134 PM

There should be a waiver for districts specifically those districts who operate regional or center-based programs These programs often provided services and

assess students that are significantly impacted by their disability Operating these programs where other districts send their students will effectincrease the percentage of the operating districts rates

11162017 130 PM

The plan should include a realistic percentage of students taking the test

11162017 112 PM

Question 3

3 Other comments

Showing 25 responses

This is against the ADA segregating our kids

12192017 112 PM

My district was at a 11 alternate assessment participation rate last year Dont force our IEPTeams to have to pick the 1 student wholl have to take the regular

assessment if the IEPTeam has already determined that 1 student is appropriate to take the alternate assessment Special education CI and SXI Programs are also

going to be punished when it comes to alternate assessment participation rates at 100 versus the 1 Cap I dont believe a cookie-cutter 1 can realistically take into account every school district or programs population or spectrum of students

with disabilities These assessment decisions should be left to the determination of the students IEPTeam - who knows the students level of functioning and

assessment needs I would much rather see students who score meets or exceeds expectations on MI-ACCESS be required to then take the M-STEP the following year If the student scores not-proficient on the M-STEP then MI-ACCESS could

be reconsidered the following year again for that student

12142017 813 AM

I am left wondering the purpose for this type of assessment How does it aid instruction benefit the student or improve our educational system Are we simply attempting to meet some compliance standard or is this data being used in a

manner that improves outcomes for kids

12132017 316 PM

Please consider that every are has their own needs

12132017 258 PM

Other concern is the way teachers are viewed by the state and the universitys are currently losing students because teachers are not supported in the school system

12132017 130 PM

How does the participation break down for the various levels of the alternate assessment FI SI and P FI is probably where we are going to have the most

flexibility in considering whether students should be taking the general assessment I encourage the department to seek this data when moving forward with the Waiver

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
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                  11. F2FParents Off
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                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

additional 2 of students) that would most likely be appropriate for an alternate assessment The eligibility of ASD would also have some students that function as if they have a severe cognitive impairment that may be appropriate for alternate assessments The third which I couldnt find easy access to the data is percentage of students participating in the various levels of our alternate assessments I do believe there are students taking the Functional Independence assessment that would be appropriate for the general assessment However I do not believe in my experience that we have students taking Supported Independence or Participation that would be appropriate for the General Assessment I think it would be valuable to look at the percentage participating in each level of our alternate assessment so we know if we need to be focusing our efforts on the FI level or if there would be a need to even look at SI or P in order to get us to the 1 level 12122017 1141 AM

This seems to be consistent with many LEAs around the state and does not seem excessive 1292017 908 AM

According to a review of our county data regarding participation in the alternate assessment we are almost to 1 just counting the number of students taking Supported Independence and Participation I would be curious about the other counties throughout state as it relates to the alternate assessment participation rates in the areas of Supported Independence and Participation Assessments Students attending programs for moderately cognitively impaired and programs for severe cognitive impairment account for 68 of the population of students with IEPs and 229 of these students are enrolled in grades 3-8 and 11 1282017 223 PM

In looking at data the SXI population alone last year was at 17 so to think that Michigan will ever be under 1 is a challenge Because Autism is such a broad spectrum it is a challenge to be at 1 if you also add in severely cognitively impaired students My point being does the state know the actual percentage of significantly impaired students in the state 1282017 1240 PM

Michigan has a higher rate of assessment participation because we assess more students than other states do 1262017 1044 AM

I feel that limiting the cap to 1 is an can be detrimental to those students who are not cognitively at the level needed to test other than with an alternate assessment A waiver is needed to go beyond 1 1242017 1249 PM

According to the American Community Survey the percentages of people with

disabilities have remained relatively unchanged since 2008 Total percentage of

people with a cognitive impairment is 48 which includes over age 65 24 taking an alternative assessment seems aligned with the data and reasonable 1242017 1111 AM

The request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform on a standardized assessment 1242017 836 AM

It is an IEP team decision for each student to take an alternative assessment It seems that if we have to stay below the 1 it is forcing IEP teams to not look at the individual students need based on data 1232017 847 PM

If these students are in fact receiving Alternate Content Standards and are accurately placed in a program that challenges their abilities then the percentages given are justified 1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt 1212017 1156 AM

Even this seems very low to me There are hundreds of children taking tests that are way beyond their ability to comprehend them I really wish I understood what we are trying to prove 1212017 1154 AM

School districts who operate regional programs for students with cognitive impairments are at a disadvantage with this cap We espouse the virtue of the IEP team making the assessment decision yet we punish districts for going over the arbitrary standard Another disadvantage is we are no longer sending scores back to home districts 11212017 139 PM

As MMC is a college preparatory curriculum and the assortment of MSTEP assessments are intended to measure this curriculum requiring all but 1 of students to demonstrate understanding of that content is inappropriate Additionally consideration of a normally distributed bell curve would suggest 2 of the population falls in the CI range Beyond that parts or all of MSTEP andor MME could be inappropriate for students with severe learning disabilities In light of these normal distributions and the nature of the MMC and its assessments Michigan assessing just over 2 with alternative measure suggests reasonable if not slightly rigid practice Put another way a valid argument MI is testing too many students with MSTEP and MME could be made 11212017 1228 PM

The decision to assess a student with an alternate assessment like MI-Access is ultimately an IEP team decision My concern with the reported percentages relates to each districts interpretation of the appropriateness for a child to be assessed using alternative tools Do we have consistency from district to district with the definition of severe cognitive impairment 11202017 1058 AM

We decide at a METIEP meeting which students have significant cognitive impairments (data cognitive scores) and which test they are able to take Our building has an high number of students who qualify to take the MIAccess because they have a cognitive impairment and they are functioning as if the they have a cognitive impairment Currently our districts participation in the MIAccess is 23 due to these students taking the test The students are in a Basic Classroom which has been labeled a High Needs Resource Room These students are not spread out into other buildings The non-participating students in the other buildings are never severe enough that there is no question that they are not counted for testing the students in the Communication Room are so low they are unable to speak The concern in our district is that these students in our building raise our percentage of participation in the MI Access testing although it is appropriate for the student The shift of concern now seems to be What is the percentage of student participation rather than What is appropriate for the whole child 11182017 723 AM

Very low numbers for high IEP numbers 11172017 1119 AM

This percentage seems to be accurate and although it exceeds the 1 cap we provide educational services to significantly impaired students across the state for whom the Mi Access assessment is the best choice for assessing these students academic knowledge 11172017 754 AM

I work in a district with a high number of students with disabilities A number of those students have or function as having a cognitive deficit Currently my district has 349 of students with IEPs taking alternate assessments As I understand the 1 cap administering Mi-Access to only those students with significant ASD impairments my district will be penalized (in some manner) if we administer the test to students with cognitive impairments 11162017 418 PM

Please look carefully at the makeup of each district and what programs are housed there I run an ISD center-based program for the county ALL of my students have significant disabilities ALL are on Mi-Access Other districts run things differently Michigan might really have that many students who require alternative assessments A deep dive is needed to investigate how alternative assessments are determined in each district 11162017 345 PM

As a special education director we have students who are in a Moderate Cognitively Impaired program and have been exposed to a modified curriculum throughout their educational career It is not in the best interest of them to expect them to participate in the MStep even if they arent considered Significant to many The MStep causes a tremendous amount of stress to students who arent in special education Our job as educators is to look at what is best for the students on an individual level not to make sure we meet a certain percentage Requiring the state to be at 1 or under isnt in the best interest of our students 11162017 310 PM

Based on MiSchool Data 2016-2017 the state of Michigan had 3500 students with a Severe Multiple Impairments (17) eligibility While this data is not reflective of the students in grades 3-8 amp 11 it does provide us with a piece of information Additionally this data does not include other students who function as if they have a significant cognitive impairment IDEA to my knowledge does not limit the number of students who may partake in an alternate assessment it is an IEP team decision I am not making excuses just stating facts Please understand we can always improve 11162017 249 PM

I would like to know the percentage of students that have an IEP that categorizes them as cognitively impaired etc 11162017 134 PM

The current Michigan rate reflects IEP team decisions regarding the appropriateness of participation for any one student IEP teams (parents included) know these students better than any legislator The overall understanding needs to exist that 24 or even 3 of all students does show that the vast majority of students who receive special education services are taking the general education assessment IEP teams have been selective with their decisions with regard to who will participate in the alternative assessment Legislators and the guidelines that are written need to have some level of flexibility for the IEP process 11162017 130 PM

22 of the population has an IQ below 70 Students with cognitive impairments are

working at the best of their ability and that includes an alternative curriculum with

an alternative assessment

Question 2

2 Please comment on what should be included in the plan and timeline for

improvement

Try inclusion real inclusion Kids with complex needs CAN LEARN They need to be provided the resources Ieprsquos need to be looked at for the students who already are not being educated look at the student when you see the amount of time a non verbal multi impaired child is getting for speech services who is attending a

segregated school Every kid in there needs these servuces Lumping the kids together is the worst thing you could do for them This system is a giant failure and nobody cares about the 1

12192017 112 PM

The plan should include monitoring the number of students that are educated using

the alternate content standards not at the assessment point

12182017 1241 PM

I think the timeline should be extended indefinitely Students should not have to

take assessments that will frustrate them unnecessarily No valuable information will be gained from students who are overwhelmed This is why we have IEPs

12172017 1212 AM

Nothing a 1 Cap rule is forcing IEPTeams to make decisions they otherwise would not have made for a student regarding participation in the regular or

alternate assessments Why should there be issued plans of improvement and timelines forced on school districts or programs who are following IDEAMARSE

rules and regulations in an attempt to do whats right for their student MDE should not be mandating additional participation rate requirements and creating more red-

tape and work for districts and staff who are already overly regulated This is part of the reason good people leave education and we are faced with educator shortages

12142017 813 AM

Maybe we should take a closer look at the existing data in comparison to other

classroom or standards based assessment to determine how these data points correlate and how we are using this data

12132017 316 PM

If support is in place for each child they will succeed We cant say what that will be

12132017 258 PM

An honest look at the value of standardized assessment

12132017 225 PM

There should be more time spent on looking at the offerring of programs and support for special education students In addition public schools need more to

support in the general education setting to be proactive to students at a younger age The funding for special education needs to be looked at across the state

12132017 130 PM

Only assess students participating in FI Mi-Access or only include participation rates for students administered FI MiAccess

12132017 1052 AM

According to MI School Data 125 of our total student population is CI This

information should be factored into the plan for improvement How does the rate of students with CI SXI or other eligibility categories compare to this 1 target

12132017 1014 AM

What should be included in the plan is the purpose of the data we are trying to gain from the assessments given There are students that will not perform well on the

assessment or students that will not be able to engage in the assessment due to lack of skills to do so If they are not allowed to access an alternate assessment

than the State will not be able to gain a true picture of where those students are

functioning The information gained from these assessments should be useful in helping students and teachers target areas of improvement through instruction

12122017 1256 PM

Data to the districts on participation rates at all three levels of our alternate

assessment so we can identify at a district and ISD level where the issues are Professional development on assessment selection guidelines It may be helpful to include performance levels on standardized assessments (ex Cognitive scores) that

would be indicative of a possible need to consider alternate assessments Comparison of overall participation rates as well as participation in alternate

assessments If not already available it would be helpful to consider a nationwide study of this data

12122017 1141 AM

Possibly an incremental change from the current 24 to 20 to 15

1292017 908 AM

While local districts need to carefully consider the decisions for students taking functional independence I believe the decision chart and intentional review of students taking alternate assessments by district will help to identify areas of

improvement

1282017 223 PM

Start with what we know the percentages of students with significant cognitive impairment Address those students who take FI specifically to discern if we are

testing to many

1282017 1240 PM

I am not sure how you can plan for students that are not cognitively able to test the regular test Many of the district schools in our county have diminishing numbers in

their student population The 1 is not realistic

1242017 1249 PM

24 seems reasonable why would we force a student to take a test that is beyond their cognitive function

1242017 1111 AM

Again the request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform

on a standardized assessment If however the student shows growth over time the IEP team should consider general assessments as well

1242017 836 AM

MDE can create an online PD but why do we need to improve if it is a team decision to take an alternate assessment Data drives this decision

1232017 847 PM

If when has your district provided training to staff and those involved in the IEP process on the guidelines for choosing the appropriate assessment for the student

training on alternate content standards training on MI-Access How many students do you serve that cross district lines county lines (School of Choice) These

districts should not be penalized for providing service to students who choose them and therefore increase special education numbers What is your percent for each

subcategory (FI SI P) Do any of these students have access to the general education curriculum content standards for the content area in which they are taking a MI-Access assessment

1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

Putting all children in rigorous programming from birth basically taking them from

the impoverished homes and parenting which robs them of the necessary tools to meet these rigorous demands Oh and eliminate birth defects while you are at it and neurological damage I guess maybe all of this by next year

1212017 1154 AM

There should be a waiver for students who are on alternate curriculum andor in

programs for students with significant disabilities

11212017 139 PM

Students who require functional life skills curricula should not be administered

MSTEP or MME Instead they should be provided an assessment (ie MiAccess) that respects their dignity and their ability to show growth in areas they have

received targeted instruction

11212017 1228 PM

To ensure there are consistent practices across the state clear definitions should be

reported to assist with determining the appropriateness of an alternate assessment

11202017 1058 AM

Special Education teachers know the students that they are working with We have already read through the IEP and have determined educational plans for each child

on our caseload If we received a transfer student with an IEP of concern we have already held an IEP and contacted former teachers regarding our concerns about goals andor MET scores and have decided as an IEP Team appropriate teaching

goals along with appropriate assessments and testing needs for these students

Several of my transfer students had MI Alternative Testing (MI Access on their IEPs) which I immediately questioned and amended to read MStep since they are

participating in the general education content standards and come to the Resource Room for intense small group instruction in reading or math The plan should be for

Special Education teachers to submit the names of students on their current caseload the name of the test that is on the students IEP and give rationale or justification for each test that has been selected These names along with the test

rationale should be sent to the Special Education Director and then submitted to the state within the next two weeks due to the shortened week next week because of

Thanksgiving break Timeline for improvement should be to make an amendment to the students IEP within that time if changes need to be made

11182017 723 AM

Educate schoolsteachercounselors let IEP teams know what is available

11172017 1119 AM

I am not sure how we improve the fact that we service students with moderate to severe cognitive impairments If I were a parent of one of these students this statement would be insulting The decision to utilize an alternative assessment is an

IEP team decision of which the parent is a part

11172017 754 AM

PLEASE look at how many kids we have in the state who have significant cognitive impairments That should give MDE an idea of the need Training in determining the

right assessments should be offered as well This could start in spring - in getting a plan Summer for the work (with educators from around the state) Roll out spring of 2019 with training in late spring and summer

11162017 345 PM

I think that if we continue to have open dialog with the IEP team then we are doing

what is best for the student The disability doesnt drive programming so as a team we need to make sure it doesnt drive testing either

11162017 310 PM

The flow chart--Should My Student Take the Alternate Assessment--s a good tool for teams to use in making decisions PD--possibly a short online video one year

timeline

11162017 249 PM

A decision tree on what assessment should be used for each student that can be used across the state

11162017 134 PM

There should be a waiver for districts specifically those districts who operate regional or center-based programs These programs often provided services and

assess students that are significantly impacted by their disability Operating these programs where other districts send their students will effectincrease the percentage of the operating districts rates

11162017 130 PM

The plan should include a realistic percentage of students taking the test

11162017 112 PM

Question 3

3 Other comments

Showing 25 responses

This is against the ADA segregating our kids

12192017 112 PM

My district was at a 11 alternate assessment participation rate last year Dont force our IEPTeams to have to pick the 1 student wholl have to take the regular

assessment if the IEPTeam has already determined that 1 student is appropriate to take the alternate assessment Special education CI and SXI Programs are also

going to be punished when it comes to alternate assessment participation rates at 100 versus the 1 Cap I dont believe a cookie-cutter 1 can realistically take into account every school district or programs population or spectrum of students

with disabilities These assessment decisions should be left to the determination of the students IEPTeam - who knows the students level of functioning and

assessment needs I would much rather see students who score meets or exceeds expectations on MI-ACCESS be required to then take the M-STEP the following year If the student scores not-proficient on the M-STEP then MI-ACCESS could

be reconsidered the following year again for that student

12142017 813 AM

I am left wondering the purpose for this type of assessment How does it aid instruction benefit the student or improve our educational system Are we simply attempting to meet some compliance standard or is this data being used in a

manner that improves outcomes for kids

12132017 316 PM

Please consider that every are has their own needs

12132017 258 PM

Other concern is the way teachers are viewed by the state and the universitys are currently losing students because teachers are not supported in the school system

12132017 130 PM

How does the participation break down for the various levels of the alternate assessment FI SI and P FI is probably where we are going to have the most

flexibility in considering whether students should be taking the general assessment I encourage the department to seek this data when moving forward with the Waiver

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 ITA (Utilizzare 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL 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PTB 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 SLV 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 SUO 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 SVE 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                  1. Date
                  2. LEA
                  3. LEAPhone
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                  40. ResourceTA

people with a cognitive impairment is 48 which includes over age 65 24 taking an alternative assessment seems aligned with the data and reasonable 1242017 1111 AM

The request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform on a standardized assessment 1242017 836 AM

It is an IEP team decision for each student to take an alternative assessment It seems that if we have to stay below the 1 it is forcing IEP teams to not look at the individual students need based on data 1232017 847 PM

If these students are in fact receiving Alternate Content Standards and are accurately placed in a program that challenges their abilities then the percentages given are justified 1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt 1212017 1156 AM

Even this seems very low to me There are hundreds of children taking tests that are way beyond their ability to comprehend them I really wish I understood what we are trying to prove 1212017 1154 AM

School districts who operate regional programs for students with cognitive impairments are at a disadvantage with this cap We espouse the virtue of the IEP team making the assessment decision yet we punish districts for going over the arbitrary standard Another disadvantage is we are no longer sending scores back to home districts 11212017 139 PM

As MMC is a college preparatory curriculum and the assortment of MSTEP assessments are intended to measure this curriculum requiring all but 1 of students to demonstrate understanding of that content is inappropriate Additionally consideration of a normally distributed bell curve would suggest 2 of the population falls in the CI range Beyond that parts or all of MSTEP andor MME could be inappropriate for students with severe learning disabilities In light of these normal distributions and the nature of the MMC and its assessments Michigan assessing just over 2 with alternative measure suggests reasonable if not slightly rigid practice Put another way a valid argument MI is testing too many students with MSTEP and MME could be made 11212017 1228 PM

The decision to assess a student with an alternate assessment like MI-Access is ultimately an IEP team decision My concern with the reported percentages relates to each districts interpretation of the appropriateness for a child to be assessed using alternative tools Do we have consistency from district to district with the definition of severe cognitive impairment 11202017 1058 AM

We decide at a METIEP meeting which students have significant cognitive impairments (data cognitive scores) and which test they are able to take Our building has an high number of students who qualify to take the MIAccess because they have a cognitive impairment and they are functioning as if the they have a cognitive impairment Currently our districts participation in the MIAccess is 23 due to these students taking the test The students are in a Basic Classroom which has been labeled a High Needs Resource Room These students are not spread out into other buildings The non-participating students in the other buildings are never severe enough that there is no question that they are not counted for testing the students in the Communication Room are so low they are unable to speak The concern in our district is that these students in our building raise our percentage of participation in the MI Access testing although it is appropriate for the student The shift of concern now seems to be What is the percentage of student participation rather than What is appropriate for the whole child 11182017 723 AM

Very low numbers for high IEP numbers 11172017 1119 AM

This percentage seems to be accurate and although it exceeds the 1 cap we provide educational services to significantly impaired students across the state for whom the Mi Access assessment is the best choice for assessing these students academic knowledge 11172017 754 AM

I work in a district with a high number of students with disabilities A number of those students have or function as having a cognitive deficit Currently my district has 349 of students with IEPs taking alternate assessments As I understand the 1 cap administering Mi-Access to only those students with significant ASD impairments my district will be penalized (in some manner) if we administer the test to students with cognitive impairments 11162017 418 PM

Please look carefully at the makeup of each district and what programs are housed there I run an ISD center-based program for the county ALL of my students have significant disabilities ALL are on Mi-Access Other districts run things differently Michigan might really have that many students who require alternative assessments A deep dive is needed to investigate how alternative assessments are determined in each district 11162017 345 PM

As a special education director we have students who are in a Moderate Cognitively Impaired program and have been exposed to a modified curriculum throughout their educational career It is not in the best interest of them to expect them to participate in the MStep even if they arent considered Significant to many The MStep causes a tremendous amount of stress to students who arent in special education Our job as educators is to look at what is best for the students on an individual level not to make sure we meet a certain percentage Requiring the state to be at 1 or under isnt in the best interest of our students 11162017 310 PM

Based on MiSchool Data 2016-2017 the state of Michigan had 3500 students with a Severe Multiple Impairments (17) eligibility While this data is not reflective of the students in grades 3-8 amp 11 it does provide us with a piece of information Additionally this data does not include other students who function as if they have a significant cognitive impairment IDEA to my knowledge does not limit the number of students who may partake in an alternate assessment it is an IEP team decision I am not making excuses just stating facts Please understand we can always improve 11162017 249 PM

I would like to know the percentage of students that have an IEP that categorizes them as cognitively impaired etc 11162017 134 PM

The current Michigan rate reflects IEP team decisions regarding the appropriateness of participation for any one student IEP teams (parents included) know these students better than any legislator The overall understanding needs to exist that 24 or even 3 of all students does show that the vast majority of students who receive special education services are taking the general education assessment IEP teams have been selective with their decisions with regard to who will participate in the alternative assessment Legislators and the guidelines that are written need to have some level of flexibility for the IEP process 11162017 130 PM

22 of the population has an IQ below 70 Students with cognitive impairments are

working at the best of their ability and that includes an alternative curriculum with

an alternative assessment

Question 2

2 Please comment on what should be included in the plan and timeline for

improvement

Try inclusion real inclusion Kids with complex needs CAN LEARN They need to be provided the resources Ieprsquos need to be looked at for the students who already are not being educated look at the student when you see the amount of time a non verbal multi impaired child is getting for speech services who is attending a

segregated school Every kid in there needs these servuces Lumping the kids together is the worst thing you could do for them This system is a giant failure and nobody cares about the 1

12192017 112 PM

The plan should include monitoring the number of students that are educated using

the alternate content standards not at the assessment point

12182017 1241 PM

I think the timeline should be extended indefinitely Students should not have to

take assessments that will frustrate them unnecessarily No valuable information will be gained from students who are overwhelmed This is why we have IEPs

12172017 1212 AM

Nothing a 1 Cap rule is forcing IEPTeams to make decisions they otherwise would not have made for a student regarding participation in the regular or

alternate assessments Why should there be issued plans of improvement and timelines forced on school districts or programs who are following IDEAMARSE

rules and regulations in an attempt to do whats right for their student MDE should not be mandating additional participation rate requirements and creating more red-

tape and work for districts and staff who are already overly regulated This is part of the reason good people leave education and we are faced with educator shortages

12142017 813 AM

Maybe we should take a closer look at the existing data in comparison to other

classroom or standards based assessment to determine how these data points correlate and how we are using this data

12132017 316 PM

If support is in place for each child they will succeed We cant say what that will be

12132017 258 PM

An honest look at the value of standardized assessment

12132017 225 PM

There should be more time spent on looking at the offerring of programs and support for special education students In addition public schools need more to

support in the general education setting to be proactive to students at a younger age The funding for special education needs to be looked at across the state

12132017 130 PM

Only assess students participating in FI Mi-Access or only include participation rates for students administered FI MiAccess

12132017 1052 AM

According to MI School Data 125 of our total student population is CI This

information should be factored into the plan for improvement How does the rate of students with CI SXI or other eligibility categories compare to this 1 target

12132017 1014 AM

What should be included in the plan is the purpose of the data we are trying to gain from the assessments given There are students that will not perform well on the

assessment or students that will not be able to engage in the assessment due to lack of skills to do so If they are not allowed to access an alternate assessment

than the State will not be able to gain a true picture of where those students are

functioning The information gained from these assessments should be useful in helping students and teachers target areas of improvement through instruction

12122017 1256 PM

Data to the districts on participation rates at all three levels of our alternate

assessment so we can identify at a district and ISD level where the issues are Professional development on assessment selection guidelines It may be helpful to include performance levels on standardized assessments (ex Cognitive scores) that

would be indicative of a possible need to consider alternate assessments Comparison of overall participation rates as well as participation in alternate

assessments If not already available it would be helpful to consider a nationwide study of this data

12122017 1141 AM

Possibly an incremental change from the current 24 to 20 to 15

1292017 908 AM

While local districts need to carefully consider the decisions for students taking functional independence I believe the decision chart and intentional review of students taking alternate assessments by district will help to identify areas of

improvement

1282017 223 PM

Start with what we know the percentages of students with significant cognitive impairment Address those students who take FI specifically to discern if we are

testing to many

1282017 1240 PM

I am not sure how you can plan for students that are not cognitively able to test the regular test Many of the district schools in our county have diminishing numbers in

their student population The 1 is not realistic

1242017 1249 PM

24 seems reasonable why would we force a student to take a test that is beyond their cognitive function

1242017 1111 AM

Again the request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform

on a standardized assessment If however the student shows growth over time the IEP team should consider general assessments as well

1242017 836 AM

MDE can create an online PD but why do we need to improve if it is a team decision to take an alternate assessment Data drives this decision

1232017 847 PM

If when has your district provided training to staff and those involved in the IEP process on the guidelines for choosing the appropriate assessment for the student

training on alternate content standards training on MI-Access How many students do you serve that cross district lines county lines (School of Choice) These

districts should not be penalized for providing service to students who choose them and therefore increase special education numbers What is your percent for each

subcategory (FI SI P) Do any of these students have access to the general education curriculum content standards for the content area in which they are taking a MI-Access assessment

1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

Putting all children in rigorous programming from birth basically taking them from

the impoverished homes and parenting which robs them of the necessary tools to meet these rigorous demands Oh and eliminate birth defects while you are at it and neurological damage I guess maybe all of this by next year

1212017 1154 AM

There should be a waiver for students who are on alternate curriculum andor in

programs for students with significant disabilities

11212017 139 PM

Students who require functional life skills curricula should not be administered

MSTEP or MME Instead they should be provided an assessment (ie MiAccess) that respects their dignity and their ability to show growth in areas they have

received targeted instruction

11212017 1228 PM

To ensure there are consistent practices across the state clear definitions should be

reported to assist with determining the appropriateness of an alternate assessment

11202017 1058 AM

Special Education teachers know the students that they are working with We have already read through the IEP and have determined educational plans for each child

on our caseload If we received a transfer student with an IEP of concern we have already held an IEP and contacted former teachers regarding our concerns about goals andor MET scores and have decided as an IEP Team appropriate teaching

goals along with appropriate assessments and testing needs for these students

Several of my transfer students had MI Alternative Testing (MI Access on their IEPs) which I immediately questioned and amended to read MStep since they are

participating in the general education content standards and come to the Resource Room for intense small group instruction in reading or math The plan should be for

Special Education teachers to submit the names of students on their current caseload the name of the test that is on the students IEP and give rationale or justification for each test that has been selected These names along with the test

rationale should be sent to the Special Education Director and then submitted to the state within the next two weeks due to the shortened week next week because of

Thanksgiving break Timeline for improvement should be to make an amendment to the students IEP within that time if changes need to be made

11182017 723 AM

Educate schoolsteachercounselors let IEP teams know what is available

11172017 1119 AM

I am not sure how we improve the fact that we service students with moderate to severe cognitive impairments If I were a parent of one of these students this statement would be insulting The decision to utilize an alternative assessment is an

IEP team decision of which the parent is a part

11172017 754 AM

PLEASE look at how many kids we have in the state who have significant cognitive impairments That should give MDE an idea of the need Training in determining the

right assessments should be offered as well This could start in spring - in getting a plan Summer for the work (with educators from around the state) Roll out spring of 2019 with training in late spring and summer

11162017 345 PM

I think that if we continue to have open dialog with the IEP team then we are doing

what is best for the student The disability doesnt drive programming so as a team we need to make sure it doesnt drive testing either

11162017 310 PM

The flow chart--Should My Student Take the Alternate Assessment--s a good tool for teams to use in making decisions PD--possibly a short online video one year

timeline

11162017 249 PM

A decision tree on what assessment should be used for each student that can be used across the state

11162017 134 PM

There should be a waiver for districts specifically those districts who operate regional or center-based programs These programs often provided services and

assess students that are significantly impacted by their disability Operating these programs where other districts send their students will effectincrease the percentage of the operating districts rates

11162017 130 PM

The plan should include a realistic percentage of students taking the test

11162017 112 PM

Question 3

3 Other comments

Showing 25 responses

This is against the ADA segregating our kids

12192017 112 PM

My district was at a 11 alternate assessment participation rate last year Dont force our IEPTeams to have to pick the 1 student wholl have to take the regular

assessment if the IEPTeam has already determined that 1 student is appropriate to take the alternate assessment Special education CI and SXI Programs are also

going to be punished when it comes to alternate assessment participation rates at 100 versus the 1 Cap I dont believe a cookie-cutter 1 can realistically take into account every school district or programs population or spectrum of students

with disabilities These assessment decisions should be left to the determination of the students IEPTeam - who knows the students level of functioning and

assessment needs I would much rather see students who score meets or exceeds expectations on MI-ACCESS be required to then take the M-STEP the following year If the student scores not-proficient on the M-STEP then MI-ACCESS could

be reconsidered the following year again for that student

12142017 813 AM

I am left wondering the purpose for this type of assessment How does it aid instruction benefit the student or improve our educational system Are we simply attempting to meet some compliance standard or is this data being used in a

manner that improves outcomes for kids

12132017 316 PM

Please consider that every are has their own needs

12132017 258 PM

Other concern is the way teachers are viewed by the state and the universitys are currently losing students because teachers are not supported in the school system

12132017 130 PM

How does the participation break down for the various levels of the alternate assessment FI SI and P FI is probably where we are going to have the most

flexibility in considering whether students should be taking the general assessment I encourage the department to seek this data when moving forward with the Waiver

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 ESP 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 FRA ltFEFF005500740069006c006900730065007a00200063006500730020006f007000740069006f006e00730020006100660069006e00200064006500200063007200e900650072002000640065007300200064006f00630075006d0065006e00740073002000410064006f006200650020005000440046002000700072006f00660065007300730069006f006e006e0065006c007300200066006900610062006c0065007300200070006f007500720020006c0061002000760069007300750061006c00690073006100740069006f006e0020006500740020006c00270069006d007000720065007300730069006f006e002e0020004c0065007300200064006f00630075006d0065006e00740073002000500044004600200063007200e900e90073002000700065007500760065006e0074002000ea0074007200650020006f007500760065007200740073002000640061006e00730020004100630072006f006200610074002c002000610069006e00730069002000710075002700410064006f00620065002000520065006100640065007200200036002e0030002000650074002000760065007200730069006f006e007300200075006c007400e90072006900650075007200650073002egt13 GRE 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 HEB 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 HRV 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020be44c988b2c8c2a40020bb38c11cb97c0020c548c815c801c73cb85c0020bcf4ace00020c778c1c4d558b2940020b3700020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200036002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL 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 PTB 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                  1. Date
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The decision to assess a student with an alternate assessment like MI-Access is ultimately an IEP team decision My concern with the reported percentages relates to each districts interpretation of the appropriateness for a child to be assessed using alternative tools Do we have consistency from district to district with the definition of severe cognitive impairment 11202017 1058 AM

We decide at a METIEP meeting which students have significant cognitive impairments (data cognitive scores) and which test they are able to take Our building has an high number of students who qualify to take the MIAccess because they have a cognitive impairment and they are functioning as if the they have a cognitive impairment Currently our districts participation in the MIAccess is 23 due to these students taking the test The students are in a Basic Classroom which has been labeled a High Needs Resource Room These students are not spread out into other buildings The non-participating students in the other buildings are never severe enough that there is no question that they are not counted for testing the students in the Communication Room are so low they are unable to speak The concern in our district is that these students in our building raise our percentage of participation in the MI Access testing although it is appropriate for the student The shift of concern now seems to be What is the percentage of student participation rather than What is appropriate for the whole child 11182017 723 AM

Very low numbers for high IEP numbers 11172017 1119 AM

This percentage seems to be accurate and although it exceeds the 1 cap we provide educational services to significantly impaired students across the state for whom the Mi Access assessment is the best choice for assessing these students academic knowledge 11172017 754 AM

I work in a district with a high number of students with disabilities A number of those students have or function as having a cognitive deficit Currently my district has 349 of students with IEPs taking alternate assessments As I understand the 1 cap administering Mi-Access to only those students with significant ASD impairments my district will be penalized (in some manner) if we administer the test to students with cognitive impairments 11162017 418 PM

Please look carefully at the makeup of each district and what programs are housed there I run an ISD center-based program for the county ALL of my students have significant disabilities ALL are on Mi-Access Other districts run things differently Michigan might really have that many students who require alternative assessments A deep dive is needed to investigate how alternative assessments are determined in each district 11162017 345 PM

As a special education director we have students who are in a Moderate Cognitively Impaired program and have been exposed to a modified curriculum throughout their educational career It is not in the best interest of them to expect them to participate in the MStep even if they arent considered Significant to many The MStep causes a tremendous amount of stress to students who arent in special education Our job as educators is to look at what is best for the students on an individual level not to make sure we meet a certain percentage Requiring the state to be at 1 or under isnt in the best interest of our students 11162017 310 PM

Based on MiSchool Data 2016-2017 the state of Michigan had 3500 students with a Severe Multiple Impairments (17) eligibility While this data is not reflective of the students in grades 3-8 amp 11 it does provide us with a piece of information Additionally this data does not include other students who function as if they have a significant cognitive impairment IDEA to my knowledge does not limit the number of students who may partake in an alternate assessment it is an IEP team decision I am not making excuses just stating facts Please understand we can always improve 11162017 249 PM

I would like to know the percentage of students that have an IEP that categorizes them as cognitively impaired etc 11162017 134 PM

The current Michigan rate reflects IEP team decisions regarding the appropriateness of participation for any one student IEP teams (parents included) know these students better than any legislator The overall understanding needs to exist that 24 or even 3 of all students does show that the vast majority of students who receive special education services are taking the general education assessment IEP teams have been selective with their decisions with regard to who will participate in the alternative assessment Legislators and the guidelines that are written need to have some level of flexibility for the IEP process 11162017 130 PM

22 of the population has an IQ below 70 Students with cognitive impairments are

working at the best of their ability and that includes an alternative curriculum with

an alternative assessment

Question 2

2 Please comment on what should be included in the plan and timeline for

improvement

Try inclusion real inclusion Kids with complex needs CAN LEARN They need to be provided the resources Ieprsquos need to be looked at for the students who already are not being educated look at the student when you see the amount of time a non verbal multi impaired child is getting for speech services who is attending a

segregated school Every kid in there needs these servuces Lumping the kids together is the worst thing you could do for them This system is a giant failure and nobody cares about the 1

12192017 112 PM

The plan should include monitoring the number of students that are educated using

the alternate content standards not at the assessment point

12182017 1241 PM

I think the timeline should be extended indefinitely Students should not have to

take assessments that will frustrate them unnecessarily No valuable information will be gained from students who are overwhelmed This is why we have IEPs

12172017 1212 AM

Nothing a 1 Cap rule is forcing IEPTeams to make decisions they otherwise would not have made for a student regarding participation in the regular or

alternate assessments Why should there be issued plans of improvement and timelines forced on school districts or programs who are following IDEAMARSE

rules and regulations in an attempt to do whats right for their student MDE should not be mandating additional participation rate requirements and creating more red-

tape and work for districts and staff who are already overly regulated This is part of the reason good people leave education and we are faced with educator shortages

12142017 813 AM

Maybe we should take a closer look at the existing data in comparison to other

classroom or standards based assessment to determine how these data points correlate and how we are using this data

12132017 316 PM

If support is in place for each child they will succeed We cant say what that will be

12132017 258 PM

An honest look at the value of standardized assessment

12132017 225 PM

There should be more time spent on looking at the offerring of programs and support for special education students In addition public schools need more to

support in the general education setting to be proactive to students at a younger age The funding for special education needs to be looked at across the state

12132017 130 PM

Only assess students participating in FI Mi-Access or only include participation rates for students administered FI MiAccess

12132017 1052 AM

According to MI School Data 125 of our total student population is CI This

information should be factored into the plan for improvement How does the rate of students with CI SXI or other eligibility categories compare to this 1 target

12132017 1014 AM

What should be included in the plan is the purpose of the data we are trying to gain from the assessments given There are students that will not perform well on the

assessment or students that will not be able to engage in the assessment due to lack of skills to do so If they are not allowed to access an alternate assessment

than the State will not be able to gain a true picture of where those students are

functioning The information gained from these assessments should be useful in helping students and teachers target areas of improvement through instruction

12122017 1256 PM

Data to the districts on participation rates at all three levels of our alternate

assessment so we can identify at a district and ISD level where the issues are Professional development on assessment selection guidelines It may be helpful to include performance levels on standardized assessments (ex Cognitive scores) that

would be indicative of a possible need to consider alternate assessments Comparison of overall participation rates as well as participation in alternate

assessments If not already available it would be helpful to consider a nationwide study of this data

12122017 1141 AM

Possibly an incremental change from the current 24 to 20 to 15

1292017 908 AM

While local districts need to carefully consider the decisions for students taking functional independence I believe the decision chart and intentional review of students taking alternate assessments by district will help to identify areas of

improvement

1282017 223 PM

Start with what we know the percentages of students with significant cognitive impairment Address those students who take FI specifically to discern if we are

testing to many

1282017 1240 PM

I am not sure how you can plan for students that are not cognitively able to test the regular test Many of the district schools in our county have diminishing numbers in

their student population The 1 is not realistic

1242017 1249 PM

24 seems reasonable why would we force a student to take a test that is beyond their cognitive function

1242017 1111 AM

Again the request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform

on a standardized assessment If however the student shows growth over time the IEP team should consider general assessments as well

1242017 836 AM

MDE can create an online PD but why do we need to improve if it is a team decision to take an alternate assessment Data drives this decision

1232017 847 PM

If when has your district provided training to staff and those involved in the IEP process on the guidelines for choosing the appropriate assessment for the student

training on alternate content standards training on MI-Access How many students do you serve that cross district lines county lines (School of Choice) These

districts should not be penalized for providing service to students who choose them and therefore increase special education numbers What is your percent for each

subcategory (FI SI P) Do any of these students have access to the general education curriculum content standards for the content area in which they are taking a MI-Access assessment

1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

Putting all children in rigorous programming from birth basically taking them from

the impoverished homes and parenting which robs them of the necessary tools to meet these rigorous demands Oh and eliminate birth defects while you are at it and neurological damage I guess maybe all of this by next year

1212017 1154 AM

There should be a waiver for students who are on alternate curriculum andor in

programs for students with significant disabilities

11212017 139 PM

Students who require functional life skills curricula should not be administered

MSTEP or MME Instead they should be provided an assessment (ie MiAccess) that respects their dignity and their ability to show growth in areas they have

received targeted instruction

11212017 1228 PM

To ensure there are consistent practices across the state clear definitions should be

reported to assist with determining the appropriateness of an alternate assessment

11202017 1058 AM

Special Education teachers know the students that they are working with We have already read through the IEP and have determined educational plans for each child

on our caseload If we received a transfer student with an IEP of concern we have already held an IEP and contacted former teachers regarding our concerns about goals andor MET scores and have decided as an IEP Team appropriate teaching

goals along with appropriate assessments and testing needs for these students

Several of my transfer students had MI Alternative Testing (MI Access on their IEPs) which I immediately questioned and amended to read MStep since they are

participating in the general education content standards and come to the Resource Room for intense small group instruction in reading or math The plan should be for

Special Education teachers to submit the names of students on their current caseload the name of the test that is on the students IEP and give rationale or justification for each test that has been selected These names along with the test

rationale should be sent to the Special Education Director and then submitted to the state within the next two weeks due to the shortened week next week because of

Thanksgiving break Timeline for improvement should be to make an amendment to the students IEP within that time if changes need to be made

11182017 723 AM

Educate schoolsteachercounselors let IEP teams know what is available

11172017 1119 AM

I am not sure how we improve the fact that we service students with moderate to severe cognitive impairments If I were a parent of one of these students this statement would be insulting The decision to utilize an alternative assessment is an

IEP team decision of which the parent is a part

11172017 754 AM

PLEASE look at how many kids we have in the state who have significant cognitive impairments That should give MDE an idea of the need Training in determining the

right assessments should be offered as well This could start in spring - in getting a plan Summer for the work (with educators from around the state) Roll out spring of 2019 with training in late spring and summer

11162017 345 PM

I think that if we continue to have open dialog with the IEP team then we are doing

what is best for the student The disability doesnt drive programming so as a team we need to make sure it doesnt drive testing either

11162017 310 PM

The flow chart--Should My Student Take the Alternate Assessment--s a good tool for teams to use in making decisions PD--possibly a short online video one year

timeline

11162017 249 PM

A decision tree on what assessment should be used for each student that can be used across the state

11162017 134 PM

There should be a waiver for districts specifically those districts who operate regional or center-based programs These programs often provided services and

assess students that are significantly impacted by their disability Operating these programs where other districts send their students will effectincrease the percentage of the operating districts rates

11162017 130 PM

The plan should include a realistic percentage of students taking the test

11162017 112 PM

Question 3

3 Other comments

Showing 25 responses

This is against the ADA segregating our kids

12192017 112 PM

My district was at a 11 alternate assessment participation rate last year Dont force our IEPTeams to have to pick the 1 student wholl have to take the regular

assessment if the IEPTeam has already determined that 1 student is appropriate to take the alternate assessment Special education CI and SXI Programs are also

going to be punished when it comes to alternate assessment participation rates at 100 versus the 1 Cap I dont believe a cookie-cutter 1 can realistically take into account every school district or programs population or spectrum of students

with disabilities These assessment decisions should be left to the determination of the students IEPTeam - who knows the students level of functioning and

assessment needs I would much rather see students who score meets or exceeds expectations on MI-ACCESS be required to then take the M-STEP the following year If the student scores not-proficient on the M-STEP then MI-ACCESS could

be reconsidered the following year again for that student

12142017 813 AM

I am left wondering the purpose for this type of assessment How does it aid instruction benefit the student or improve our educational system Are we simply attempting to meet some compliance standard or is this data being used in a

manner that improves outcomes for kids

12132017 316 PM

Please consider that every are has their own needs

12132017 258 PM

Other concern is the way teachers are viewed by the state and the universitys are currently losing students because teachers are not supported in the school system

12132017 130 PM

How does the participation break down for the various levels of the alternate assessment FI SI and P FI is probably where we are going to have the most

flexibility in considering whether students should be taking the general assessment I encourage the department to seek this data when moving forward with the Waiver

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
                • ltlt13 ASCII85EncodePages false13 AllowTransparency false13 AutoPositionEPSFiles true13 AutoRotatePages All13 Binding Left13 CalGrayProfile (Gray Gamma 22)13 CalRGBProfile (sRGB IEC61966-21)13 CalCMYKProfile (US Web Coated 050SWOP051 v2)13 sRGBProfile (sRGB IEC61966-21)13 CannotEmbedFontPolicy Warning13 CompatibilityLevel 1513 CompressObjects All13 CompressPages true13 ConvertImagesToIndexed true13 PassThroughJPEGImages true13 CreateJobTicket false13 DefaultRenderingIntent Default13 DetectBlends true13 DetectCurves 0100013 ColorConversionStrategy sRGB13 DoThumbnails false13 EmbedAllFonts true13 EmbedOpenType false13 ParseICCProfilesInComments true13 EmbedJobOptions false13 DSCReportingLevel 013 EmitDSCWarnings false13 EndPage -113 ImageMemory 104857613 LockDistillerParams false13 MaxSubsetPct 10013 Optimize true13 OPM 113 ParseDSCComments true13 ParseDSCCommentsForDocInfo true13 PreserveCopyPage true13 PreserveDICMYKValues true13 PreserveEPSInfo false13 PreserveFlatness true13 PreserveHalftoneInfo false13 PreserveOPIComments false13 PreserveOverprintSettings true13 StartPage 113 SubsetFonts true13 TransferFunctionInfo Apply13 UCRandBGInfo Remove13 UsePrologue false13 ColorSettingsFile ()13 AlwaysEmbed [ true13 ]13 NeverEmbed [ true13 Arial-Black13 Arial-BlackItalic13 Arial-BoldItalicMT13 Arial-BoldMT13 Arial-ItalicMT13 ArialMT13 ArialNarrow13 ArialNarrow-Bold13 ArialNarrow-BoldItalic13 ArialNarrow-Italic13 CenturyGothic13 CenturyGothic-Bold13 CenturyGothic-BoldItalic13 CenturyGothic-Italic13 CourierNewPS-BoldItalicMT13 CourierNewPS-BoldMT13 CourierNewPS-ItalicMT13 CourierNewPSMT13 Georgia13 Georgia-Bold13 Georgia-BoldItalic13 Georgia-Italic13 Impact13 LucidaConsole13 Tahoma13 Tahoma-Bold13 TimesNewRomanMT-ExtraBold13 TimesNewRomanPS-BoldItalicMT13 TimesNewRomanPS-BoldMT13 TimesNewRomanPS-ItalicMT13 TimesNewRomanPSMT13 Trebuchet-BoldItalic13 TrebuchetMS13 TrebuchetMS-Bold13 TrebuchetMS-Italic13 Verdana13 Verdana-Bold13 Verdana-BoldItalic13 Verdana-Italic13 ]13 AntiAliasColorImages false13 CropColorImages true13 ColorImageMinResolution 15013 ColorImageMinResolutionPolicy OK13 DownsampleColorImages true13 ColorImageDownsampleType Bicubic13 ColorImageResolution 15013 ColorImageDepth -113 ColorImageMinDownsampleDepth 113 ColorImageDownsampleThreshold 15000013 EncodeColorImages true13 ColorImageFilter DCTEncode13 AutoFilterColorImages true13 ColorImageAutoFilterStrategy JPEG13 ColorACSImageDict ltlt13 QFactor 07613 HSamples [2 1 1 2] VSamples [2 1 1 2]13 gtgt13 ColorImageDict ltlt13 QFactor 07613 HSamples [2 1 1 2] VSamples [2 1 1 2]13 gtgt13 JPEG2000ColorACSImageDict ltlt13 TileWidth 25613 TileHeight 25613 Quality 1513 gtgt13 JPEG2000ColorImageDict ltlt13 TileWidth 25613 TileHeight 25613 Quality 1513 gtgt13 AntiAliasGrayImages false13 CropGrayImages true13 GrayImageMinResolution 15013 GrayImageMinResolutionPolicy OK13 DownsampleGrayImages true13 GrayImageDownsampleType Bicubic13 GrayImageResolution 15013 GrayImageDepth -113 GrayImageMinDownsampleDepth 213 GrayImageDownsampleThreshold 15000013 EncodeGrayImages true13 GrayImageFilter DCTEncode13 AutoFilterGrayImages true13 GrayImageAutoFilterStrategy JPEG13 GrayACSImageDict ltlt13 QFactor 07613 HSamples [2 1 1 2] VSamples [2 1 1 2]13 gtgt13 GrayImageDict ltlt13 QFactor 07613 HSamples [2 1 1 2] VSamples [2 1 1 2]13 gtgt13 JPEG2000GrayACSImageDict ltlt13 TileWidth 25613 TileHeight 25613 Quality 1513 gtgt13 JPEG2000GrayImageDict ltlt13 TileWidth 25613 TileHeight 25613 Quality 1513 gtgt13 AntiAliasMonoImages false13 CropMonoImages true13 MonoImageMinResolution 120013 MonoImageMinResolutionPolicy OK13 DownsampleMonoImages true13 MonoImageDownsampleType Bicubic13 MonoImageResolution 120013 MonoImageDepth -113 MonoImageDownsampleThreshold 15000013 EncodeMonoImages true13 MonoImageFilter CCITTFaxEncode13 MonoImageDict ltlt13 K -113 gtgt13 AllowPSXObjects true13 CheckCompliance [13 None13 ]13 PDFX1aCheck false13 PDFX3Check false13 PDFXCompliantPDFOnly false13 PDFXNoTrimBoxError true13 PDFXTrimBoxToMediaBoxOffset [13 00000013 00000013 00000013 00000013 ]13 PDFXSetBleedBoxToMediaBox true13 PDFXBleedBoxToTrimBoxOffset [13 00000013 00000013 00000013 00000013 ]13 PDFXOutputIntentProfile ()13 PDFXOutputConditionIdentifier ()13 PDFXOutputCondition ()13 PDFXRegistryName ()13 PDFXTrapped False1313 CreateJDFFile false13 Description ltlt13 ARA 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 BGR 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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e55464e1a65876863768467e5770b548c62535370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc666e901a554652d965874ef6768467e5770b548c52175370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU ltFEFF00560065007200770065006e00640065006e0020005300690065002000640069006500730065002000450069006e007300740065006c006c0075006e00670065006e0020007a0075006d002000450072007300740065006c006c0065006e00200076006f006e002000410064006f006200650020005000440046002d0044006f006b0075006d0065006e00740065006e002c00200075006d002000650069006e00650020007a0075007600650072006c00e40073007300690067006500200041006e007a006500690067006500200075006e00640020004100750073006700610062006500200076006f006e00200047006500730063006800e40066007400730064006f006b0075006d0065006e00740065006e0020007a0075002000650072007a00690065006c0065006e002e00200044006900650020005000440046002d0044006f006b0075006d0065006e007400650020006b00f6006e006e0065006e0020006d006900740020004100630072006f00620061007400200075006e0064002000520065006100640065007200200036002e003000200075006e00640020006800f600680065007200200067006500f600660066006e00650074002000770065007200640065006e002egt13 ESP 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 ETI 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 FRA 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 GRE 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 HEB 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 HRV 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020be44c988b2c8c2a40020bb38c11cb97c0020c548c815c801c73cb85c0020bcf4ace00020c778c1c4d558b2940020b3700020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200036002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH ltFEFF004e006100750064006f006b0069007400650020016100690075006f007300200070006100720061006d006500740072007500730020006e006f0072011700640061006d0069002000730075006b0075007200740069002000410064006f00620065002000500044004600200064006f006b0075006d0065006e007400750073002c002000740069006e006b0061006d0075007300200076006500720073006c006f00200064006f006b0075006d0065006e00740061006d00730020006b006f006b0079006200690161006b006100690020007000650072017e0069016b007201170074006900200069007200200073007000610075007300640069006e00740069002e002000530075006b00750072007400750073002000500044004600200064006f006b0075006d0065006e007400750073002000670061006c0069006d006100200061007400690064006100720079007400690020007300750020004100630072006f006200610074002000690072002000410064006f00620065002000520065006100640065007200200036002e00300020006200650069002000760117006c00650073006e0117006d00690073002000760065007200730069006a006f006d00690073002egt13 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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                  1. Date
                  2. LEA
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                  40. ResourceTA

As a special education director we have students who are in a Moderate Cognitively Impaired program and have been exposed to a modified curriculum throughout their educational career It is not in the best interest of them to expect them to participate in the MStep even if they arent considered Significant to many The MStep causes a tremendous amount of stress to students who arent in special education Our job as educators is to look at what is best for the students on an individual level not to make sure we meet a certain percentage Requiring the state to be at 1 or under isnt in the best interest of our students 11162017 310 PM

Based on MiSchool Data 2016-2017 the state of Michigan had 3500 students with a Severe Multiple Impairments (17) eligibility While this data is not reflective of the students in grades 3-8 amp 11 it does provide us with a piece of information Additionally this data does not include other students who function as if they have a significant cognitive impairment IDEA to my knowledge does not limit the number of students who may partake in an alternate assessment it is an IEP team decision I am not making excuses just stating facts Please understand we can always improve 11162017 249 PM

I would like to know the percentage of students that have an IEP that categorizes them as cognitively impaired etc 11162017 134 PM

The current Michigan rate reflects IEP team decisions regarding the appropriateness of participation for any one student IEP teams (parents included) know these students better than any legislator The overall understanding needs to exist that 24 or even 3 of all students does show that the vast majority of students who receive special education services are taking the general education assessment IEP teams have been selective with their decisions with regard to who will participate in the alternative assessment Legislators and the guidelines that are written need to have some level of flexibility for the IEP process 11162017 130 PM

22 of the population has an IQ below 70 Students with cognitive impairments are

working at the best of their ability and that includes an alternative curriculum with

an alternative assessment

Question 2

2 Please comment on what should be included in the plan and timeline for

improvement

Try inclusion real inclusion Kids with complex needs CAN LEARN They need to be provided the resources Ieprsquos need to be looked at for the students who already are not being educated look at the student when you see the amount of time a non verbal multi impaired child is getting for speech services who is attending a

segregated school Every kid in there needs these servuces Lumping the kids together is the worst thing you could do for them This system is a giant failure and nobody cares about the 1

12192017 112 PM

The plan should include monitoring the number of students that are educated using

the alternate content standards not at the assessment point

12182017 1241 PM

I think the timeline should be extended indefinitely Students should not have to

take assessments that will frustrate them unnecessarily No valuable information will be gained from students who are overwhelmed This is why we have IEPs

12172017 1212 AM

Nothing a 1 Cap rule is forcing IEPTeams to make decisions they otherwise would not have made for a student regarding participation in the regular or

alternate assessments Why should there be issued plans of improvement and timelines forced on school districts or programs who are following IDEAMARSE

rules and regulations in an attempt to do whats right for their student MDE should not be mandating additional participation rate requirements and creating more red-

tape and work for districts and staff who are already overly regulated This is part of the reason good people leave education and we are faced with educator shortages

12142017 813 AM

Maybe we should take a closer look at the existing data in comparison to other

classroom or standards based assessment to determine how these data points correlate and how we are using this data

12132017 316 PM

If support is in place for each child they will succeed We cant say what that will be

12132017 258 PM

An honest look at the value of standardized assessment

12132017 225 PM

There should be more time spent on looking at the offerring of programs and support for special education students In addition public schools need more to

support in the general education setting to be proactive to students at a younger age The funding for special education needs to be looked at across the state

12132017 130 PM

Only assess students participating in FI Mi-Access or only include participation rates for students administered FI MiAccess

12132017 1052 AM

According to MI School Data 125 of our total student population is CI This

information should be factored into the plan for improvement How does the rate of students with CI SXI or other eligibility categories compare to this 1 target

12132017 1014 AM

What should be included in the plan is the purpose of the data we are trying to gain from the assessments given There are students that will not perform well on the

assessment or students that will not be able to engage in the assessment due to lack of skills to do so If they are not allowed to access an alternate assessment

than the State will not be able to gain a true picture of where those students are

functioning The information gained from these assessments should be useful in helping students and teachers target areas of improvement through instruction

12122017 1256 PM

Data to the districts on participation rates at all three levels of our alternate

assessment so we can identify at a district and ISD level where the issues are Professional development on assessment selection guidelines It may be helpful to include performance levels on standardized assessments (ex Cognitive scores) that

would be indicative of a possible need to consider alternate assessments Comparison of overall participation rates as well as participation in alternate

assessments If not already available it would be helpful to consider a nationwide study of this data

12122017 1141 AM

Possibly an incremental change from the current 24 to 20 to 15

1292017 908 AM

While local districts need to carefully consider the decisions for students taking functional independence I believe the decision chart and intentional review of students taking alternate assessments by district will help to identify areas of

improvement

1282017 223 PM

Start with what we know the percentages of students with significant cognitive impairment Address those students who take FI specifically to discern if we are

testing to many

1282017 1240 PM

I am not sure how you can plan for students that are not cognitively able to test the regular test Many of the district schools in our county have diminishing numbers in

their student population The 1 is not realistic

1242017 1249 PM

24 seems reasonable why would we force a student to take a test that is beyond their cognitive function

1242017 1111 AM

Again the request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform

on a standardized assessment If however the student shows growth over time the IEP team should consider general assessments as well

1242017 836 AM

MDE can create an online PD but why do we need to improve if it is a team decision to take an alternate assessment Data drives this decision

1232017 847 PM

If when has your district provided training to staff and those involved in the IEP process on the guidelines for choosing the appropriate assessment for the student

training on alternate content standards training on MI-Access How many students do you serve that cross district lines county lines (School of Choice) These

districts should not be penalized for providing service to students who choose them and therefore increase special education numbers What is your percent for each

subcategory (FI SI P) Do any of these students have access to the general education curriculum content standards for the content area in which they are taking a MI-Access assessment

1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

Putting all children in rigorous programming from birth basically taking them from

the impoverished homes and parenting which robs them of the necessary tools to meet these rigorous demands Oh and eliminate birth defects while you are at it and neurological damage I guess maybe all of this by next year

1212017 1154 AM

There should be a waiver for students who are on alternate curriculum andor in

programs for students with significant disabilities

11212017 139 PM

Students who require functional life skills curricula should not be administered

MSTEP or MME Instead they should be provided an assessment (ie MiAccess) that respects their dignity and their ability to show growth in areas they have

received targeted instruction

11212017 1228 PM

To ensure there are consistent practices across the state clear definitions should be

reported to assist with determining the appropriateness of an alternate assessment

11202017 1058 AM

Special Education teachers know the students that they are working with We have already read through the IEP and have determined educational plans for each child

on our caseload If we received a transfer student with an IEP of concern we have already held an IEP and contacted former teachers regarding our concerns about goals andor MET scores and have decided as an IEP Team appropriate teaching

goals along with appropriate assessments and testing needs for these students

Several of my transfer students had MI Alternative Testing (MI Access on their IEPs) which I immediately questioned and amended to read MStep since they are

participating in the general education content standards and come to the Resource Room for intense small group instruction in reading or math The plan should be for

Special Education teachers to submit the names of students on their current caseload the name of the test that is on the students IEP and give rationale or justification for each test that has been selected These names along with the test

rationale should be sent to the Special Education Director and then submitted to the state within the next two weeks due to the shortened week next week because of

Thanksgiving break Timeline for improvement should be to make an amendment to the students IEP within that time if changes need to be made

11182017 723 AM

Educate schoolsteachercounselors let IEP teams know what is available

11172017 1119 AM

I am not sure how we improve the fact that we service students with moderate to severe cognitive impairments If I were a parent of one of these students this statement would be insulting The decision to utilize an alternative assessment is an

IEP team decision of which the parent is a part

11172017 754 AM

PLEASE look at how many kids we have in the state who have significant cognitive impairments That should give MDE an idea of the need Training in determining the

right assessments should be offered as well This could start in spring - in getting a plan Summer for the work (with educators from around the state) Roll out spring of 2019 with training in late spring and summer

11162017 345 PM

I think that if we continue to have open dialog with the IEP team then we are doing

what is best for the student The disability doesnt drive programming so as a team we need to make sure it doesnt drive testing either

11162017 310 PM

The flow chart--Should My Student Take the Alternate Assessment--s a good tool for teams to use in making decisions PD--possibly a short online video one year

timeline

11162017 249 PM

A decision tree on what assessment should be used for each student that can be used across the state

11162017 134 PM

There should be a waiver for districts specifically those districts who operate regional or center-based programs These programs often provided services and

assess students that are significantly impacted by their disability Operating these programs where other districts send their students will effectincrease the percentage of the operating districts rates

11162017 130 PM

The plan should include a realistic percentage of students taking the test

11162017 112 PM

Question 3

3 Other comments

Showing 25 responses

This is against the ADA segregating our kids

12192017 112 PM

My district was at a 11 alternate assessment participation rate last year Dont force our IEPTeams to have to pick the 1 student wholl have to take the regular

assessment if the IEPTeam has already determined that 1 student is appropriate to take the alternate assessment Special education CI and SXI Programs are also

going to be punished when it comes to alternate assessment participation rates at 100 versus the 1 Cap I dont believe a cookie-cutter 1 can realistically take into account every school district or programs population or spectrum of students

with disabilities These assessment decisions should be left to the determination of the students IEPTeam - who knows the students level of functioning and

assessment needs I would much rather see students who score meets or exceeds expectations on MI-ACCESS be required to then take the M-STEP the following year If the student scores not-proficient on the M-STEP then MI-ACCESS could

be reconsidered the following year again for that student

12142017 813 AM

I am left wondering the purpose for this type of assessment How does it aid instruction benefit the student or improve our educational system Are we simply attempting to meet some compliance standard or is this data being used in a

manner that improves outcomes for kids

12132017 316 PM

Please consider that every are has their own needs

12132017 258 PM

Other concern is the way teachers are viewed by the state and the universitys are currently losing students because teachers are not supported in the school system

12132017 130 PM

How does the participation break down for the various levels of the alternate assessment FI SI and P FI is probably where we are going to have the most

flexibility in considering whether students should be taking the general assessment I encourage the department to seek this data when moving forward with the Waiver

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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                  1. Date
                  2. LEA
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                  35. CenterBasedClarification
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                  40. ResourceTA

Try inclusion real inclusion Kids with complex needs CAN LEARN They need to be provided the resources Ieprsquos need to be looked at for the students who already are not being educated look at the student when you see the amount of time a non verbal multi impaired child is getting for speech services who is attending a

segregated school Every kid in there needs these servuces Lumping the kids together is the worst thing you could do for them This system is a giant failure and nobody cares about the 1

12192017 112 PM

The plan should include monitoring the number of students that are educated using

the alternate content standards not at the assessment point

12182017 1241 PM

I think the timeline should be extended indefinitely Students should not have to

take assessments that will frustrate them unnecessarily No valuable information will be gained from students who are overwhelmed This is why we have IEPs

12172017 1212 AM

Nothing a 1 Cap rule is forcing IEPTeams to make decisions they otherwise would not have made for a student regarding participation in the regular or

alternate assessments Why should there be issued plans of improvement and timelines forced on school districts or programs who are following IDEAMARSE

rules and regulations in an attempt to do whats right for their student MDE should not be mandating additional participation rate requirements and creating more red-

tape and work for districts and staff who are already overly regulated This is part of the reason good people leave education and we are faced with educator shortages

12142017 813 AM

Maybe we should take a closer look at the existing data in comparison to other

classroom or standards based assessment to determine how these data points correlate and how we are using this data

12132017 316 PM

If support is in place for each child they will succeed We cant say what that will be

12132017 258 PM

An honest look at the value of standardized assessment

12132017 225 PM

There should be more time spent on looking at the offerring of programs and support for special education students In addition public schools need more to

support in the general education setting to be proactive to students at a younger age The funding for special education needs to be looked at across the state

12132017 130 PM

Only assess students participating in FI Mi-Access or only include participation rates for students administered FI MiAccess

12132017 1052 AM

According to MI School Data 125 of our total student population is CI This

information should be factored into the plan for improvement How does the rate of students with CI SXI or other eligibility categories compare to this 1 target

12132017 1014 AM

What should be included in the plan is the purpose of the data we are trying to gain from the assessments given There are students that will not perform well on the

assessment or students that will not be able to engage in the assessment due to lack of skills to do so If they are not allowed to access an alternate assessment

than the State will not be able to gain a true picture of where those students are

functioning The information gained from these assessments should be useful in helping students and teachers target areas of improvement through instruction

12122017 1256 PM

Data to the districts on participation rates at all three levels of our alternate

assessment so we can identify at a district and ISD level where the issues are Professional development on assessment selection guidelines It may be helpful to include performance levels on standardized assessments (ex Cognitive scores) that

would be indicative of a possible need to consider alternate assessments Comparison of overall participation rates as well as participation in alternate

assessments If not already available it would be helpful to consider a nationwide study of this data

12122017 1141 AM

Possibly an incremental change from the current 24 to 20 to 15

1292017 908 AM

While local districts need to carefully consider the decisions for students taking functional independence I believe the decision chart and intentional review of students taking alternate assessments by district will help to identify areas of

improvement

1282017 223 PM

Start with what we know the percentages of students with significant cognitive impairment Address those students who take FI specifically to discern if we are

testing to many

1282017 1240 PM

I am not sure how you can plan for students that are not cognitively able to test the regular test Many of the district schools in our county have diminishing numbers in

their student population The 1 is not realistic

1242017 1249 PM

24 seems reasonable why would we force a student to take a test that is beyond their cognitive function

1242017 1111 AM

Again the request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform

on a standardized assessment If however the student shows growth over time the IEP team should consider general assessments as well

1242017 836 AM

MDE can create an online PD but why do we need to improve if it is a team decision to take an alternate assessment Data drives this decision

1232017 847 PM

If when has your district provided training to staff and those involved in the IEP process on the guidelines for choosing the appropriate assessment for the student

training on alternate content standards training on MI-Access How many students do you serve that cross district lines county lines (School of Choice) These

districts should not be penalized for providing service to students who choose them and therefore increase special education numbers What is your percent for each

subcategory (FI SI P) Do any of these students have access to the general education curriculum content standards for the content area in which they are taking a MI-Access assessment

1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

Putting all children in rigorous programming from birth basically taking them from

the impoverished homes and parenting which robs them of the necessary tools to meet these rigorous demands Oh and eliminate birth defects while you are at it and neurological damage I guess maybe all of this by next year

1212017 1154 AM

There should be a waiver for students who are on alternate curriculum andor in

programs for students with significant disabilities

11212017 139 PM

Students who require functional life skills curricula should not be administered

MSTEP or MME Instead they should be provided an assessment (ie MiAccess) that respects their dignity and their ability to show growth in areas they have

received targeted instruction

11212017 1228 PM

To ensure there are consistent practices across the state clear definitions should be

reported to assist with determining the appropriateness of an alternate assessment

11202017 1058 AM

Special Education teachers know the students that they are working with We have already read through the IEP and have determined educational plans for each child

on our caseload If we received a transfer student with an IEP of concern we have already held an IEP and contacted former teachers regarding our concerns about goals andor MET scores and have decided as an IEP Team appropriate teaching

goals along with appropriate assessments and testing needs for these students

Several of my transfer students had MI Alternative Testing (MI Access on their IEPs) which I immediately questioned and amended to read MStep since they are

participating in the general education content standards and come to the Resource Room for intense small group instruction in reading or math The plan should be for

Special Education teachers to submit the names of students on their current caseload the name of the test that is on the students IEP and give rationale or justification for each test that has been selected These names along with the test

rationale should be sent to the Special Education Director and then submitted to the state within the next two weeks due to the shortened week next week because of

Thanksgiving break Timeline for improvement should be to make an amendment to the students IEP within that time if changes need to be made

11182017 723 AM

Educate schoolsteachercounselors let IEP teams know what is available

11172017 1119 AM

I am not sure how we improve the fact that we service students with moderate to severe cognitive impairments If I were a parent of one of these students this statement would be insulting The decision to utilize an alternative assessment is an

IEP team decision of which the parent is a part

11172017 754 AM

PLEASE look at how many kids we have in the state who have significant cognitive impairments That should give MDE an idea of the need Training in determining the

right assessments should be offered as well This could start in spring - in getting a plan Summer for the work (with educators from around the state) Roll out spring of 2019 with training in late spring and summer

11162017 345 PM

I think that if we continue to have open dialog with the IEP team then we are doing

what is best for the student The disability doesnt drive programming so as a team we need to make sure it doesnt drive testing either

11162017 310 PM

The flow chart--Should My Student Take the Alternate Assessment--s a good tool for teams to use in making decisions PD--possibly a short online video one year

timeline

11162017 249 PM

A decision tree on what assessment should be used for each student that can be used across the state

11162017 134 PM

There should be a waiver for districts specifically those districts who operate regional or center-based programs These programs often provided services and

assess students that are significantly impacted by their disability Operating these programs where other districts send their students will effectincrease the percentage of the operating districts rates

11162017 130 PM

The plan should include a realistic percentage of students taking the test

11162017 112 PM

Question 3

3 Other comments

Showing 25 responses

This is against the ADA segregating our kids

12192017 112 PM

My district was at a 11 alternate assessment participation rate last year Dont force our IEPTeams to have to pick the 1 student wholl have to take the regular

assessment if the IEPTeam has already determined that 1 student is appropriate to take the alternate assessment Special education CI and SXI Programs are also

going to be punished when it comes to alternate assessment participation rates at 100 versus the 1 Cap I dont believe a cookie-cutter 1 can realistically take into account every school district or programs population or spectrum of students

with disabilities These assessment decisions should be left to the determination of the students IEPTeam - who knows the students level of functioning and

assessment needs I would much rather see students who score meets or exceeds expectations on MI-ACCESS be required to then take the M-STEP the following year If the student scores not-proficient on the M-STEP then MI-ACCESS could

be reconsidered the following year again for that student

12142017 813 AM

I am left wondering the purpose for this type of assessment How does it aid instruction benefit the student or improve our educational system Are we simply attempting to meet some compliance standard or is this data being used in a

manner that improves outcomes for kids

12132017 316 PM

Please consider that every are has their own needs

12132017 258 PM

Other concern is the way teachers are viewed by the state and the universitys are currently losing students because teachers are not supported in the school system

12132017 130 PM

How does the participation break down for the various levels of the alternate assessment FI SI and P FI is probably where we are going to have the most

flexibility in considering whether students should be taking the general assessment I encourage the department to seek this data when moving forward with the Waiver

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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                  1. Date
                  2. LEA
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                  40. ResourceTA

If support is in place for each child they will succeed We cant say what that will be

12132017 258 PM

An honest look at the value of standardized assessment

12132017 225 PM

There should be more time spent on looking at the offerring of programs and support for special education students In addition public schools need more to

support in the general education setting to be proactive to students at a younger age The funding for special education needs to be looked at across the state

12132017 130 PM

Only assess students participating in FI Mi-Access or only include participation rates for students administered FI MiAccess

12132017 1052 AM

According to MI School Data 125 of our total student population is CI This

information should be factored into the plan for improvement How does the rate of students with CI SXI or other eligibility categories compare to this 1 target

12132017 1014 AM

What should be included in the plan is the purpose of the data we are trying to gain from the assessments given There are students that will not perform well on the

assessment or students that will not be able to engage in the assessment due to lack of skills to do so If they are not allowed to access an alternate assessment

than the State will not be able to gain a true picture of where those students are

functioning The information gained from these assessments should be useful in helping students and teachers target areas of improvement through instruction

12122017 1256 PM

Data to the districts on participation rates at all three levels of our alternate

assessment so we can identify at a district and ISD level where the issues are Professional development on assessment selection guidelines It may be helpful to include performance levels on standardized assessments (ex Cognitive scores) that

would be indicative of a possible need to consider alternate assessments Comparison of overall participation rates as well as participation in alternate

assessments If not already available it would be helpful to consider a nationwide study of this data

12122017 1141 AM

Possibly an incremental change from the current 24 to 20 to 15

1292017 908 AM

While local districts need to carefully consider the decisions for students taking functional independence I believe the decision chart and intentional review of students taking alternate assessments by district will help to identify areas of

improvement

1282017 223 PM

Start with what we know the percentages of students with significant cognitive impairment Address those students who take FI specifically to discern if we are

testing to many

1282017 1240 PM

I am not sure how you can plan for students that are not cognitively able to test the regular test Many of the district schools in our county have diminishing numbers in

their student population The 1 is not realistic

1242017 1249 PM

24 seems reasonable why would we force a student to take a test that is beyond their cognitive function

1242017 1111 AM

Again the request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform

on a standardized assessment If however the student shows growth over time the IEP team should consider general assessments as well

1242017 836 AM

MDE can create an online PD but why do we need to improve if it is a team decision to take an alternate assessment Data drives this decision

1232017 847 PM

If when has your district provided training to staff and those involved in the IEP process on the guidelines for choosing the appropriate assessment for the student

training on alternate content standards training on MI-Access How many students do you serve that cross district lines county lines (School of Choice) These

districts should not be penalized for providing service to students who choose them and therefore increase special education numbers What is your percent for each

subcategory (FI SI P) Do any of these students have access to the general education curriculum content standards for the content area in which they are taking a MI-Access assessment

1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

Putting all children in rigorous programming from birth basically taking them from

the impoverished homes and parenting which robs them of the necessary tools to meet these rigorous demands Oh and eliminate birth defects while you are at it and neurological damage I guess maybe all of this by next year

1212017 1154 AM

There should be a waiver for students who are on alternate curriculum andor in

programs for students with significant disabilities

11212017 139 PM

Students who require functional life skills curricula should not be administered

MSTEP or MME Instead they should be provided an assessment (ie MiAccess) that respects their dignity and their ability to show growth in areas they have

received targeted instruction

11212017 1228 PM

To ensure there are consistent practices across the state clear definitions should be

reported to assist with determining the appropriateness of an alternate assessment

11202017 1058 AM

Special Education teachers know the students that they are working with We have already read through the IEP and have determined educational plans for each child

on our caseload If we received a transfer student with an IEP of concern we have already held an IEP and contacted former teachers regarding our concerns about goals andor MET scores and have decided as an IEP Team appropriate teaching

goals along with appropriate assessments and testing needs for these students

Several of my transfer students had MI Alternative Testing (MI Access on their IEPs) which I immediately questioned and amended to read MStep since they are

participating in the general education content standards and come to the Resource Room for intense small group instruction in reading or math The plan should be for

Special Education teachers to submit the names of students on their current caseload the name of the test that is on the students IEP and give rationale or justification for each test that has been selected These names along with the test

rationale should be sent to the Special Education Director and then submitted to the state within the next two weeks due to the shortened week next week because of

Thanksgiving break Timeline for improvement should be to make an amendment to the students IEP within that time if changes need to be made

11182017 723 AM

Educate schoolsteachercounselors let IEP teams know what is available

11172017 1119 AM

I am not sure how we improve the fact that we service students with moderate to severe cognitive impairments If I were a parent of one of these students this statement would be insulting The decision to utilize an alternative assessment is an

IEP team decision of which the parent is a part

11172017 754 AM

PLEASE look at how many kids we have in the state who have significant cognitive impairments That should give MDE an idea of the need Training in determining the

right assessments should be offered as well This could start in spring - in getting a plan Summer for the work (with educators from around the state) Roll out spring of 2019 with training in late spring and summer

11162017 345 PM

I think that if we continue to have open dialog with the IEP team then we are doing

what is best for the student The disability doesnt drive programming so as a team we need to make sure it doesnt drive testing either

11162017 310 PM

The flow chart--Should My Student Take the Alternate Assessment--s a good tool for teams to use in making decisions PD--possibly a short online video one year

timeline

11162017 249 PM

A decision tree on what assessment should be used for each student that can be used across the state

11162017 134 PM

There should be a waiver for districts specifically those districts who operate regional or center-based programs These programs often provided services and

assess students that are significantly impacted by their disability Operating these programs where other districts send their students will effectincrease the percentage of the operating districts rates

11162017 130 PM

The plan should include a realistic percentage of students taking the test

11162017 112 PM

Question 3

3 Other comments

Showing 25 responses

This is against the ADA segregating our kids

12192017 112 PM

My district was at a 11 alternate assessment participation rate last year Dont force our IEPTeams to have to pick the 1 student wholl have to take the regular

assessment if the IEPTeam has already determined that 1 student is appropriate to take the alternate assessment Special education CI and SXI Programs are also

going to be punished when it comes to alternate assessment participation rates at 100 versus the 1 Cap I dont believe a cookie-cutter 1 can realistically take into account every school district or programs population or spectrum of students

with disabilities These assessment decisions should be left to the determination of the students IEPTeam - who knows the students level of functioning and

assessment needs I would much rather see students who score meets or exceeds expectations on MI-ACCESS be required to then take the M-STEP the following year If the student scores not-proficient on the M-STEP then MI-ACCESS could

be reconsidered the following year again for that student

12142017 813 AM

I am left wondering the purpose for this type of assessment How does it aid instruction benefit the student or improve our educational system Are we simply attempting to meet some compliance standard or is this data being used in a

manner that improves outcomes for kids

12132017 316 PM

Please consider that every are has their own needs

12132017 258 PM

Other concern is the way teachers are viewed by the state and the universitys are currently losing students because teachers are not supported in the school system

12132017 130 PM

How does the participation break down for the various levels of the alternate assessment FI SI and P FI is probably where we are going to have the most

flexibility in considering whether students should be taking the general assessment I encourage the department to seek this data when moving forward with the Waiver

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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                  1. Date
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functioning The information gained from these assessments should be useful in helping students and teachers target areas of improvement through instruction

12122017 1256 PM

Data to the districts on participation rates at all three levels of our alternate

assessment so we can identify at a district and ISD level where the issues are Professional development on assessment selection guidelines It may be helpful to include performance levels on standardized assessments (ex Cognitive scores) that

would be indicative of a possible need to consider alternate assessments Comparison of overall participation rates as well as participation in alternate

assessments If not already available it would be helpful to consider a nationwide study of this data

12122017 1141 AM

Possibly an incremental change from the current 24 to 20 to 15

1292017 908 AM

While local districts need to carefully consider the decisions for students taking functional independence I believe the decision chart and intentional review of students taking alternate assessments by district will help to identify areas of

improvement

1282017 223 PM

Start with what we know the percentages of students with significant cognitive impairment Address those students who take FI specifically to discern if we are

testing to many

1282017 1240 PM

I am not sure how you can plan for students that are not cognitively able to test the regular test Many of the district schools in our county have diminishing numbers in

their student population The 1 is not realistic

1242017 1249 PM

24 seems reasonable why would we force a student to take a test that is beyond their cognitive function

1242017 1111 AM

Again the request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform

on a standardized assessment If however the student shows growth over time the IEP team should consider general assessments as well

1242017 836 AM

MDE can create an online PD but why do we need to improve if it is a team decision to take an alternate assessment Data drives this decision

1232017 847 PM

If when has your district provided training to staff and those involved in the IEP process on the guidelines for choosing the appropriate assessment for the student

training on alternate content standards training on MI-Access How many students do you serve that cross district lines county lines (School of Choice) These

districts should not be penalized for providing service to students who choose them and therefore increase special education numbers What is your percent for each

subcategory (FI SI P) Do any of these students have access to the general education curriculum content standards for the content area in which they are taking a MI-Access assessment

1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

Putting all children in rigorous programming from birth basically taking them from

the impoverished homes and parenting which robs them of the necessary tools to meet these rigorous demands Oh and eliminate birth defects while you are at it and neurological damage I guess maybe all of this by next year

1212017 1154 AM

There should be a waiver for students who are on alternate curriculum andor in

programs for students with significant disabilities

11212017 139 PM

Students who require functional life skills curricula should not be administered

MSTEP or MME Instead they should be provided an assessment (ie MiAccess) that respects their dignity and their ability to show growth in areas they have

received targeted instruction

11212017 1228 PM

To ensure there are consistent practices across the state clear definitions should be

reported to assist with determining the appropriateness of an alternate assessment

11202017 1058 AM

Special Education teachers know the students that they are working with We have already read through the IEP and have determined educational plans for each child

on our caseload If we received a transfer student with an IEP of concern we have already held an IEP and contacted former teachers regarding our concerns about goals andor MET scores and have decided as an IEP Team appropriate teaching

goals along with appropriate assessments and testing needs for these students

Several of my transfer students had MI Alternative Testing (MI Access on their IEPs) which I immediately questioned and amended to read MStep since they are

participating in the general education content standards and come to the Resource Room for intense small group instruction in reading or math The plan should be for

Special Education teachers to submit the names of students on their current caseload the name of the test that is on the students IEP and give rationale or justification for each test that has been selected These names along with the test

rationale should be sent to the Special Education Director and then submitted to the state within the next two weeks due to the shortened week next week because of

Thanksgiving break Timeline for improvement should be to make an amendment to the students IEP within that time if changes need to be made

11182017 723 AM

Educate schoolsteachercounselors let IEP teams know what is available

11172017 1119 AM

I am not sure how we improve the fact that we service students with moderate to severe cognitive impairments If I were a parent of one of these students this statement would be insulting The decision to utilize an alternative assessment is an

IEP team decision of which the parent is a part

11172017 754 AM

PLEASE look at how many kids we have in the state who have significant cognitive impairments That should give MDE an idea of the need Training in determining the

right assessments should be offered as well This could start in spring - in getting a plan Summer for the work (with educators from around the state) Roll out spring of 2019 with training in late spring and summer

11162017 345 PM

I think that if we continue to have open dialog with the IEP team then we are doing

what is best for the student The disability doesnt drive programming so as a team we need to make sure it doesnt drive testing either

11162017 310 PM

The flow chart--Should My Student Take the Alternate Assessment--s a good tool for teams to use in making decisions PD--possibly a short online video one year

timeline

11162017 249 PM

A decision tree on what assessment should be used for each student that can be used across the state

11162017 134 PM

There should be a waiver for districts specifically those districts who operate regional or center-based programs These programs often provided services and

assess students that are significantly impacted by their disability Operating these programs where other districts send their students will effectincrease the percentage of the operating districts rates

11162017 130 PM

The plan should include a realistic percentage of students taking the test

11162017 112 PM

Question 3

3 Other comments

Showing 25 responses

This is against the ADA segregating our kids

12192017 112 PM

My district was at a 11 alternate assessment participation rate last year Dont force our IEPTeams to have to pick the 1 student wholl have to take the regular

assessment if the IEPTeam has already determined that 1 student is appropriate to take the alternate assessment Special education CI and SXI Programs are also

going to be punished when it comes to alternate assessment participation rates at 100 versus the 1 Cap I dont believe a cookie-cutter 1 can realistically take into account every school district or programs population or spectrum of students

with disabilities These assessment decisions should be left to the determination of the students IEPTeam - who knows the students level of functioning and

assessment needs I would much rather see students who score meets or exceeds expectations on MI-ACCESS be required to then take the M-STEP the following year If the student scores not-proficient on the M-STEP then MI-ACCESS could

be reconsidered the following year again for that student

12142017 813 AM

I am left wondering the purpose for this type of assessment How does it aid instruction benefit the student or improve our educational system Are we simply attempting to meet some compliance standard or is this data being used in a

manner that improves outcomes for kids

12132017 316 PM

Please consider that every are has their own needs

12132017 258 PM

Other concern is the way teachers are viewed by the state and the universitys are currently losing students because teachers are not supported in the school system

12132017 130 PM

How does the participation break down for the various levels of the alternate assessment FI SI and P FI is probably where we are going to have the most

flexibility in considering whether students should be taking the general assessment I encourage the department to seek this data when moving forward with the Waiver

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e55464e1a65876863768467e5770b548c62535370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc666e901a554652d965874ef6768467e5770b548c52175370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 ESP 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 FRA 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 GRE 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 HEB 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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                  1. Date
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                  40. ResourceTA

I am not sure how you can plan for students that are not cognitively able to test the regular test Many of the district schools in our county have diminishing numbers in

their student population The 1 is not realistic

1242017 1249 PM

24 seems reasonable why would we force a student to take a test that is beyond their cognitive function

1242017 1111 AM

Again the request for alternative assessment(s) is an IEP team decision based on the data presented at the time of the IEP about how the student will likely perform

on a standardized assessment If however the student shows growth over time the IEP team should consider general assessments as well

1242017 836 AM

MDE can create an online PD but why do we need to improve if it is a team decision to take an alternate assessment Data drives this decision

1232017 847 PM

If when has your district provided training to staff and those involved in the IEP process on the guidelines for choosing the appropriate assessment for the student

training on alternate content standards training on MI-Access How many students do you serve that cross district lines county lines (School of Choice) These

districts should not be penalized for providing service to students who choose them and therefore increase special education numbers What is your percent for each

subcategory (FI SI P) Do any of these students have access to the general education curriculum content standards for the content area in which they are taking a MI-Access assessment

1232017 705 PM

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

Putting all children in rigorous programming from birth basically taking them from

the impoverished homes and parenting which robs them of the necessary tools to meet these rigorous demands Oh and eliminate birth defects while you are at it and neurological damage I guess maybe all of this by next year

1212017 1154 AM

There should be a waiver for students who are on alternate curriculum andor in

programs for students with significant disabilities

11212017 139 PM

Students who require functional life skills curricula should not be administered

MSTEP or MME Instead they should be provided an assessment (ie MiAccess) that respects their dignity and their ability to show growth in areas they have

received targeted instruction

11212017 1228 PM

To ensure there are consistent practices across the state clear definitions should be

reported to assist with determining the appropriateness of an alternate assessment

11202017 1058 AM

Special Education teachers know the students that they are working with We have already read through the IEP and have determined educational plans for each child

on our caseload If we received a transfer student with an IEP of concern we have already held an IEP and contacted former teachers regarding our concerns about goals andor MET scores and have decided as an IEP Team appropriate teaching

goals along with appropriate assessments and testing needs for these students

Several of my transfer students had MI Alternative Testing (MI Access on their IEPs) which I immediately questioned and amended to read MStep since they are

participating in the general education content standards and come to the Resource Room for intense small group instruction in reading or math The plan should be for

Special Education teachers to submit the names of students on their current caseload the name of the test that is on the students IEP and give rationale or justification for each test that has been selected These names along with the test

rationale should be sent to the Special Education Director and then submitted to the state within the next two weeks due to the shortened week next week because of

Thanksgiving break Timeline for improvement should be to make an amendment to the students IEP within that time if changes need to be made

11182017 723 AM

Educate schoolsteachercounselors let IEP teams know what is available

11172017 1119 AM

I am not sure how we improve the fact that we service students with moderate to severe cognitive impairments If I were a parent of one of these students this statement would be insulting The decision to utilize an alternative assessment is an

IEP team decision of which the parent is a part

11172017 754 AM

PLEASE look at how many kids we have in the state who have significant cognitive impairments That should give MDE an idea of the need Training in determining the

right assessments should be offered as well This could start in spring - in getting a plan Summer for the work (with educators from around the state) Roll out spring of 2019 with training in late spring and summer

11162017 345 PM

I think that if we continue to have open dialog with the IEP team then we are doing

what is best for the student The disability doesnt drive programming so as a team we need to make sure it doesnt drive testing either

11162017 310 PM

The flow chart--Should My Student Take the Alternate Assessment--s a good tool for teams to use in making decisions PD--possibly a short online video one year

timeline

11162017 249 PM

A decision tree on what assessment should be used for each student that can be used across the state

11162017 134 PM

There should be a waiver for districts specifically those districts who operate regional or center-based programs These programs often provided services and

assess students that are significantly impacted by their disability Operating these programs where other districts send their students will effectincrease the percentage of the operating districts rates

11162017 130 PM

The plan should include a realistic percentage of students taking the test

11162017 112 PM

Question 3

3 Other comments

Showing 25 responses

This is against the ADA segregating our kids

12192017 112 PM

My district was at a 11 alternate assessment participation rate last year Dont force our IEPTeams to have to pick the 1 student wholl have to take the regular

assessment if the IEPTeam has already determined that 1 student is appropriate to take the alternate assessment Special education CI and SXI Programs are also

going to be punished when it comes to alternate assessment participation rates at 100 versus the 1 Cap I dont believe a cookie-cutter 1 can realistically take into account every school district or programs population or spectrum of students

with disabilities These assessment decisions should be left to the determination of the students IEPTeam - who knows the students level of functioning and

assessment needs I would much rather see students who score meets or exceeds expectations on MI-ACCESS be required to then take the M-STEP the following year If the student scores not-proficient on the M-STEP then MI-ACCESS could

be reconsidered the following year again for that student

12142017 813 AM

I am left wondering the purpose for this type of assessment How does it aid instruction benefit the student or improve our educational system Are we simply attempting to meet some compliance standard or is this data being used in a

manner that improves outcomes for kids

12132017 316 PM

Please consider that every are has their own needs

12132017 258 PM

Other concern is the way teachers are viewed by the state and the universitys are currently losing students because teachers are not supported in the school system

12132017 130 PM

How does the participation break down for the various levels of the alternate assessment FI SI and P FI is probably where we are going to have the most

flexibility in considering whether students should be taking the general assessment I encourage the department to seek this data when moving forward with the Waiver

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e55464e1a65876863768467e5770b548c62535370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc666e901a554652d965874ef6768467e5770b548c52175370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE ltFEFF0054006f0074006f0020006e006100730074006100760065006e00ed00200070006f0075017e0069006a007400650020006b0020007600790074007600e101590065006e00ed00200064006f006b0075006d0065006e0074016f002000410064006f006200650020005000440046002000760068006f0064006e00fd006300680020006b0065002000730070006f006c00650068006c0069007600e9006d0075002000700072006f0068006c00ed017e0065006e00ed002000610020007400690073006b00750020006f006200630068006f0064006e00ed0063006800200064006f006b0075006d0065006e0074016f002e002000200056007900740076006f01590065006e00e900200064006f006b0075006d0065006e0074007900200050004400460020006c007a00650020006f007400650076015900ed007400200076002000610070006c0069006b0061006300ed006300680020004100630072006f006200610074002000610020004100630072006f006200610074002000520065006100640065007200200036002e0030002000610020006e006f0076011b006a016100ed00630068002egt13 DAN 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 ESP 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ltFEFF03A703C103B703C303B903BC03BF03C003BF03B903AE03C303C403B5002003B103C503C403AD03C2002003C403B903C2002003C103C503B803BC03AF03C303B503B903C2002003B303B903B1002003BD03B1002003B403B703BC03B903BF03C503C103B303AE03C303B503C403B5002003AD03B303B303C103B103C603B1002000410064006F006200650020005000440046002003BA03B103C403AC03BB03BB03B703BB03B1002003B303B903B1002003B103BE03B903CC03C003B903C303C403B7002003C003C103BF03B203BF03BB03AE002003BA03B103B9002003B503BA03C403CD03C003C903C303B7002003B503C003B103B303B303B503BB03BC03B103C403B903BA03CE03BD002003B503B303B303C103AC03C603C903BD002E0020002003A403B1002003AD03B303B303C103B103C603B10020005000440046002003C003BF03C5002003B803B1002003B403B703BC03B903BF03C503C103B303B703B803BF03CD03BD002003B103BD03BF03AF03B303BF03C503BD002003BC03B50020004100630072006F006200610074002003BA03B103B9002000410064006F00620065002000520065006100640065007200200036002E0030002003BA03B103B9002003BD03B503CC03C403B503C103B503C2002003B503BA03B403CC03C303B503B903C2002Egt13 HEB 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ltFEFF0045007a0065006b006b0065006c0020006100200062006500e1006c006c00ed007400e10073006f006b006b0061006c002000fc007a006c00650074006900200064006f006b0075006d0065006e00740075006d006f006b0020006d00650067006200ed007a00680061007400f30020006d00650067006a0065006c0065006e00ed007400e9007300e900720065002000e900730020006e0079006f006d00740061007400e1007300e10072006100200061006c006b0061006c006d00610073002000410064006f006200650020005000440046002d0064006f006b0075006d0065006e00740075006d006f006b006100740020006b00e90073007a00ed0074006800650074002e002000200041007a002000ed006700790020006c00e90074007200650068006f007a006f007400740020005000440046002d0064006f006b0075006d0065006e00740075006d006f006b00200061007a0020004100630072006f006200610074002000e9007300200061007a002000410064006f00620065002000520065006100640065007200200036002c0030002d0073002000e900730020006b00e9007301510062006200690020007600650072007a006900f3006900760061006c0020006e00790069007400680061007400f3006b0020006d00650067002egt13 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN ltFEFF30d330b830cd30b9658766f8306e8868793a304a3088307353705237306b90693057305f002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200036002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a3067306f30d530a930f330c8306e57cb30818fbc307f3092884c3044307e30593002gt13 KOR 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ltFEFF004c006900650074006f006a00690065007400200161006f00730020006900650073007400610074012b006a0075006d00750073002c0020006c0061006900200069007a0076006500690064006f00740075002000410064006f00620065002000500044004600200064006f006b0075006d0065006e007400750073002c0020006b006100730020007000690065006d01130072006f00740069002000640072006f01610061006900200075007a01460113006d0075006d006100200064006f006b0075006d0065006e0074007500200073006b00610074012b01610061006e0061006900200075006e0020006400720075006b010101610061006e00610069002e00200049007a0076006500690064006f0074006f0073002000500044004600200064006f006b0075006d0065006e00740075007300200076006100720020006100740076011300720074002c00200069007a006d0061006e0074006f006a006f0074002000700072006f006700720061006d006d00750020004100630072006f00620061007400200075006e002000410064006f00620065002000520065006100640065007200200036002e003000200076006100690020006a00610075006e0101006b0075002000760065007200730069006a0075002egt13 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
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                  8. Justification Off
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                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

Center Based Programs are unfairly scored in that all of our students take the MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

Putting all children in rigorous programming from birth basically taking them from

the impoverished homes and parenting which robs them of the necessary tools to meet these rigorous demands Oh and eliminate birth defects while you are at it and neurological damage I guess maybe all of this by next year

1212017 1154 AM

There should be a waiver for students who are on alternate curriculum andor in

programs for students with significant disabilities

11212017 139 PM

Students who require functional life skills curricula should not be administered

MSTEP or MME Instead they should be provided an assessment (ie MiAccess) that respects their dignity and their ability to show growth in areas they have

received targeted instruction

11212017 1228 PM

To ensure there are consistent practices across the state clear definitions should be

reported to assist with determining the appropriateness of an alternate assessment

11202017 1058 AM

Special Education teachers know the students that they are working with We have already read through the IEP and have determined educational plans for each child

on our caseload If we received a transfer student with an IEP of concern we have already held an IEP and contacted former teachers regarding our concerns about goals andor MET scores and have decided as an IEP Team appropriate teaching

goals along with appropriate assessments and testing needs for these students

Several of my transfer students had MI Alternative Testing (MI Access on their IEPs) which I immediately questioned and amended to read MStep since they are

participating in the general education content standards and come to the Resource Room for intense small group instruction in reading or math The plan should be for

Special Education teachers to submit the names of students on their current caseload the name of the test that is on the students IEP and give rationale or justification for each test that has been selected These names along with the test

rationale should be sent to the Special Education Director and then submitted to the state within the next two weeks due to the shortened week next week because of

Thanksgiving break Timeline for improvement should be to make an amendment to the students IEP within that time if changes need to be made

11182017 723 AM

Educate schoolsteachercounselors let IEP teams know what is available

11172017 1119 AM

I am not sure how we improve the fact that we service students with moderate to severe cognitive impairments If I were a parent of one of these students this statement would be insulting The decision to utilize an alternative assessment is an

IEP team decision of which the parent is a part

11172017 754 AM

PLEASE look at how many kids we have in the state who have significant cognitive impairments That should give MDE an idea of the need Training in determining the

right assessments should be offered as well This could start in spring - in getting a plan Summer for the work (with educators from around the state) Roll out spring of 2019 with training in late spring and summer

11162017 345 PM

I think that if we continue to have open dialog with the IEP team then we are doing

what is best for the student The disability doesnt drive programming so as a team we need to make sure it doesnt drive testing either

11162017 310 PM

The flow chart--Should My Student Take the Alternate Assessment--s a good tool for teams to use in making decisions PD--possibly a short online video one year

timeline

11162017 249 PM

A decision tree on what assessment should be used for each student that can be used across the state

11162017 134 PM

There should be a waiver for districts specifically those districts who operate regional or center-based programs These programs often provided services and

assess students that are significantly impacted by their disability Operating these programs where other districts send their students will effectincrease the percentage of the operating districts rates

11162017 130 PM

The plan should include a realistic percentage of students taking the test

11162017 112 PM

Question 3

3 Other comments

Showing 25 responses

This is against the ADA segregating our kids

12192017 112 PM

My district was at a 11 alternate assessment participation rate last year Dont force our IEPTeams to have to pick the 1 student wholl have to take the regular

assessment if the IEPTeam has already determined that 1 student is appropriate to take the alternate assessment Special education CI and SXI Programs are also

going to be punished when it comes to alternate assessment participation rates at 100 versus the 1 Cap I dont believe a cookie-cutter 1 can realistically take into account every school district or programs population or spectrum of students

with disabilities These assessment decisions should be left to the determination of the students IEPTeam - who knows the students level of functioning and

assessment needs I would much rather see students who score meets or exceeds expectations on MI-ACCESS be required to then take the M-STEP the following year If the student scores not-proficient on the M-STEP then MI-ACCESS could

be reconsidered the following year again for that student

12142017 813 AM

I am left wondering the purpose for this type of assessment How does it aid instruction benefit the student or improve our educational system Are we simply attempting to meet some compliance standard or is this data being used in a

manner that improves outcomes for kids

12132017 316 PM

Please consider that every are has their own needs

12132017 258 PM

Other concern is the way teachers are viewed by the state and the universitys are currently losing students because teachers are not supported in the school system

12132017 130 PM

How does the participation break down for the various levels of the alternate assessment FI SI and P FI is probably where we are going to have the most

flexibility in considering whether students should be taking the general assessment I encourage the department to seek this data when moving forward with the Waiver

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 ITA (Utilizzare 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PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
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                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

Several of my transfer students had MI Alternative Testing (MI Access on their IEPs) which I immediately questioned and amended to read MStep since they are

participating in the general education content standards and come to the Resource Room for intense small group instruction in reading or math The plan should be for

Special Education teachers to submit the names of students on their current caseload the name of the test that is on the students IEP and give rationale or justification for each test that has been selected These names along with the test

rationale should be sent to the Special Education Director and then submitted to the state within the next two weeks due to the shortened week next week because of

Thanksgiving break Timeline for improvement should be to make an amendment to the students IEP within that time if changes need to be made

11182017 723 AM

Educate schoolsteachercounselors let IEP teams know what is available

11172017 1119 AM

I am not sure how we improve the fact that we service students with moderate to severe cognitive impairments If I were a parent of one of these students this statement would be insulting The decision to utilize an alternative assessment is an

IEP team decision of which the parent is a part

11172017 754 AM

PLEASE look at how many kids we have in the state who have significant cognitive impairments That should give MDE an idea of the need Training in determining the

right assessments should be offered as well This could start in spring - in getting a plan Summer for the work (with educators from around the state) Roll out spring of 2019 with training in late spring and summer

11162017 345 PM

I think that if we continue to have open dialog with the IEP team then we are doing

what is best for the student The disability doesnt drive programming so as a team we need to make sure it doesnt drive testing either

11162017 310 PM

The flow chart--Should My Student Take the Alternate Assessment--s a good tool for teams to use in making decisions PD--possibly a short online video one year

timeline

11162017 249 PM

A decision tree on what assessment should be used for each student that can be used across the state

11162017 134 PM

There should be a waiver for districts specifically those districts who operate regional or center-based programs These programs often provided services and

assess students that are significantly impacted by their disability Operating these programs where other districts send their students will effectincrease the percentage of the operating districts rates

11162017 130 PM

The plan should include a realistic percentage of students taking the test

11162017 112 PM

Question 3

3 Other comments

Showing 25 responses

This is against the ADA segregating our kids

12192017 112 PM

My district was at a 11 alternate assessment participation rate last year Dont force our IEPTeams to have to pick the 1 student wholl have to take the regular

assessment if the IEPTeam has already determined that 1 student is appropriate to take the alternate assessment Special education CI and SXI Programs are also

going to be punished when it comes to alternate assessment participation rates at 100 versus the 1 Cap I dont believe a cookie-cutter 1 can realistically take into account every school district or programs population or spectrum of students

with disabilities These assessment decisions should be left to the determination of the students IEPTeam - who knows the students level of functioning and

assessment needs I would much rather see students who score meets or exceeds expectations on MI-ACCESS be required to then take the M-STEP the following year If the student scores not-proficient on the M-STEP then MI-ACCESS could

be reconsidered the following year again for that student

12142017 813 AM

I am left wondering the purpose for this type of assessment How does it aid instruction benefit the student or improve our educational system Are we simply attempting to meet some compliance standard or is this data being used in a

manner that improves outcomes for kids

12132017 316 PM

Please consider that every are has their own needs

12132017 258 PM

Other concern is the way teachers are viewed by the state and the universitys are currently losing students because teachers are not supported in the school system

12132017 130 PM

How does the participation break down for the various levels of the alternate assessment FI SI and P FI is probably where we are going to have the most

flexibility in considering whether students should be taking the general assessment I encourage the department to seek this data when moving forward with the Waiver

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 BGR 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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e55464e1a65876863768467e5770b548c62535370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc666e901a554652d965874ef6768467e5770b548c52175370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU 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 ESP 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 ETI 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 FRA 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 GRE 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 HEB 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 HRV 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020be44c988b2c8c2a40020bb38c11cb97c0020c548c815c801c73cb85c0020bcf4ace00020c778c1c4d558b2940020b3700020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200036002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL 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PTB 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                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
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                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
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                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
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                  27. OtherParents Off
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                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

The flow chart--Should My Student Take the Alternate Assessment--s a good tool for teams to use in making decisions PD--possibly a short online video one year

timeline

11162017 249 PM

A decision tree on what assessment should be used for each student that can be used across the state

11162017 134 PM

There should be a waiver for districts specifically those districts who operate regional or center-based programs These programs often provided services and

assess students that are significantly impacted by their disability Operating these programs where other districts send their students will effectincrease the percentage of the operating districts rates

11162017 130 PM

The plan should include a realistic percentage of students taking the test

11162017 112 PM

Question 3

3 Other comments

Showing 25 responses

This is against the ADA segregating our kids

12192017 112 PM

My district was at a 11 alternate assessment participation rate last year Dont force our IEPTeams to have to pick the 1 student wholl have to take the regular

assessment if the IEPTeam has already determined that 1 student is appropriate to take the alternate assessment Special education CI and SXI Programs are also

going to be punished when it comes to alternate assessment participation rates at 100 versus the 1 Cap I dont believe a cookie-cutter 1 can realistically take into account every school district or programs population or spectrum of students

with disabilities These assessment decisions should be left to the determination of the students IEPTeam - who knows the students level of functioning and

assessment needs I would much rather see students who score meets or exceeds expectations on MI-ACCESS be required to then take the M-STEP the following year If the student scores not-proficient on the M-STEP then MI-ACCESS could

be reconsidered the following year again for that student

12142017 813 AM

I am left wondering the purpose for this type of assessment How does it aid instruction benefit the student or improve our educational system Are we simply attempting to meet some compliance standard or is this data being used in a

manner that improves outcomes for kids

12132017 316 PM

Please consider that every are has their own needs

12132017 258 PM

Other concern is the way teachers are viewed by the state and the universitys are currently losing students because teachers are not supported in the school system

12132017 130 PM

How does the participation break down for the various levels of the alternate assessment FI SI and P FI is probably where we are going to have the most

flexibility in considering whether students should be taking the general assessment I encourage the department to seek this data when moving forward with the Waiver

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 ESP 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 FRA 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 GRE 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 HEB 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 HRV 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020be44c988b2c8c2a40020bb38c11cb97c0020c548c815c801c73cb85c0020bcf4ace00020c778c1c4d558b2940020b3700020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200036002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI ltFEFF004c006900650074006f006a00690065007400200161006f00730020006900650073007400610074012b006a0075006d00750073002c0020006c0061006900200069007a0076006500690064006f00740075002000410064006f00620065002000500044004600200064006f006b0075006d0065006e007400750073002c0020006b006100730020007000690065006d01130072006f00740069002000640072006f01610061006900200075007a01460113006d0075006d006100200064006f006b0075006d0065006e0074007500200073006b00610074012b01610061006e0061006900200075006e0020006400720075006b010101610061006e00610069002e00200049007a0076006500690064006f0074006f0073002000500044004600200064006f006b0075006d0065006e00740075007300200076006100720020006100740076011300720074002c00200069007a006d0061006e0074006f006a006f0074002000700072006f006700720061006d006d00750020004100630072006f00620061007400200075006e002000410064006f00620065002000520065006100640065007200200036002e003000200076006100690020006a00610075006e0101006b0075002000760065007200730069006a0075002egt13 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
                  20. GuideDocsRelServStaff Off
                  21. NoTrainAdmin Off
                  22. NoTrainSpecialEdStaff Off
                  23. NoTrainParents Off
                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
                  26. OtherSpecialEdStaff Off
                  27. OtherParents Off
                  28. OtherRelServStaff Off
                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

My district was at a 11 alternate assessment participation rate last year Dont force our IEPTeams to have to pick the 1 student wholl have to take the regular

assessment if the IEPTeam has already determined that 1 student is appropriate to take the alternate assessment Special education CI and SXI Programs are also

going to be punished when it comes to alternate assessment participation rates at 100 versus the 1 Cap I dont believe a cookie-cutter 1 can realistically take into account every school district or programs population or spectrum of students

with disabilities These assessment decisions should be left to the determination of the students IEPTeam - who knows the students level of functioning and

assessment needs I would much rather see students who score meets or exceeds expectations on MI-ACCESS be required to then take the M-STEP the following year If the student scores not-proficient on the M-STEP then MI-ACCESS could

be reconsidered the following year again for that student

12142017 813 AM

I am left wondering the purpose for this type of assessment How does it aid instruction benefit the student or improve our educational system Are we simply attempting to meet some compliance standard or is this data being used in a

manner that improves outcomes for kids

12132017 316 PM

Please consider that every are has their own needs

12132017 258 PM

Other concern is the way teachers are viewed by the state and the universitys are currently losing students because teachers are not supported in the school system

12132017 130 PM

How does the participation break down for the various levels of the alternate assessment FI SI and P FI is probably where we are going to have the most

flexibility in considering whether students should be taking the general assessment I encourage the department to seek this data when moving forward with the Waiver

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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ltFEFF00560065007200770065006e00640065006e0020005300690065002000640069006500730065002000450069006e007300740065006c006c0075006e00670065006e0020007a0075006d002000450072007300740065006c006c0065006e00200076006f006e002000410064006f006200650020005000440046002d0044006f006b0075006d0065006e00740065006e002c00200075006d002000650069006e00650020007a0075007600650072006c00e40073007300690067006500200041006e007a006500690067006500200075006e00640020004100750073006700610062006500200076006f006e00200047006500730063006800e40066007400730064006f006b0075006d0065006e00740065006e0020007a0075002000650072007a00690065006c0065006e002e00200044006900650020005000440046002d0044006f006b0075006d0065006e007400650020006b00f6006e006e0065006e0020006d006900740020004100630072006f00620061007400200075006e0064002000520065006100640065007200200036002e003000200075006e00640020006800f600680065007200200067006500f600660066006e00650074002000770065007200640065006e002egt13 ESP 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 ETI 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 FRA 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 GRE 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 HEB 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 HRV 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020be44c988b2c8c2a40020bb38c11cb97c0020c548c815c801c73cb85c0020bcf4ace00020c778c1c4d558b2940020b3700020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200036002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL 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 PTB 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 RUM ltFEFF005500740069006C0069007A00610163006900200061006300650073007400650020007300650074010300720069002000700065006E007400720075002000610020006300720065006100200064006F00630075006D0065006E00740065002000410064006F006200650020005000440046002000610064006500630076006100740065002000700065006E007400720075002000760069007A00750061006C0069007A006100720065002000640065002000EE006E00630072006500640065007200650020015F0069002000700065006E00740072007500200069006D007000720069006D006100720065006100200064006F00630075006D0065006E00740065006C006F007200200064006500200061006600610063006500720069002E00200044006F00630075006D0065006E00740065006C00650020005000440046002000630072006500610074006500200070006F00740020006600690020006400650073006300680069007300650020006300750020004100630072006F0062006100740020015F0069002000410064006F00620065002000520065006100640065007200200036002E003000200073006100750020007600650072007300690075006E006900200075006C0074006500720069006F006100720065002Egt13 RUS 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documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
                  20. GuideDocsRelServStaff Off
                  21. NoTrainAdmin Off
                  22. NoTrainSpecialEdStaff Off
                  23. NoTrainParents Off
                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
                  26. OtherSpecialEdStaff Off
                  27. OtherParents Off
                  28. OtherRelServStaff Off
                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

12132017 1014 AM

Im concerned that the 1 target is an arbitrary number that isnt grounded in

data When reviewing eligibility rates and students that function within the range of performance that is appropriate for alternate assessments Im concerned that 1 is

not an attainable goal I think that providing a summary of some of the data mentioned in number 1 may provide a stronger case for Michigans waiver

12122017 1141 AM

It may be helpful to provide examples of the meaning of alternate curriculum in the MDE guidelines for alternate assessment

1292017 908 AM

As mentioned in item 1 our students with the most severe needs are increasing in number and account for a sizable percentage of our population taking the

alternate state assessment (Supported Independence and Participation) that is close to the 1 participation cap

1282017 223 PM

I am not sure Michigan can ever be at or below 1 if proportionately our total significantly impaired population is over 1 Given that we can always be training

on expectations

1282017 1240 PM

Districts that host regional programs and center based programs will have higher percentages of students taking alternate assessments This should be considered

before requiring technical support for such sites

1262017 1044 AM

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 GRE 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 HEB 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 HRV 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL 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 PTB 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RUM 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 RUS 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 SKY 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 SLV ltFEFF005400650020006E006100730074006100760069007400760065002000750070006F0072006100620069007400650020007A00610020007500730074007600610072006A0061006E006A006500200064006F006B0075006D0065006E0074006F0076002000410064006F006200650020005000440046002C0020007000720069006D00650072006E006900680020007A00610020007A0061006E00650073006C006A006900760020006F0067006C0065006400200069006E0020007400690073006B0061006E006A006500200070006F0073006C006F0076006E0069006800200064006F006B0075006D0065006E0074006F0076002E0020005500730074007600610072006A0065006E006500200064006F006B0075006D0065006E0074006500200050004400460020006A00650020006D006F0067006F010D00650020006F00640070007200650074006900200073002000700072006F006700720061006D006F006D00610020004100630072006F00620061007400200069006E002000410064006F00620065002000520065006100640065007200200036002E003000200074006500720020006E006F00760065006A01610069006D0069002Egt13 SUO 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
                  20. GuideDocsRelServStaff Off
                  21. NoTrainAdmin Off
                  22. NoTrainSpecialEdStaff Off
                  23. NoTrainParents Off
                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
                  26. OtherSpecialEdStaff Off
                  27. OtherParents Off
                  28. OtherRelServStaff Off
                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

Not all students test well I understand that we have to prepare students to be productive in our society but not all students need to be at college level We just

need to make sure that all of our students are trained and can be productive Skilled trades individuals are just as important if not more important as college

trained individuals

1242017 1249 PM

lowering the percentage is only for adult rationale it is not taking into account

student function ability and stress this is not a good decision and should be reconsidered based on real data from the field from educators that are working

with this population regularly

1242017 1111 AM

None noted at this time

1242017 836 AM

Center Based Programs are unfairly scored in that all of our students take the

MiAccess We always show a red score Is there any way that we can be exempt

1212017 1156 AM

I know that my comments are probably not even helpful How I wish that the

people making these tests and guidelines and laws had to come and try to teach students with learning disabilities autism cognitive physical and otherwise health

impaired and emotional difficulties this demanding curriculum This entire test-driven reform has done little to improve anything rather put us further behind in

the world against countries who are practical in how they spend their money to educate their children

1212017 1154 AM

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN ltFEFF30d330b830cd30b9658766f8306e8868793a304a3088307353705237306b90693057305f002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200036002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a3067306f30d530a930f330c8306e57cb30818fbc307f3092884c3044307e30593002gt13 KOR 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 TUR 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 ENU (Use these settings to create Adobe PDF documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
                  20. GuideDocsRelServStaff Off
                  21. NoTrainAdmin Off
                  22. NoTrainSpecialEdStaff Off
                  23. NoTrainParents Off
                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
                  26. OtherSpecialEdStaff Off
                  27. OtherParents Off
                  28. OtherRelServStaff Off
                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

As a whole I feel that our staff does an excellent job in ensuring that only the students with the most significant impairments take the alternate assessment

When students are on a modified curriculum (which is decided by the IEP team and includes parents) it would be inappropriate to use any other assessment Even

though we provide programming for students from 7 school districts in our K-12 regional programs our percentage is only just over 2 I think that should be applauded not punished Parents have begun to question the entire assessment

process While in attendance at IEPs where we review the Should my child take an alternate assessment document I have parents who have stated that if their child

is forced to take MSTEP they will not allow it

11212017 139 PM

It would seem the pendulum of inclusiveness has swung a bit too far with regards

to state level testing The original intent of testing all students regardless of abilities was noble and respected dignity The evolution of this idea into testing children

with a singular measure reminds me of the old age Fair is not equal Equally testing all but 1 of school age children with college-centric assessments does not represent progress for students with disabilities Nor does it represent workforce

needs in the State of MI Similarly testing 2-5 of students with an alternative measure should not be seen as watering things down or lowering expectations

Instead it should be viewed as a reasonable response to quantifiable student differences

11212017 1228 PM

Overall the concept of capping the number of students who take an alternate state assessment at 1 is concerning even if the decisions are left to IEP teams What

are the complete determining factors that identifies 1 (or less) as the appropriate cut off percentage

11202017 1058 AM

It is appropriate to question what is on any IEP and to determine and justify appropriate current plans of instruction and assessing academic goals for each

student However the two choices that we have for our students are MStep and MIAccess Not all students fit into one of these boxes and yes there are

exceptions to every rule There are students with physical limitations emotional andor behavioral concerns There are students who are Autistic and high functioning on a daily basis but become very anxious when taking any test on the

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e55464e1a65876863768467e5770b548c62535370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc666e901a554652d965874ef6768467e5770b548c52175370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 ESP 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 FRA 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 GRE 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 HEB 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
                  20. GuideDocsRelServStaff Off
                  21. NoTrainAdmin Off
                  22. NoTrainSpecialEdStaff Off
                  23. NoTrainParents Off
                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
                  26. OtherSpecialEdStaff Off
                  27. OtherParents Off
                  28. OtherRelServStaff Off
                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

computer Our professional and ethical responsibility is to help every student be successful at his or her ability yet there seems to be a One size fits all mentality

when it comes to state assessment We are penalized as a district if parents choose to have their child exempted from the test so the pressure is there to test the

child regardless of whats best for the child What about having the allowance for some special education children tested with the state assessment every three years to align with their MET scores It seems that accountability (test data) and teach

to the test mentality has become more important that to do what is right for these unique individuals who are learning and growing under our guidance These

children and our parents entrust us to do the right things

11182017 723 AM

The State of Michigan needs to accommodate students with needs Schools need to

be accommodating

11172017 1119 AM

The State should provide waivers for districts that provide programs for students with moderate to severe cognitive impairments There should be no oversight for these districts

11172017 754 AM

How was the 1 cap determined and what are the consequences for districts with

a higher number of students with cognitive deficits

11162017 418 PM

I think it will be interesting to dissect the data of the students who are currently taking alternate assessment What categories cognitive levels etc

11162017 134 PM

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 ESP 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 ETI 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 FRA 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 GRE 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 HEB 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 HRV 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 HUN ltFEFF0045007a0065006b006b0065006c0020006100200062006500e1006c006c00ed007400e10073006f006b006b0061006c002000fc007a006c00650074006900200064006f006b0075006d0065006e00740075006d006f006b0020006d00650067006200ed007a00680061007400f30020006d00650067006a0065006c0065006e00ed007400e9007300e900720065002000e900730020006e0079006f006d00740061007400e1007300e10072006100200061006c006b0061006c006d00610073002000410064006f006200650020005000440046002d0064006f006b0075006d0065006e00740075006d006f006b006100740020006b00e90073007a00ed0074006800650074002e002000200041007a002000ed006700790020006c00e90074007200650068006f007a006f007400740020005000440046002d0064006f006b0075006d0065006e00740075006d006f006b00200061007a0020004100630072006f006200610074002000e9007300200061007a002000410064006f00620065002000520065006100640065007200200036002c0030002d0073002000e900730020006b00e9007301510062006200690020007600650072007a006900f3006900760061006c0020006e00790069007400680061007400f3006b0020006d00650067002egt13 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020be44c988b2c8c2a40020bb38c11cb97c0020c548c815c801c73cb85c0020bcf4ace00020c778c1c4d558b2940020b3700020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200036002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL ltFEFF004b006f0072007a0079007300740061006a010500630020007a00200074007900630068002000750073007400610077006900650144002c0020006d006f017c006e0061002000740077006f0072007a0079010700200064006f006b0075006d0065006e00740079002000410064006f00620065002000500044004600200070006f007a00770061006c0061006a01050063006500200077002000730070006f007300f300620020006e00690065007a00610077006f0064006e0079002000770079015b0077006900650074006c00610107002000690020006400720075006b006f00770061010700200064006f006b0075006d0065006e007400790020006600690072006d006f00770065002e00200020005500740077006f0072007a006f006e006500200064006f006b0075006d0065006e0074007900200050004400460020006d006f017c006e00610020006f007400770069006500720061010700200077002000700072006f006700720061006d0061006300680020004100630072006f00620061007400200069002000410064006f0062006500200052006500610064006500720020007700200077006500720073006a006900200036002e00300020006f00720061007a002000770020006e006f00770073007a00790063006800200077006500720073006a00610063006800200074007900630068002000700072006f006700720061006d00f30077002e004b006f0072007a0079007300740061006a010500630020007a00200074007900630068002000750073007400610077006900650144002c0020006d006f017c006e0061002000740077006f0072007a0079010700200064006f006b0075006d0065006e00740079002000410064006f00620065002000500044004600200070006f007a00770061006c0061006a01050063006500200077002000730070006f007300f300620020006e00690065007a00610077006f0064006e0079002000770079015b0077006900650074006c00610107002000690020006400720075006b006f00770061010700200064006f006b0075006d0065006e007400790020006600690072006d006f00770065002e00200020005500740077006f0072007a006f006e006500200064006f006b0075006d0065006e0074007900200050004400460020006d006f017c006e00610020006f007400770069006500720061010700200077002000700072006f006700720061006d0061006300680020004100630072006f00620061007400200069002000410064006f0062006500200052006500610064006500720020007700200077006500720073006a006900200036002e00300020006f00720061007a002000770020006e006f00770073007a00790063006800200077006500720073006a00610063006800200074007900630068002000700072006f006700720061006d00f30077002egt13 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE ltFEFF0041006e007600e4006e00640020006400650020006800e4007200200069006e0073007400e4006c006c006e0069006e006700610072006e00610020006f006d002000640075002000760069006c006c00200073006b006100700061002000410064006f006200650020005000440046002d0064006f006b0075006d0065006e007400200073006f006d00200070006100730073006100720020006600f60072002000740069006c006c006600f60072006c00690074006c006900670020007600690073006e0069006e00670020006f006300680020007500740073006b007200690066007400650072002000610076002000610066006600e4007200730064006f006b0075006d0065006e0074002e002000200053006b006100700061006400650020005000440046002d0064006f006b0075006d0065006e00740020006b0061006e002000f600700070006e00610073002000690020004100630072006f0062006100740020006f00630068002000410064006f00620065002000520065006100640065007200200036002e00300020006f00630068002000730065006e006100720065002egt13 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
                  20. GuideDocsRelServStaff Off
                  21. NoTrainAdmin Off
                  22. NoTrainSpecialEdStaff Off
                  23. NoTrainParents Off
                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
                  26. OtherSpecialEdStaff Off
                  27. OtherParents Off
                  28. OtherRelServStaff Off
                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

Let IEP teams make these decisions regardless of an arbitrary percentage rate set by legislation This is a major issue as it relates to using high risk assessments

where it may make no sense to have a special education student participate and the data obtained by that assessment is not useful to the child or the districts As

stated in previous answer a 3 participation rate matches the 3 of students who are impacted severely by a disability Again some flexibility needs to be had when applying rules to center-based and regional programs

11162017 130 PM

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR 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PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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PTB 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RUM 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 RUS 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SLV 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 SUO 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
                  20. GuideDocsRelServStaff Off
                  21. NoTrainAdmin Off
                  22. NoTrainSpecialEdStaff Off
                  23. NoTrainParents Off
                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
                  26. OtherSpecialEdStaff Off
                  27. OtherParents Off
                  28. OtherRelServStaff Off
                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

Appendix C Guidelines for Participation in Michiganrsquos Alternate Assessment

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 BGR ltFEFF04180437043F043E043B043704320430043904420435002004420435043704380020043D0430044104420440043E0439043A0438002C00200437043000200434043000200441044A0437043404300432043004420435002000410064006F00620065002000500044004600200434043E043A0443043C0435043D04420438002C0020043F043E04340445043E0434044F044904380020043704300020043D04300434043504360434043D043E00200440043004370433043B0435043604340430043D0435002004380020043F04350447043004420430043D04350020043D04300020043104380437043D0435044100200434043E043A0443043C0435043D04420438002E00200421044A04370434043004340435043D043804420435002000500044004600200434043E043A0443043C0435043D044204380020043C043E0433043004420020043404300020044104350020043E0442043204300440044F0442002004410020004100630072006F00620061007400200438002000410064006F00620065002000520065006100640065007200200036002E0030002004380020043F043E002D043D043E043204380020043204350440044104380438002Egt13 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e55464e1a65876863768467e5770b548c62535370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc666e901a554652d965874ef6768467e5770b548c52175370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU 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 ESP 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 ETI 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 FRA 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 GRE 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 HEB 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 HRV 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020be44c988b2c8c2a40020bb38c11cb97c0020c548c815c801c73cb85c0020bcf4ace00020c778c1c4d558b2940020b3700020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200036002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH ltFEFF004e006100750064006f006b0069007400650020016100690075006f007300200070006100720061006d006500740072007500730020006e006f0072011700640061006d0069002000730075006b0075007200740069002000410064006f00620065002000500044004600200064006f006b0075006d0065006e007400750073002c002000740069006e006b0061006d0075007300200076006500720073006c006f00200064006f006b0075006d0065006e00740061006d00730020006b006f006b0079006200690161006b006100690020007000650072017e0069016b007201170074006900200069007200200073007000610075007300640069006e00740069002e002000530075006b00750072007400750073002000500044004600200064006f006b0075006d0065006e007400750073002000670061006c0069006d006100200061007400690064006100720079007400690020007300750020004100630072006f006200610074002000690072002000410064006f00620065002000520065006100640065007200200036002e00300020006200650069002000760117006c00650073006e0117006d00690073002000760065007200730069006a006f006d00690073002egt13 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
                  20. GuideDocsRelServStaff Off
                  21. NoTrainAdmin Off
                  22. NoTrainSpecialEdStaff Off
                  23. NoTrainParents Off
                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
                  26. OtherSpecialEdStaff Off
                  27. OtherParents Off
                  28. OtherRelServStaff Off
                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

Appendix D Sample of data provided to Intermediate School Districts

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 GRE ltFEFF03A703C103B703C303B903BC03BF03C003BF03B903AE03C303C403B5002003B103C503C403AD03C2002003C403B903C2002003C103C503B803BC03AF03C303B503B903C2002003B303B903B1002003BD03B1002003B403B703BC03B903BF03C503C103B303AE03C303B503C403B5002003AD03B303B303C103B103C603B1002000410064006F006200650020005000440046002003BA03B103C403AC03BB03BB03B703BB03B1002003B303B903B1002003B103BE03B903CC03C003B903C303C403B7002003C003C103BF03B203BF03BB03AE002003BA03B103B9002003B503BA03C403CD03C003C903C303B7002003B503C003B103B303B303B503BB03BC03B103C403B903BA03CE03BD002003B503B303B303C103AC03C603C903BD002E0020002003A403B1002003AD03B303B303C103B103C603B10020005000440046002003C003BF03C5002003B803B1002003B403B703BC03B903BF03C503C103B303B703B803BF03CD03BD002003B103BD03BF03AF03B303BF03C503BD002003BC03B50020004100630072006F006200610074002003BA03B103B9002000410064006F00620065002000520065006100640065007200200036002E0030002003BA03B103B9002003BD03B503CC03C403B503C103B503C2002003B503BA03B403CC03C303B503B903C2002Egt13 HEB 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 HRV 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR 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ltFEFF004c006900650074006f006a00690065007400200161006f00730020006900650073007400610074012b006a0075006d00750073002c0020006c0061006900200069007a0076006500690064006f00740075002000410064006f00620065002000500044004600200064006f006b0075006d0065006e007400750073002c0020006b006100730020007000690065006d01130072006f00740069002000640072006f01610061006900200075007a01460113006d0075006d006100200064006f006b0075006d0065006e0074007500200073006b00610074012b01610061006e0061006900200075006e0020006400720075006b010101610061006e00610069002e00200049007a0076006500690064006f0074006f0073002000500044004600200064006f006b0075006d0065006e00740075007300200076006100720020006100740076011300720074002c00200069007a006d0061006e0074006f006a006f0074002000700072006f006700720061006d006d00750020004100630072006f00620061007400200075006e002000410064006f00620065002000520065006100640065007200200036002e003000200076006100690020006a00610075006e0101006b0075002000760065007200730069006a0075002egt13 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL 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 PTB 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RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
                  20. GuideDocsRelServStaff Off
                  21. NoTrainAdmin Off
                  22. NoTrainSpecialEdStaff Off
                  23. NoTrainParents Off
                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
                  26. OtherSpecialEdStaff Off
                  27. OtherParents Off
                  28. OtherRelServStaff Off
                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

District Information

Date

Local Educational Agency (LEA) Phone

LEA Contact Phone

Intermediate School District (ISD)

Baseline

Did more than 1 of students tested using state assessments in any content area take the alternate assessment (MI-Access)

Yes No

APPENDIX E

Exceeding 1 Cap Justification Form The Every Student Succeeds Act (ESSA) places a 1 cap on alternate assessment (MI-Access) participation at the state level Local educational agencies (LEAs) that contribute to the state exceeding its participation cap must submit information to their ISD justifying the need to exceed the 1 threshold I n addition intermediate school districts (ISDs) that run programs (functioning as an LEA) must complete the form as an LEA

Each ISD collects information from its LEAs to submit to the state

Author Michigan Department of Education Last updated 121817

If you answer no date stamp the form and keep it on file for future reference If you answer yes complete the remainder of the form

Michigan Department of Education Page 1

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
                  20. GuideDocsRelServStaff Off
                  21. NoTrainAdmin Off
                  22. NoTrainSpecialEdStaff Off
                  23. NoTrainParents Off
                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
                  26. OtherSpecialEdStaff Off
                  27. OtherParents Off
                  28. OtherRelServStaff Off
                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

Training Method School Administration

Special Education

Staff Parents

Related Service Staff

Face-to-face training

Online training

Given copy of guidance documents

No training provided

Other please explain below

Justification

Do not submit any student identifiable information with this form

Did your individualized education program (IEP) teams utilize the alternate assessment participation guidelines to make assessment participation decisions

Yes No

Indicate how all members of the IEP teams have been informed or trained on the participation guidelines Check all that apply

If you selected other in the above table please explain

Michigan Department of Education Page 2

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 DEU ltFEFF00560065007200770065006e00640065006e0020005300690065002000640069006500730065002000450069006e007300740065006c006c0075006e00670065006e0020007a0075006d002000450072007300740065006c006c0065006e00200076006f006e002000410064006f006200650020005000440046002d0044006f006b0075006d0065006e00740065006e002c00200075006d002000650069006e00650020007a0075007600650072006c00e40073007300690067006500200041006e007a006500690067006500200075006e00640020004100750073006700610062006500200076006f006e00200047006500730063006800e40066007400730064006f006b0075006d0065006e00740065006e0020007a0075002000650072007a00690065006c0065006e002e00200044006900650020005000440046002d0044006f006b0075006d0065006e007400650020006b00f6006e006e0065006e0020006d006900740020004100630072006f00620061007400200075006e0064002000520065006100640065007200200036002e003000200075006e00640020006800f600680065007200200067006500f600660066006e00650074002000770065007200640065006e002egt13 ESP 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 ETI 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 FRA 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 GRE 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 HEB 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 HRV 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020be44c988b2c8c2a40020bb38c11cb97c0020c548c815c801c73cb85c0020bcf4ace00020c778c1c4d558b2940020b3700020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200036002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
                  20. GuideDocsRelServStaff Off
                  21. NoTrainAdmin Off
                  22. NoTrainSpecialEdStaff Off
                  23. NoTrainParents Off
                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
                  26. OtherSpecialEdStaff Off
                  27. OtherParents Off
                  28. OtherRelServStaff Off
                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

Identify the factors that contributed to your LEA exceeding the 1 cap of students allowed to participate in MI-Access Select at least one and all that apply

The IEP teams lack the necessary knowledge to effectively use the participation guidelines when defining a student as having a significant cognitive disability

A small LEA size results in a greater impact on participation rates (for example a district size of 180 students with 2 students with significant cognitive disabilities results in a higher than 1 participation rate)

Provide clarification or explain the impact of this factor

The LEA operates a center-based program serving other students within the ISD or region that results in an expected higher population of students with significant cognitive impairments

If students from other LEAs are removed from this count what is the adjusted participation rate (Be sure to keep students who are residents of the LEA in the count when calculating the percentage)

Provide clarification or explain the impact of this factor

Other (please explain)

Michigan Department of Education Page 3

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR 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PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
                  20. GuideDocsRelServStaff Off
                  21. NoTrainAdmin Off
                  22. NoTrainSpecialEdStaff Off
                  23. NoTrainParents Off
                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
                  26. OtherSpecialEdStaff Off
                  27. OtherParents Off
                  28. OtherRelServStaff Off
                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

Assurances

Please provide the following assurances Select all that apply

Our LEA will provide IEP team members with additional training on the state guidelines for participation in the alternate assessment

Our LEA will continue to allow IEP team members to decide which students take an alternate assessment

Resources and Technical Assistance

What resources or technical assistance does your LEA need from your ISD or the MDE to ensure that students are being assessed using the appropriate state summative assessment tool

Submission Process

LEAs must send this completed form to their ISD director of special education no later than February 15 2018

The ISD director of special education will collect all LEA forms and submit to the state no later than March 9 2018

Questions

If you have any questions regarding this form please contact your ISD director of special education or contact John Jaquith at the MDE at JaquithJmichigangov

Michigan Department of Education Page 4

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 ESP 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 FRA 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 GRE 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 HEB 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 HRV 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020be44c988b2c8c2a40020bb38c11cb97c0020c548c815c801c73cb85c0020bcf4ace00020c778c1c4d558b2940020b3700020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200036002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS ltFEFF04180441043F043E043B044C043704430439044204350020044D044204380020043F043004400430043C043504420440044B0020043F0440043800200441043E043704340430043D0438043800200434043E043A0443043C0435043D0442043E0432002000410064006F006200650020005000440046002C0020043F043E04340445043E0434044F04490438044500200434043B044F0020043D0430043404350436043D043E0433043E0020043F0440043E0441043C043E044204400430002004380020043F043504470430044204380020043104380437043D04350441002D0434043E043A0443043C0435043D0442043E0432002E00200421043E043704340430043D043D044B043500200434043E043A0443043C0435043D0442044B00200050004400460020043C043E0436043D043E0020043E0442043A0440044B0442044C002C002004380441043F043E043B044C04370443044F0020004100630072006F00620061007400200438002000410064006F00620065002000520065006100640065007200200036002E00300020043B04380431043E00200438044500200431043E043B043504350020043F043E04370434043D043804350020043204350440044104380438002Egt13 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
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                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
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                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
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                  40. ResourceTA

APPENDIX F

Every Student Succeeds Act (ESSA) and the 1 Cap The MDE Guide for Intermediate School Districts (ISDs)

Revised 8417

1) A Brief History

The 2003 ESEA regulations placed a 1 cap on the percentage of the total tested student population that could count as proficient for accountability purposes from the alternate assessment based on alternate achievement standards This was not a cap on participation in the assessment

In 2015 with the passage of the Every Student Succeeds Act (ESSA) the requirements changed for the alternate assessment (based on alternate achievement standards) This act also officially eliminated an alternate assessment based on ldquomodifiedrdquo achievement standards

2) Michiganrsquos Approach to the 1 Cap

In addition ESSA reaffirmed that the alternate assessment is an appropriate assessment for students with the most significant cognitive disabilities to demonstrate their knowledge and skills but rather than placing a cap on accountability proficiency rates for the alternate assessment ESSA places a 1 cap on alternate assessment participation

This shift in policy means that states districts and schools need to consider carefully which students should be included in the alternate assessment as it is designed for students with the most significant cognitive impairments

A Understanding the Cap

bull The 1 cap on participation is imposed at the state level The state may not impose a cap on Intermediate School Districts (ISDs) or Local Education Agencies (LEAs) and ISDs may not impose a cap on LEAs

bull The ESSA language includes assurances regarding informing parents about the standards to which their childrsquos academic achievement will be measured and how participation in an alternate assessment may impact the studentrsquos completing requirements for a regular high school diploma

bull The Act continues to give final authority to the Individualized Education Program (IEP) team regarding decisions around which assessment is given to a student However the IEP team must follow the state guidelines for participation in the alternate assessment

bull LEAs that contribute to the state exceeding its participation cap (without having a direct cap imposed) must provide information to the state regarding why this is the case and the state must provide guidance and technical assistance to such agencies

ndash Rationale from each LEA regarding exceeding the cap will be collected and compiled by each ISD (Future guidance on how to submit this will be provided by MDE)

ndash The information compiled by each ISD will then be sent to the state

B Baseline and Waiver

bull Baseline Currently in Michigan approximately 23 of all students tested in Englishlanguage arts and mathematics are assessed using the alternate assessment (MI-Access) Please see the ldquoCalculating

1

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020be44c988b2c8c2a40020bb38c11cb97c0020c548c815c801c73cb85c0020bcf4ace00020c778c1c4d558b2940020b3700020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200036002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
                  20. GuideDocsRelServStaff Off
                  21. NoTrainAdmin Off
                  22. NoTrainSpecialEdStaff Off
                  23. NoTrainParents Off
                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
                  26. OtherSpecialEdStaff Off
                  27. OtherParents Off
                  28. OtherRelServStaff Off
                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

Formula

TSALT TSTIG rate divide =Guidelines

1 TSALT = Total number of students tested on the state alternate assessment (any level of MI-Access FI SI P) in grades 3 4 5 6 7 8 and 11 for the given content area

2 TSTIG = Total number of students tested on any state assessment in grades 3 4 5 6 7 8 and 11 for the given content area

3 Calculate for each EACH content area (Englishlanguage arts mathematics science)

4 Calculate for EACH LEA and ISD in a complete file sortablefilterable by ISD

Alternate Assessment Participation Ratesrdquo table at right This formula was used to calculate this current baseline

bull Waiver States will be provided the opportunity to request a waiver of the 1 cap The Michigan Department of Education (MDE) may consider participating in this option as it works with ISDs and local agencies to come into alignment with the requirements of the statute However the state must meet the following requirements

ndash Provide assurances that each LEA that exceeded the 1 participation cap followed the statersquos guidelines for participation in the assessment

ndash Address disproportionality in the percentage of students in any subgroup taking the assessment

ndash Provide a plan and timeline for meeting the 1 cap in future school years

ndash Request the waiver prior to the assessment window for which the waiver will apply

ndash Demonstrate that at least 95 of students in all subgroups have been assessed at the state level in the previous assessment year (or more as required by the US Department of Education)

C Review and Technical Assistance through ISDs

bull Data regarding participation rates for each ISD and LEA will be provided by MDE

bull ISDs are encouraged to share this information with each local agency and to walk locals through the process of calculating their own participation rates

using data to better understand how the rate is calculated Use the following calculation formula and guidelines

Calculating Alternate Assessment Participation Rates

bull Section 3 below presents guidance that is based on an April 2017 brief published by the National Center on Educational Outcomes It should be shared with all districts In addition ISDs should offer facilitated conversations and assistance to any LEAs exceeding the 1 participation cap

3) Strategies for meeting the 1 cap on participation in the state alternate assessment (MI-Access)

ISDs will facilitate and explore options with LEAs using LEA data

bull Gather district and school data on current participation rates for the alternate assessment

ndash Rates for participation will be provided by the state as a baseline

ndash Compare rates across schools and correspond such rates to programs being operated in each building

ndash Compare rates across grade levels

ndash ISDs will consider how to account for students attending center-based programs according to how those programs are administered within the ISD

2

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 DEU 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 ESP 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 ETI 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 FRA 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 GRE ltFEFF03A703C103B703C303B903BC03BF03C003BF03B903AE03C303C403B5002003B103C503C403AD03C2002003C403B903C2002003C103C503B803BC03AF03C303B503B903C2002003B303B903B1002003BD03B1002003B403B703BC03B903BF03C503C103B303AE03C303B503C403B5002003AD03B303B303C103B103C603B1002000410064006F006200650020005000440046002003BA03B103C403AC03BB03BB03B703BB03B1002003B303B903B1002003B103BE03B903CC03C003B903C303C403B7002003C003C103BF03B203BF03BB03AE002003BA03B103B9002003B503BA03C403CD03C003C903C303B7002003B503C003B103B303B303B503BB03BC03B103C403B903BA03CE03BD002003B503B303B303C103AC03C603C903BD002E0020002003A403B1002003AD03B303B303C103B103C603B10020005000440046002003C003BF03C5002003B803B1002003B403B703BC03B903BF03C503C103B303B703B803BF03CD03BD002003B103BD03BF03AF03B303BF03C503BD002003BC03B50020004100630072006F006200610074002003BA03B103B9002000410064006F00620065002000520065006100640065007200200036002E0030002003BA03B103B9002003BD03B503CC03C403B503C103B503C2002003B503BA03B403CC03C303B503B903C2002Egt13 HEB 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 HRV 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020be44c988b2c8c2a40020bb38c11cb97c0020c548c815c801c73cb85c0020bcf4ace00020c778c1c4d558b2940020b3700020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200036002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL ltFEFF004b006f0072007a0079007300740061006a010500630020007a00200074007900630068002000750073007400610077006900650144002c0020006d006f017c006e0061002000740077006f0072007a0079010700200064006f006b0075006d0065006e00740079002000410064006f00620065002000500044004600200070006f007a00770061006c0061006a01050063006500200077002000730070006f007300f300620020006e00690065007a00610077006f0064006e0079002000770079015b0077006900650074006c00610107002000690020006400720075006b006f00770061010700200064006f006b0075006d0065006e007400790020006600690072006d006f00770065002e00200020005500740077006f0072007a006f006e006500200064006f006b0075006d0065006e0074007900200050004400460020006d006f017c006e00610020006f007400770069006500720061010700200077002000700072006f006700720061006d0061006300680020004100630072006f00620061007400200069002000410064006f0062006500200052006500610064006500720020007700200077006500720073006a006900200036002e00300020006f00720061007a002000770020006e006f00770073007a00790063006800200077006500720073006a00610063006800200074007900630068002000700072006f006700720061006d00f30077002e004b006f0072007a0079007300740061006a010500630020007a00200074007900630068002000750073007400610077006900650144002c0020006d006f017c006e0061002000740077006f0072007a0079010700200064006f006b0075006d0065006e00740079002000410064006f00620065002000500044004600200070006f007a00770061006c0061006a01050063006500200077002000730070006f007300f300620020006e00690065007a00610077006f0064006e0079002000770079015b0077006900650074006c00610107002000690020006400720075006b006f00770061010700200064006f006b0075006d0065006e007400790020006600690072006d006f00770065002e00200020005500740077006f0072007a006f006e006500200064006f006b0075006d0065006e0074007900200050004400460020006d006f017c006e00610020006f007400770069006500720061010700200077002000700072006f006700720061006d0061006300680020004100630072006f00620061007400200069002000410064006f0062006500200052006500610064006500720020007700200077006500720073006a006900200036002e00300020006f00720061007a002000770020006e006f00770073007a00790063006800200077006500720073006a00610063006800200074007900630068002000700072006f006700720061006d00f30077002egt13 PTB 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 RUM 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 RUS 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 SKY ltFEFF0054006900650074006f0020006e006100730074006100760065006e0069006100200073006c00fa017e006900610020006e00610020007600790074007600e100720061006e0069006500200064006f006b0075006d0065006e0074006f007600200076006f00200066006f0072006d00e100740065002000410064006f006200650020005000440046002c0020006b0074006f007200e90020007300fa002000760068006f0064006e00e90020006e0061002000730070006f013e00610068006c0069007600e90020007a006f006200720061007a006f00760061006e006900650020006100200074006c0061010d0020006f006200630068006f0064006e00fd0063006800200064006f006b0075006d0065006e0074006f0076002e002000200056007900740076006f00720065006e00e900200064006f006b0075006d0065006e0074007900200076006f00200066006f0072006d00e10074006500200050004400460020006a00650020006d006f017e006e00e90020006f00740076006f00720069016500200076002000700072006f006700720061006d00650020004100630072006f0062006100740020006100200076002000700072006f006700720061006d0065002000410064006f006200650020005200650061006400650072002c0020007600650072007a0069006900200036002e003000200061006c00650062006f0020006e006f007601610065006a002egt13 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 UKR 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documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
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                  30. FactorsIEPTeamKnowl Off
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                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
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                  40. ResourceTA

bull Provide professional development for IEP team members and other educators on the nature of the alternate assessment and who should participate in it

ndash Provide targeted professional development for LEAs exceeding the 1 cap

ndash Facilitate conversations with parents regarding the implications of a studentrsquos instructional path that may include an alternate assessment which may result in the student potentially not meeting requirements for a regular high school diploma

ndash ISDs may consider eliciting the assistance of MDE for larger scale professional development (Contact baamichigangov with the subject ldquoProfessional Development Request Alternate Assessmentsrdquo)

bull Provide informational sessions for parents of students with disabilities so that they can participate in the IEP decision-making process about assessment participation

ndash Training on Michiganrsquos alternate content expectations

ǿ What they are

ǿ Instructional implications

ǿ Implications on the impact of a student completing requirements for a general high school diploma

ndash Training on MI-Access

ǿ Characteristics of students who typically take this assessment

ǿ Understanding all state assessment options and how this fits into local assessment practices

ǿ Understanding the participation guidance document

bull Review the current assessment selection guidance document on the use of MI-Access

ndash Determine if current IEP team practice aligns with assessment selection guidance

ndash Provide professional development to IEP teams regarding assessment selection and the use of MI-Access

bull Gather data on the characteristics of students participating in the alternate assessment

ndash While the following factors are not a part of the decision process for selecting an alternate assessment trends should be explored regarding the rates across

ǿ Eligibility

ǿ Placementprogram

ndash Compare characteristics of students participating in the alternate assessment against the assessment selection guidance document

bull Review local policies surrounding use of the alternate assessment

ndash Determine if there are any local written or unwritten policies regarding participation in MI-Access

ǿ Are any such policies or practices in conflict with Michiganrsquos assessment selection guidance on the alternate assessment

ndash Determine the local practice on assessment guidance and determine

ǿ whether guidance has been implemented appropriately

ǿ whether local policy or practices need to be revised and

ǿ whether training needs for teachers and IEP team members have been considered

(Source Strategies for Meeting the 1 State-Level Cap on Alternate Assessment Participation NCEO Brief Number 12 April 2017 httpsnceoumnedudocsOnlinePubsNCEOBrief12OnePercentCappdf )

3

RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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RICK SNYDER GOVERNOR

January 9 2018

STATE OF MICHIGAN DEPARTMENT OF EDUCATION

LANSING

Jason Batel Principal Deputy Assistant Secretary Office of Elementary and Secondary Education US Department of Education 400 Maryland Ave SW Washington DC 20202 jasonboteledgov

Dear Mr Batel

BRIAN J WHISTON STATE SUPERINTENDENT

The Every Student Succeeds Act (ESSA) amended a provision of Title I of the Elementary and Secondary Education Act of 1965 related to students participating in alternate assessments of each State Education Agencys (SEAs) statewide assessment The ESSA requires SEAs to submit waiver requests to the United States Department of Education in the event they expect more than 1 of their students tested in a given content area and will participate in the states alternate assessment

The Michigan Department of Education (MOE) has conducted an extensive review of data from Michigans statewide assessments in 2016 - 2017 The purpose of the review was to determine the participation rates of students taking the alternate assessments aligned with alternate academic achievement standards (AA- AAAS) better known as MI-Access

The data revealed that an average of 24 percent of Michigan students participated in each of the content areas included on MI-Access in 2016 - 2017 Table 1 listed below displays participation rates by subject for the 2016 - 2017 MI-Access assessment Based on the data the state anticipates exceeding the 1 threshold enacted by the ESSA for school year 2017 - 2018

STATE BOARD OF EDUCATION

CASANDRA E ULBRICH - CO-PRESIDENT bull RICHARD ZEILE - CO-PRESIDENT MICHELLE FECTEAU- SECRETARY bull TOM MCMILLIN - TREASURER

NIKKI SNYDER- NASBE DELEGATE bull PAMELA PUGH LUPE RAMOS-MONTIGNY bull EILEEN LAPPIN WEISER

608 WEST ALLEGAN STREET bull PO BOX 30008 bull LANSING MICHIGAN 48909 wwwmlchlgangovmde bull 517-373middot3324

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020be44c988b2c8c2a40020bb38c11cb97c0020c548c815c801c73cb85c0020bcf4ace00020c778c1c4d558b2940020b3700020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200036002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR ltFEFF004200720075006b00200064006900730073006500200069006e006e007300740069006c006c0069006e00670065006e0065002000740069006c002000e50020006f0070007000720065007400740065002000410064006f006200650020005000440046002d0064006f006b0075006d0065006e00740065007200200073006f006d002000650072002000650067006e0065007400200066006f00720020007000e5006c006900740065006c006900670020007600690073006e0069006e00670020006f00670020007500740073006b007200690066007400200061007600200066006f0072007200650074006e0069006e006700730064006f006b0075006d0065006e007400650072002e0020005000440046002d0064006f006b0075006d0065006e00740065006e00650020006b0061006e002000e50070006e00650073002000690020004100630072006f00620061007400200065006c006c00650072002000410064006f00620065002000520065006100640065007200200036002e003000200065006c006c00650072002egt13 POL 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PTB 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 RUM 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 RUS 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 SKY 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 SLV ltFEFF005400650020006E006100730074006100760069007400760065002000750070006F0072006100620069007400650020007A00610020007500730074007600610072006A0061006E006A006500200064006F006B0075006D0065006E0074006F0076002000410064006F006200650020005000440046002C0020007000720069006D00650072006E006900680020007A00610020007A0061006E00650073006C006A006900760020006F0067006C0065006400200069006E0020007400690073006B0061006E006A006500200070006F0073006C006F0076006E0069006800200064006F006B0075006D0065006E0074006F0076002E0020005500730074007600610072006A0065006E006500200064006F006B0075006D0065006E0074006500200050004400460020006A00650020006D006F0067006F010D00650020006F00640070007200650074006900200073002000700072006F006700720061006D006F006D00610020004100630072006F00620061007400200069006E002000410064006F00620065002000520065006100640065007200200036002E003000200074006500720020006E006F00760065006A01610069006D0069002Egt13 SUO 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
                  20. GuideDocsRelServStaff Off
                  21. NoTrainAdmin Off
                  22. NoTrainSpecialEdStaff Off
                  23. NoTrainParents Off
                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
                  26. OtherSpecialEdStaff Off
                  27. OtherParents Off
                  28. OtherRelServStaff Off
                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA

Page 2 January 9 2018

Table 1 2016 - 2017 Participation in Alternate Assessment MI+Access by content

Content Number of Students Number of students Percent of students participating in

alternate participating in

statewide participating in

alternate

English Language Arts

assessment (Ml-Access)

18830

summative assessments (M-

STEPMichigan Merit Exam MI-Access)

771950

assessment (Mlmiddot Access)

24 (Grades 3-8 and 11)

Mathematics (Grades 3-8 and 11) 18421 773767 24

Science (Grades 4 7 and

11) 7747 335091 23

Table 2 2016 - 2017 Total Students tested using state summative assessment ( M-STEP MME MlshyAccess) by content

Content Number of students Number of students Percent of total participating in

statewide expected to test in

statewide students tested

summative summative assessments (M- assessments (M-

STEPMichigan Merit Exam Ml-Access)

STEPMichigan Merit Exam MI-Access)

English Language 769087 782421 9830 Arts

(Grades 3-8 and 11) Mathematics 771390 782421 9859

(Grades 3-8 and 11) Science 332390 340032 9775

(Grades 4 7 and 11)

Pursuant to 34 CFR sect 2006(c)(4) MOE is seeking a waiver for all subject areas for the 2017 - 2018 school year from the Secretary of the United States Department of Education The 2017 - 2018 testing window for the alternate assessment MI-Access is from April 9 2018 through May 25 2018 The purpose of requesting this waiver is to acknowledge our baseline and to describe our plan to ensure that students are held to high academic standards and that students are being assessed using the assessment tools that are most appropriate to each student

Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

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Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

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bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

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assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

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demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

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bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

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httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

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The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 GRE 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 HEB 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 HRV 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL 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 PTB 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RUM 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 RUS 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 SKY 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 SLV 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 SUO 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Page 3 January 9 2018

Input from MDEs Assessment of Students with Disabilities Advisory Committee was obtained and included in the creation of this waiver and plan Feedback included the importance of including the following information

bull The current state participation rates bull Consideration of the percentage of students identified with a cognitive

impairment within a specific county and within the state bull A consideration that Michigan has long been committed to assessing all

students regardless of ability or disability and that we do not offer exemptions to certain populations of students

bull For English Language Arts and Mathematics Michigan has adopted rigorous alternate content standards based on the Essential Elements developed by the Dynamic Learning Maps Consortia of which Michigan was a part of developing

bull Social Studies alternate content standards are aligned to the general Michigan content standards and new alternate content standards in science are currently being developed to align with recent changes to the general science content standards and

bull Michigan emphasizes that decisions regarding assessment selection are a local Individualized Education Program (IEP) team decision

Additional feedback included the following suggestions for local education agencies (LEAs) to include in their examination of their data on participation rates

bull Identify students that are being taught to general content standards but taking an alternate assessment

bull Identify the use of the state guidelines for participation in the alternate assessment as well as training provided to staff on assessment selection the alternate content standards and the alternate assessment

bull Identify how many students enroll in schools outside of their resident district The districts serving these students should not be penalized for providing service to students who choose them and therefore increase special education numbers and

bull LEAs operating center-based programs for students with significant cognitive impairments that are open to students regionally should have their participation rates looked at from a variety of perspectives including examining rates with and without resident district students included

PUBLIC COMMENT

MOE communicated to the public its intent to file a waiver for the 1 cap on alternate assessment participation This communication was sent from our state superintendent to local and intermediate school district superintendents and publicshyschool academy directors with a copy to the Michigan Education Alliance In addition the communication was sent to all intermediate school district (SD) Local Education

Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 DEU 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 ESP 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 FRA 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 GRE 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 HEB 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 HRV 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020be44c988b2c8c2a40020bb38c11cb97c0020c548c815c801c73cb85c0020bcf4ace00020c778c1c4d558b2940020b3700020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200036002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL 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 PTB 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                  1. Date
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Page 4 January 9 2018

Agency (LEA) and public-school academy (PSA) special education directors as a state-wide press release and as a memo to Family Matters Michigan Alliance for Families and the Special Education Advisory Committee An article in our state-wide newsletter regarding student assessments provided a link to the communication and it was also posted on the Office of Special Education MI-Access and the general assessment websites The memo is provided as Appendix A Public comment opened on November 15 2017 and closed on December 20 2017 which provided to the public a similar window to other MOE surveys

Michigan had 36 total respondents who provided comments on the following openshyended opportunities found in the survey

1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24dego Mathematics 23 Science) (36 responses)

2 Please comment on what should be included in the plan and timeline for improvement (34 responses)

3 Other comments (25 responses)

Summary results and responses are as follows (For full details see Appendix B)

PROMPT 1 Please comment on Michigans current rate of participation in the alternate assessment (24 English Language Arts 24 Mathematics 23 Science)

bull Comments were primarily in defense of Michigans current participation rate citing beliefs that more than 1 of students function as if they have a cognitive impairment alternate assessment participation should be based on student needs and is an IEP team decision the belief that Michigan assesses more students than other states concern that putting students who now take the alternate assessment into the regular assessment will be detrimental to the individuals Because of these thoughts many commented that districts should not be punished for being over 1

Response Evidence signifies that most states also assess ALL students Although there are a variety of data sets that can be considered to provide research and documentation regarding the validity of a 1 cap the State of Michigan is required to follow federal guidance and reporting requirements Michigan underscores that the practice ofIEP teams determining alternate assessment participation continues to be the expectation The MDE will continue to work with all districts to ensure IEP teams have the proper training and tools to make appropriate decisions

Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e55464e1a65876863768467e5770b548c62535370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc666e901a554652d965874ef6768467e5770b548c52175370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 ESP 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 HEB 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
                  20. GuideDocsRelServStaff Off
                  21. NoTrainAdmin Off
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                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
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Page 5 January 9 2018

bull Comments included concern for districts being punished when providing programming to or assessing students with cognitive impairments

Response There is no penalty for an SD LEA or PSA who exceeds the 1 cap Justification is required from the district so the SD and MDE can determine if technical assistance is needed to ensure students take the appropriate assessment The department is aware of district programming variations and have provided consideration of that factor in the justification form for districts who exceed the 1 cap

bull One commenter asked the question do we have consistency from district to district with the definition of severe cognitive impairment

Response Michigan provides cognitive impairment eligibility guidance in R 3401705 but has not defined what is meant by functioning as if heshe has a significant cognitive impairment for the purposes of assessment consideration

bull One commenter questioned all decisions made regarding students with disabilities and whether this waiver reduces expectations

Response The department is working to substantiate that the decision-making tool is utilized by all IEP teams to ensure that students academic competences are being measured with the appropriate assessment tool MDE is committed to reinforcing high standards and providing aligned assessments for all students

PROMPT 2 Please comment on what should be included in the plan and timeline for improvement

bull Twenty-five comments were general and did not provide input regarding what should be included in a plan to address Michigan exceeding the 1 cap

bull Sixteen comments provided input such as creating online professional development providing a clear definition of a significant cognitive impairment making sure staff have access to decision making tools focusing on appropriateness of those students taking the functional independence assessment making sure staff understand the purpose of alternate assessments and more

Response All the ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define significant cognitive impairment relating to participation in the alternate

Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
                • ltlt13 ASCII85EncodePages false13 AllowTransparency false13 AutoPositionEPSFiles true13 AutoRotatePages All13 Binding Left13 CalGrayProfile (Gray Gamma 22)13 CalRGBProfile (sRGB IEC61966-21)13 CalCMYKProfile (US Web Coated 050SWOP051 v2)13 sRGBProfile (sRGB IEC61966-21)13 CannotEmbedFontPolicy Warning13 CompatibilityLevel 1513 CompressObjects All13 CompressPages true13 ConvertImagesToIndexed true13 PassThroughJPEGImages true13 CreateJobTicket false13 DefaultRenderingIntent Default13 DetectBlends true13 DetectCurves 0100013 ColorConversionStrategy sRGB13 DoThumbnails false13 EmbedAllFonts true13 EmbedOpenType false13 ParseICCProfilesInComments true13 EmbedJobOptions false13 DSCReportingLevel 013 EmitDSCWarnings false13 EndPage -113 ImageMemory 104857613 LockDistillerParams false13 MaxSubsetPct 10013 Optimize true13 OPM 113 ParseDSCComments true13 ParseDSCCommentsForDocInfo true13 PreserveCopyPage true13 PreserveDICMYKValues true13 PreserveEPSInfo false13 PreserveFlatness true13 PreserveHalftoneInfo false13 PreserveOPIComments false13 PreserveOverprintSettings true13 StartPage 113 SubsetFonts true13 TransferFunctionInfo Apply13 UCRandBGInfo Remove13 UsePrologue false13 ColorSettingsFile ()13 AlwaysEmbed [ true13 ]13 NeverEmbed [ true13 Arial-Black13 Arial-BlackItalic13 Arial-BoldItalicMT13 Arial-BoldMT13 Arial-ItalicMT13 ArialMT13 ArialNarrow13 ArialNarrow-Bold13 ArialNarrow-BoldItalic13 ArialNarrow-Italic13 CenturyGothic13 CenturyGothic-Bold13 CenturyGothic-BoldItalic13 CenturyGothic-Italic13 CourierNewPS-BoldItalicMT13 CourierNewPS-BoldMT13 CourierNewPS-ItalicMT13 CourierNewPSMT13 Georgia13 Georgia-Bold13 Georgia-BoldItalic13 Georgia-Italic13 Impact13 LucidaConsole13 Tahoma13 Tahoma-Bold13 TimesNewRomanMT-ExtraBold13 TimesNewRomanPS-BoldItalicMT13 TimesNewRomanPS-BoldMT13 TimesNewRomanPS-ItalicMT13 TimesNewRomanPSMT13 Trebuchet-BoldItalic13 TrebuchetMS13 TrebuchetMS-Bold13 TrebuchetMS-Italic13 Verdana13 Verdana-Bold13 Verdana-BoldItalic13 Verdana-Italic13 ]13 AntiAliasColorImages false13 CropColorImages true13 ColorImageMinResolution 15013 ColorImageMinResolutionPolicy OK13 DownsampleColorImages true13 ColorImageDownsampleType Bicubic13 ColorImageResolution 15013 ColorImageDepth -113 ColorImageMinDownsampleDepth 113 ColorImageDownsampleThreshold 15000013 EncodeColorImages true13 ColorImageFilter DCTEncode13 AutoFilterColorImages true13 ColorImageAutoFilterStrategy JPEG13 ColorACSImageDict ltlt13 QFactor 07613 HSamples [2 1 1 2] VSamples [2 1 1 2]13 gtgt13 ColorImageDict ltlt13 QFactor 07613 HSamples [2 1 1 2] VSamples [2 1 1 2]13 gtgt13 JPEG2000ColorACSImageDict ltlt13 TileWidth 25613 TileHeight 25613 Quality 1513 gtgt13 JPEG2000ColorImageDict ltlt13 TileWidth 25613 TileHeight 25613 Quality 1513 gtgt13 AntiAliasGrayImages false13 CropGrayImages true13 GrayImageMinResolution 15013 GrayImageMinResolutionPolicy OK13 DownsampleGrayImages true13 GrayImageDownsampleType Bicubic13 GrayImageResolution 15013 GrayImageDepth -113 GrayImageMinDownsampleDepth 213 GrayImageDownsampleThreshold 15000013 EncodeGrayImages true13 GrayImageFilter DCTEncode13 AutoFilterGrayImages true13 GrayImageAutoFilterStrategy JPEG13 GrayACSImageDict ltlt13 QFactor 07613 HSamples [2 1 1 2] VSamples [2 1 1 2]13 gtgt13 GrayImageDict ltlt13 QFactor 07613 HSamples [2 1 1 2] VSamples [2 1 1 2]13 gtgt13 JPEG2000GrayACSImageDict ltlt13 TileWidth 25613 TileHeight 25613 Quality 1513 gtgt13 JPEG2000GrayImageDict ltlt13 TileWidth 25613 TileHeight 25613 Quality 1513 gtgt13 AntiAliasMonoImages false13 CropMonoImages true13 MonoImageMinResolution 120013 MonoImageMinResolutionPolicy OK13 DownsampleMonoImages true13 MonoImageDownsampleType Bicubic13 MonoImageResolution 120013 MonoImageDepth -113 MonoImageDownsampleThreshold 15000013 EncodeMonoImages true13 MonoImageFilter CCITTFaxEncode13 MonoImageDict ltlt13 K -113 gtgt13 AllowPSXObjects true13 CheckCompliance [13 None13 ]13 PDFX1aCheck false13 PDFX3Check false13 PDFXCompliantPDFOnly false13 PDFXNoTrimBoxError true13 PDFXTrimBoxToMediaBoxOffset [13 00000013 00000013 00000013 00000013 ]13 PDFXSetBleedBoxToMediaBox true13 PDFXBleedBoxToTrimBoxOffset [13 00000013 00000013 00000013 00000013 ]13 PDFXOutputIntentProfile ()13 PDFXOutputConditionIdentifier ()13 PDFXOutputCondition ()13 PDFXRegistryName ()13 PDFXTrapped False1313 CreateJDFFile false13 Description ltlt13 ARA ltFEFF0633062A062E062F0645002006470630064700200627064406250639062F0627062F0627062A002006440625064606340627062100200648062B062706260642002000410064006F006200650020005000440046002006450646062706330628062900200644063906310636002006480637062806270639062900200648062B06270626064200200627064406230639064506270644002E00200020064A06450643064600200641062A062D00200648062B0627062606420020005000440046002006270644062A064A0020062A0645002006250646063406270626064706270020062806270633062A062E062F062706450020004100630072006F00620061007400200648002000410064006F00620065002000520065006100640065007200200036002E00300020064806450627002006280639062F0647002Egt13 BGR 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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e55464e1a65876863768467e5770b548c62535370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc666e901a554652d965874ef6768467e5770b548c52175370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU ltFEFF00560065007200770065006e00640065006e0020005300690065002000640069006500730065002000450069006e007300740065006c006c0075006e00670065006e0020007a0075006d002000450072007300740065006c006c0065006e00200076006f006e002000410064006f006200650020005000440046002d0044006f006b0075006d0065006e00740065006e002c00200075006d002000650069006e00650020007a0075007600650072006c00e40073007300690067006500200041006e007a006500690067006500200075006e00640020004100750073006700610062006500200076006f006e00200047006500730063006800e40066007400730064006f006b0075006d0065006e00740065006e0020007a0075002000650072007a00690065006c0065006e002e00200044006900650020005000440046002d0044006f006b0075006d0065006e007400650020006b00f6006e006e0065006e0020006d006900740020004100630072006f00620061007400200075006e0064002000520065006100640065007200200036002e003000200075006e00640020006800f600680065007200200067006500f600660066006e00650074002000770065007200640065006e002egt13 ESP ltFEFF005500740069006c0069006300650020006500730074006100200063006f006e0066006900670075007200610063006900f3006e0020007000610072006100200063007200650061007200200064006f00630075006d0065006e0074006f0073002000640065002000410064006f00620065002000500044004600200061006400650063007500610064006f007300200070006100720061002000760069007300750061006c0069007a00610063006900f3006e0020006500200069006d0070007200650073006900f3006e00200064006500200063006f006e006600690061006e007a006100200064006500200064006f00630075006d0065006e0074006f007300200063006f006d00650072006300690061006c00650073002e002000530065002000700075006500640065006e00200061006200720069007200200064006f00630075006d0065006e0074006f00730020005000440046002000630072006500610064006f007300200063006f006e0020004100630072006f006200610074002c002000410064006f00620065002000520065006100640065007200200036002e003000200079002000760065007200730069006f006e0065007300200070006f00730074006500720069006f007200650073002egt13 ETI 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 FRA 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 GRE ltFEFF03A703C103B703C303B903BC03BF03C003BF03B903AE03C303C403B5002003B103C503C403AD03C2002003C403B903C2002003C103C503B803BC03AF03C303B503B903C2002003B303B903B1002003BD03B1002003B403B703BC03B903BF03C503C103B303AE03C303B503C403B5002003AD03B303B303C103B103C603B1002000410064006F006200650020005000440046002003BA03B103C403AC03BB03BB03B703BB03B1002003B303B903B1002003B103BE03B903CC03C003B903C303C403B7002003C003C103BF03B203BF03BB03AE002003BA03B103B9002003B503BA03C403CD03C003C903C303B7002003B503C003B103B303B303B503BB03BC03B103C403B903BA03CE03BD002003B503B303B303C103AC03C603C903BD002E0020002003A403B1002003AD03B303B303C103B103C603B10020005000440046002003C003BF03C5002003B803B1002003B403B703BC03B903BF03C503C103B303B703B803BF03CD03BD002003B103BD03BF03AF03B303BF03C503BD002003BC03B50020004100630072006F006200610074002003BA03B103B9002000410064006F00620065002000520065006100640065007200200036002E0030002003BA03B103B9002003BD03B503CC03C403B503C103B503C2002003B503BA03B403CC03C303B503B903C2002Egt13 HEB 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 HRV 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020be44c988b2c8c2a40020bb38c11cb97c0020c548c815c801c73cb85c0020bcf4ace00020c778c1c4d558b2940020b3700020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200036002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
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Page 6 January 9 2018

assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1 cap

PROMPT 3 Other comments bull There were twenty-five additional comments of varying types most of which

were similar in nature to the comments for prompts 1 and 2

Response All ideas will be considered when creating the plan MDE is reminding the commenters that although the state will look at the percentages of students identified with a cognitive impairment and will work to define nsignificant cognitive impairment relating to participation in the alternate assessment the State of Michigan is required to follow federal guidance and reporting requirements specific to the 1degA cap

DISPROPORTIONATE REPRESENTATION IN ALTERNATE ASSESSMENT PARTICIPATION

Michigan examined disproportionality regarding participation in the state alternate assessment (MI-Access) for the following demographics

1) Gender a Male b Female

2) Economically disadvantaged (based on poverty risk factors such as free and reduced lunch eligibility homelessness migrant status and direct certification for government food assista nee)

a Disadvantaged b Not Disadvantaged

3) RacialEthnic groups a Native American b Asian c African American or Black d Pacific Islander e Hispanic f White g Two or more races

4) English Language Learners status a Participation in a Learning English Program b Non-participation in a Learning English Program

To determine if substantive disproportionality of students occurred Michigan uses a Relative Risk Ratio method to analyze the rate of participation in alternate assessments For other federal reporting (ie in the Annual Performance Report) Michigan uses multiple years of data and a threshold Risk Ratio of 25 for each

Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e55464e1a65876863768467e5770b548c62535370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc666e901a554652d965874ef6768467e5770b548c52175370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 ESP 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 FRA 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 GRE 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 HEB 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
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                  8. Justification Off
                  9. F2FAdmin Off
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Page 7 January 9 2018

demographic subgroup For assessments this threshold means students in one demographic subgroup are participating in the alternate assessment at a rate of 2Y2 times more often than students who are not in that demographic A relative Risk Ratio of 10 means that students in one demographic participate in the alternate assessment at the same rate as students who are not in that demographic

For each assessment content area (English Language Arts Math and Science) Michigan examined 3 years of test participation aggregated to improve reliability of the analyses (especially in cases where districts have smaller numbers of students) These findings will be shared with ISDs and districts to review as part of their general guidance and ISO staff will be trained to identify and target districts with substantively high disproportionate representation in alternate assessment participation Statewide Michigan has identified one demographic (ie the economically disadvantaged) for which we find some elevated Risk Ratios See Table 3 - 5 for statewide results

Table 3 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for English Language Art

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

315 VS 168

Risk Ratio

187 Economic Disadvantaged English Language Learner

Race

Native American

345 vs 149 236 vs 244

Group Rate Comparison (In-group vs not)

341 vs 241

232 097

Risk Ratio

140 Asian 131 vs 247 053 African American 375 vs 216 174 Pacific Islander 305 vs 243 125 Hispanic White

233 vs 244 216 VS 301

096 072

Two or More Races 225 vs 244 092

Table 4 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Math

Gender Group Rate Comparison

(In-group vs not) Risk Ratio

Male vs Female 305 vs 167 183 Economic Disadvantaged 335 vs 146 229 English Language Learner 219 vs 239 092

Race Group Rate Comparison

(In-group vs not) Risk Ratio

Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e55464e1a65876863768467e5770b548c62535370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc666e901a554652d965874ef6768467e5770b548c52175370300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200036002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 ESP 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 HEB 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR 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 NLD (Gebruik deze instellingen om Adobe 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                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
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                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
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                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
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Page 8 January 9 2018

Gender

Native American

Group Rate Comparison (In-group vs not)

325 vs 243

Risk Ratio

134 Asian 124 vs 248 050

African American 368 vs 217 169

Pacific Islander 317 vs 243 130

Hispanic White

224 vs 245 211 vs 313

092 067

Two or More Races 221 VS 244 091

Table 5 Disproportionate Alternate Assessment Participation by Demography (3-year aggregate) for Science

Gender

Male vs Female

Group Rate Comparison (In-group vs not)

298 vs 162

Risk Ratio

184 Economic Disadvantaged English Language Learner

Race

Native American

333 vs 144 228 vs 231

Group Rate Comparison (In-group vs not)

312 vs 243

232 098

Risk Ratio

128 Asian 120 vs 245 049 African American 356 vs 235 152 Pacific Islander 310 vs 243 128 Hispanic White

2 21 vs 244 207 vs 259

090 080

Two or More Races 2 14 vs 244 088 Risk Ratlo ~ 20 Risk Ratio ~ 25 = = Note Data examined alternate assessment participation rates aggregated over 3 years (School Years 2014 - 2015 2015 - 2016 2016 - 2017) Relative Rlsk Ratios of 250 or above are consJdered disproportionately high representation among students taking the alternate assessment

GUIDELINES FOR PARTICIPATION

Michigans guidelines for IEP teams to use in determining which assessment a students should be taking can be found here and in Appendix C http wwwmich igan gov docu mentsmdeShould_My _Student_ Take_the_Alternate_ Assessment_556705_7 pdf

I n addition to making this document publicly available professional development has been provided by MDE over the course of the past year from the Office of Educational Assessment and Accountability and the Office of Special Education in the following venues

Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 ITA (Utilizzare 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Page 9 January 9 2018

bull The Michigan State Testing Conference in February 2017 bull MI Council for Exceptional Children Conference March 2017 bull MI-Access Test Administration webcast March 2017 bull Mi-Access Standard Setting July and August 2017 bull Michigan Association of Administrators of Special Education Summer

Conference August 2017 bull Multiple articles appearing in the MOE eNewsletter Spotlight on Student

Assessment bull Michigan Association of Administrators of Special Education fall meeting

December 2017

PLAN FOR IMPROVEMENT

The Michigan Department of Education will partner with each ISO in Michigan to implement a plan to address the 1 cap ISOs divide the state into smaller regions and serve a variety of oversight and services to LEAs and PSAs There are approximately 56 ISDs 546 LEAs and 297 PSAs in Michigan As sub-recipients of IDEA federal funding part of the ISO responsibility under R 3401839 of the Michigan Administrative Rules for Special Education includes

Each ISO shall implement monitoring procedures and evaluation methods developed by the department to ensure that the standards and criteria established are being achieved by the ISO their constituent LEAs and their PSAs

MOE will bull Provide each ISO with both ISO summary and LEAPSA data regarding

participation rates for students taking MI-Access Data will be updated and reshydistributed as it becomes available for each test administration cycle (a sample can be found in Appendix D)

bull Provide a justification form for districts that currently exceed the 1 participation rate to provide feedback to the ISO and MDE regarding why this is the case and any plans they have to provide training to IEP teams (see Appendix E)

bull Provide guidance for holding discussions and data review for LEAs on the 1dego cap This guidance will be updated as MOE receives and responds to the data from each ISO LEA and PSA For example future versions will include addressing disproportionate representation in alternate assessment participation The current guidance Every Student Succeeds Act (ESSA) and the 1 GAP The MOE Guide for Intermediate School Districts (ISO) document is found in Appendix F and at the website below

Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR 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                  1. Date
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Page 10 January 9 2018

httpwwwmichigangovdocumentsmde1_Cap_Guidance_for_ISDs_595801

_7pdf

bull Develop a template for collecting LEA level data for ISDs to use in structuring

support and technical assistance

bull Provide state level training that will include but is not limited to

o Online accessible training on the assessment selection guidance

for special education staff and IEP team members

o In person training on assessment selection assessment supports

and accommodations and understanding alternate content

standards (various state conferences) and

o Continued training modules on supports and accommodations for

all Michigan assessments

bull Work with interested parties to further define what it means in consideration

of alternate assessment participation for a student to function as if they have

a significant cognitive impairment and

bull Consider other technical assistance activities as gleaned throughout the

process

In partnership with MDE each ISD will

bull Review the data of each LEA regarding the current participation rate for

students taking MI-Access

bull Collect justification forms and additional information as needed from any

district that has a participation rate over 1

bull Structure support and technical assistance to districts based on their current

rate of participation identified needs and additional information provided by

the district

o Focus will be on training for IEP team members on assessment

selection decisions including but not limited tobull Assessment selection guidelines

bull Characteristics of adaptive behavior as outlined in assessment

selection guidelinesbull Review of current alternate content standards in English

Language Arts Mathematics Science and Social Studies

bull Potential implication for a student earning a regular high school

diploma when a path of alternate content standards and

assessment is chosen

bull Provide the IS Ds participation rate and justification if over the 1 CAP and

bull Provide an 15D level summary of technical assistance for LEA PSA and 15D

program staff to address strict adherence to the assessment selection

guidance and related topics

Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 ESP 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 ETI ltFEFF004b00610073007500740061006700650020006e0065006900640020007300e400740074006500690064002c0020006500740020006c0075007500610020005000440046002d0064006f006b0075006d0065006e00740065002c0020006d0069007300200073006f00620069007600610064002000e4007200690064006f006b0075006d0065006e00740069006400650020007500730061006c006400750073007600e400e4007200730065006b0073002000760061006100740061006d006900730065006b00730020006a00610020007000720069006e00740069006d006900730065006b0073002e00200020004c006f006f0064007500640020005000440046002d0064006f006b0075006d0065006e0074006500200073006100610062002000610076006100640061002000760061006900640020004100630072006f0062006100740020006a0061002000410064006f00620065002000520065006100640065007200200036002e00300020006a00610020007500750065006d006100740065002000760065007200730069006f006f006e00690064006500670061002egt13 FRA 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 GRE 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 HEB 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 HRV 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020be44c988b2c8c2a40020bb38c11cb97c0020c548c815c801c73cb85c0020bcf4ace00020c778c1c4d558b2940020b3700020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200036002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL ltFEFF004b006f0072007a0079007300740061006a010500630020007a00200074007900630068002000750073007400610077006900650144002c0020006d006f017c006e0061002000740077006f0072007a0079010700200064006f006b0075006d0065006e00740079002000410064006f00620065002000500044004600200070006f007a00770061006c0061006a01050063006500200077002000730070006f007300f300620020006e00690065007a00610077006f0064006e0079002000770079015b0077006900650074006c00610107002000690020006400720075006b006f00770061010700200064006f006b0075006d0065006e007400790020006600690072006d006f00770065002e00200020005500740077006f0072007a006f006e006500200064006f006b0075006d0065006e0074007900200050004400460020006d006f017c006e00610020006f007400770069006500720061010700200077002000700072006f006700720061006d0061006300680020004100630072006f00620061007400200069002000410064006f0062006500200052006500610064006500720020007700200077006500720073006a006900200036002e00300020006f00720061007a002000770020006e006f00770073007a00790063006800200077006500720073006a00610063006800200074007900630068002000700072006f006700720061006d00f30077002e004b006f0072007a0079007300740061006a010500630020007a00200074007900630068002000750073007400610077006900650144002c0020006d006f017c006e0061002000740077006f0072007a0079010700200064006f006b0075006d0065006e00740079002000410064006f00620065002000500044004600200070006f007a00770061006c0061006a01050063006500200077002000730070006f007300f300620020006e00690065007a00610077006f0064006e0079002000770079015b0077006900650074006c00610107002000690020006400720075006b006f00770061010700200064006f006b0075006d0065006e007400790020006600690072006d006f00770065002e00200020005500740077006f0072007a006f006e006500200064006f006b0075006d0065006e0074007900200050004400460020006d006f017c006e00610020006f007400770069006500720061010700200077002000700072006f006700720061006d0061006300680020004100630072006f00620061007400200069002000410064006f0062006500200052006500610064006500720020007700200077006500720073006a006900200036002e00300020006f00720061007a002000770020006e006f00770073007a00790063006800200077006500720073006a00610063006800200074007900630068002000700072006f006700720061006d00f30077002egt13 PTB 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 RUM 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 RUS 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Page 11 January 9 2018

The Michigan Department of Education believes its plan will reduce the percentage of Michigan students participating in the alternate assessment MI-Access to be closer to the 1 cap required by ESSA Beyond meeting the requirements of ESSA the MOE is committed to providing ISDs LEAs PSAs and IEP teams information and assistance to ensure that students are held to high academic achievement standards and that students are assessed using the tools most appropriate for individual student needs

Please contact John Jaquith jaguithjmichigangov or (517) 335-1987 to discuss the content of this waiver request or to answer any questions you may have We look forward to working with the United States Department of Education staff to achieve a positive response to this request

Brian histon State Superintendent Michigan Department of Education

Attachments

cc Michigan Education Alliance ossmichiqanedgov

  • Appendix A MDE_Memo_Alt_Assessment_waiver_Nov_2017_FINAL_606113_7
    • MEMORANDUM
    • DATE November 16 2017
    • FROM Brian J Whiston State Superintendent
    • Michigan Department of Education
    • SUBJECT Alternative assessment waiver request for the 1 cap
    • cc Michigan Education Alliance
      • Appendix B Public Comment Responses
      • Appendix C Guidelines for Participation in Michigan
      • Appendix D Sample of data provided to Intermediate School Districts
      • Appendix E 1PctCap_Justification_Form
        • Exceeding 1 Cap Justification Form
          • District Information
          • Baseline
          • Justification
          • Assurances
          • Resources and Technical Assistance
          • Submission Process
          • Questions
            • Untitled
              • Appendix F 1_Cap_Guidance_for_ISDs_595801_7
              • Michigan 1 Waiver with Approval Signature
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 GRE 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 HEB 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 HRV 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 HUN 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 ITA (Utilizzare queste impostazioni per creare documenti Adobe PDF adatti per visualizzare e stampare documenti aziendali in modo affidabile I documenti PDF creati possono essere aperti con Acrobat e Adobe Reader 60 e versioni successive)13 JPN 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 KOR 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken waarmee zakelijke documenten betrouwbaar kunnen worden weergegeven en afgedrukt De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 60 en hoger)13 NOR 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 POL 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 PTB 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RUM ltFEFF005500740069006C0069007A00610163006900200061006300650073007400650020007300650074010300720069002000700065006E007400720075002000610020006300720065006100200064006F00630075006D0065006E00740065002000410064006F006200650020005000440046002000610064006500630076006100740065002000700065006E007400720075002000760069007A00750061006C0069007A006100720065002000640065002000EE006E00630072006500640065007200650020015F0069002000700065006E00740072007500200069006D007000720069006D006100720065006100200064006F00630075006D0065006E00740065006C006F007200200064006500200061006600610063006500720069002E00200044006F00630075006D0065006E00740065006C00650020005000440046002000630072006500610074006500200070006F00740020006600690020006400650073006300680069007300650020006300750020004100630072006F0062006100740020015F0069002000410064006F00620065002000520065006100640065007200200036002E003000200073006100750020007600650072007300690075006E006900200075006C0074006500720069006F006100720065002Egt13 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents suitable for reliable viewing and printing of business documents Created PDF documents can be opened with Acrobat and Adobe Reader 60 and later)13 gtgt13gtgt setdistillerparams13ltlt13 HWResolution [600 600]13 PageSize [612000 792000]13gtgt setpagedevice13

                  1. Date
                  2. LEA
                  3. LEAPhone
                  4. LEAContact
                  5. LEAContactPhone
                  6. ISD
                  7. Baseline Off
                  8. Justification Off
                  9. F2FAdmin Off
                  10. F2FSpecialEdStaff Off
                  11. F2FParents Off
                  12. F2FRelServStaff Off
                  13. OnlineAdmin Off
                  14. OnlineSpecialEdStaff Off
                  15. OnlineParents Off
                  16. OnlineRelServStaff Off
                  17. GuideDocsAdmin Off
                  18. GuideDocsSpecialEdStaff Off
                  19. GuideDocsParents Off
                  20. GuideDocsRelServStaff Off
                  21. NoTrainAdmin Off
                  22. NoTrainSpecialEdStaff Off
                  23. NoTrainParents Off
                  24. NoTrainRelServStaff Off
                  25. OtherAdmin Off
                  26. OtherSpecialEdStaff Off
                  27. OtherParents Off
                  28. OtherRelServStaff Off
                  29. OtherTrainExplain
                  30. FactorsIEPTeamKnowl Off
                  31. FactorsLEASize Off
                  32. SmallLEAClarification
                  33. FactorsLEACenterBased Off
                  34. AdjustedRate
                  35. CenterBasedClarification
                  36. FactorsOther Off
                  37. OtherExplained
                  38. AssuranceAdditionalTraining Off
                  39. AssuranceIEPTeamDecides Off
                  40. ResourceTA