BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 484
                                                                  Page 1

          CONCURRENCE IN SENATE AMENDMENTS
          AB 484 (Bonilla)
          As Amended  September 6, 2013
          Majority vote
           
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          |ASSEMBLY:  |55-16|(May 29, 2013)  |SENATE: |26-7 |(September 10, |
          |           |     |                |        |     |2013)          |
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           Original Committee Reference:    ED.  

           SUMMARY  :  Establishes the Measurement of Academic Performance  
          and Progress (MAPP), commencing with the 2013-14 school year, as  
          the statewide assessment program for specified pupils and  
          provides direction to the State Board of Education (SBE), the  
          Superintendent of Public Instruction (SPI), and the California  
          Department of Education (CDE) on the transition of California's  
          current assessment system to the MAPP, the administration of the  
          MAPP, and the expansion of the MAPP to include additional  
          assessments beyond those specified in this bill. Specifically,  
           this bill  :


          1)Permits the SPI to make a determination that an Academic  
            Performance Index (API) will not be calculated for local  
            education agencies (LEAs) if the transition to the new  
            standards and assessments compromises the comparability of  
            results across, but limits the SPI's authority to make this  
            determination only for the 2013-14 and 2014-15 school years  
            and only with the approval of the SBE.

          2)Specifies that for LEAs without an API due to the SPI's  
            determination specified above, similarly shall not receive a  
            growth target and shall instead use one of the following to  
            satisfy any statutory requirements requiring an API  
            calculation:

             a)   The LEA's  most recent annual API calculation;

             b)   An average of the LEA's three most recent annual API  
               calculations;

             c)   Alternative measures that show increases in pupil  
               academic achievement for all groups of pupils school-wide  








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               and among significant subgroups. 

          3)Reauthorizes the Leroy Greene California Assessment of  
            Academic Achievement Act, which is California's system of  
            individual pupil assessment, until the year 2021.

          4)Identifies the intent of the Legislature to provide an  
            assessment system of assessments of pupils that has the  
            primary purposes of assisting teachers, administrators, and  
            pupils and their parents; improving teaching and learning; and  
            promoting high-quality teaching and learning using a variety  
            of assessment approaches and item types.

          5)Declares the intent of the Legislature that in order to  
            achieve the stated legislative goals for its system of  
            assessments, the state should adopt a coordinated testing  
            program that does all of the following:

             a)   Develop and adopt a set of statewide academically  
               rigorous content standards in all major subject areas and  
               produce performance standards for each subject area;
             b)   Provide information and resources to schools and LEAs to  
               assist with the selection of local benchmark assessments,  
               diagnostic assessments, and formative tools aligned with  
               the state-adopted California academic content standards; 

             c)   Ensure that all assessment procedures, items,  
               instruments, scoring systems, and results meet high  
               standards of statistical reliability and validity, and that  
               they do not use procedures, items, instruments, or scoring  
               practices that are racially, culturally, socioeconomically,  
               or gender biased;

             d)   Provide information to pupils, parents and guardians,  
               teachers, schools, and local educational agencies on a  
               timely basis so the information can be used to further the  
               development of the pupil or to improve the educational  
               program;

             e)   Report results of any census administration in terms  
               describing a pupil's academic performance in relation to  
               the statewide academically rigorous content and performance  
               standards and in terms of college and career readiness  
               skills possessed by the pupil, in addition to being  
               reported as a numerical;








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             f)   Where feasible, administer assessments via technology;  
               and

             g)    Minimize the amount of instructional time devoted to  
               assessments administered pursuant to this chapter.

          6)Makes inoperative those provisions of law governing the  
            development of the Standardized Testing and Reporting (STAR)  
            Program as of July 1, 2014.

          7)Defines key terms for the development, implementation, and  
            administration of the MAPP.

          8)Requires the SPI to provide annual updates to the Legislature,  
            Department of Finance, and the SBE, that include a five-year  
            cost projection, implementation plan, and time table for  
            implementing the assessment system set forth in this measure.

          9)Repeals Education Code Sections 60605.5 and 60606 which  
            required the SBE, on or before November 15, 2001, to adopt  
            performance standards systems and established a Statewide  
            Pupil Assessment Review (SPAR) Panel.

          10)Establishes the MAPP as the pupil assessment system to  
            replace the STAR program.

          11)Requires individual pupil level data be reported from the  
            MAPP that documents a pupil's individual level of  
            accomplishment. 

          12)Permits the use of the grade 11 MAPP assessment in English  
            language arts and mathematics to be used for the Early  
            Assessment Program (EAP).

          13)Requires the SPI to develop and post a periodic update on the  
            implementation of the MAPP.

          14)Specifies the assessments that shall be included in the MAPP,  
            commencing with the 2013-14 school year.
          15)Makes clear that in the 2013-14 school year, the consortium  
            summative assessment in English language arts and mathematics  
            shall be a field test only, and the results of this field test  
            shall not be used for any other purpose, including the  
            calculation of any accountability measure.








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          16)Requires the SPI to make a recommendation to the SBE, as soon  
            as is feasible, regarding the assessment aligned to the Next  
            Generation Science Standards, adopted by the SBE on September  
            4, 2013. The measure also requires the SPI, before making  
            these recommendations, to consult with stakeholders, as  
            specified and requires the recommendation to include cost  
            estimates and a plan for implementation of at least one  
            assessment in specified grade spans.

          17)Requires the CDE to make available to LEAs a primary language  
            assessment aligned to the English language arts standards for  
            assessing pupils who are enrolled in a dual language immersion  
            program.

          18)Requires the SPI to consult with stakeholders, including  
            assessment and English learner experts, to determine the  
            content and purpose of a stand-alone language arts summative  
            assessment in primary languages other than English that aligns  
            with the English-language arts content standards and then  
            report and make recommendations to the SBE regarding an  
            implementation timeline and estimated costs of this  
            assessment.

          19)Requires the SBE to adopt and the SPI to administer a primary  
            language assessment no later than the 2016-17 school year.

          20)Requires the SPI, no later than March 1, 2016, to submit to  
            the SBE recommendations on expanding the MAPP to include  
            additional assessments, including, but not necessarily limited  
            to, history-social science, technology, visual and performing  
            arts, and other subjects as appropriate, and include a  
            recommendation for the use of matrix sampling, if appropriate,  
            and the use of population sampling in the administration of  
            these assessments.  Upon approval by the SBE and the  
            appropriation of funding for this purpose, the SPI is required  
            to develop and administer the approved assessments.

          21)Requires the CDE to make available to LEAs STAR Program test  
            forms no longer required by the MAPP, though if administered,  
            the costs of shipping, printing, scoring, and reporting per  
            pupil shall be borne by the LEA.  

          22)Requires the SPI to make available a paper and pencil version  
            of any computer-based MAPP assessment for use by pupils who  








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            are unable to access the computer-based version of the  
            assessment for a maximum of three years after a new  
            operational test is first administered.

          23)Requires all LEAs, in the 2013-14 school year, to administer  
            the field tests in a manner described by the CDE.

          24)Allows the CDE to approve additional LEAs to participate in  
            the field test beyond the representative sample already chosen  
            for participation.

          25)Requires the CDE to use existing contract savings to fund LEA  
            participation in one or more tests per participant for the  
            purpose of allowing maximum participation in the field test  
            across the state. 

          26)Specifies that if savings in the current contract are not  
            available to fully fund LEA participation in the field test,  
            the CDE is required to prorate available funds by test and  
            specifies that LEAs shall bear any additional costs to  
            administer these assessments that are in excess of the  
            contracted amount.

          27)Prohibits the generation of pupil-level data from the 2013-14  
            administration of the MAPP field tests unless it is determined  
            that these scores are valid and reliable. 

          28)Requires the SPI to apportion funds to LEAs to enable them to  
            administer assessments used to satisfy the voluntary EAP in  
            the 2013-14 school year.

          29)Requires that when the SBE annually establishes the amount of  
            funding to be apportioned to LEAs for each test administered,  
            that it take into account changes to LEA test administration  
            activities under the MAPP, including, but not limited to, the  
            number, type of tests administered, and changes in  
            computerized test registration and administration procedures.

          30)Prohibits state agencies or LEAs from using a comparison  
            resulting from the scores and results of the MAPP assessments  
            and the assessment scores and results from assessments that  
            measured previously adopted content standards. 

          31)Requires the SBE to adopt regulations that outline a calendar  
            for delivery and receipt of summative assessment results at  








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            the pupil, school, grade, district, county, and state levels.   
            Requires these regulations to provide for the timely return of  
            assessment results, consider the amount of paper-and-pencil  
            administered assessments, and the number of items requiring  
            hand scoring.  Finally, the amendments require the regulations  
            to ensure that individual assessment results are reported to  
            LEAs within eight weeks of receipt by the contractor for  
            scoring. 

          32)Requires the CDE to acquire, and offer at no cost to LEAs,  
            interim and formative assessment tools for kindergarten and  
            grades 1 to 12, inclusive, as provided through the consortium  
            membership. 

          33)Permits, in approving a contract amendment to an assessment  
            contract authorized pursuant to this section, the CDE, in  
            consultation with the SBE, to make material amendments to the  
            contract that do not increase the contract cost. 

          34)Removes many of the statutory requirements for assessment  
            contracts and instead defers to the SPI and SBE to set the  
            terms of the assessment contracts.

          35)Requires the CDE to use a competitive and open process  
            utilizing standardized scoring criteria through which to  
            select a potential administration contractor or contractors  
            for the purposes of this measure.  When approving any such  
            contract, the CDE is required to consider specified criteria.   


          36)Removes the requirement of test publishers to make available  
            a reading list on the Internet by June 1 of the applicable  
            school year.

          37)Removes the requirement that a panel reviews the assessment  
            to ensure that no assessment item solicits or invites  
            disclosure of a pupil's beliefs, practices, morality,  
            religion, or evaluates the pupil's personal behavioral  
            characteristics.

          38)Specifies that the first full administration of assessments  
            aligned to the common core standards in English language arts  
            and mathematics shall occur in the 2014-15 school year unless  
            the SBE determines that the assessments cannot be fully  
            implemented.








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          39)Requires the CDE to determine and report on how school  
            districts are progressing toward implementation of a  
            technology-enabled assessment system by October 1, 2014. 

          40)Requires the SBE, based on the report submitted by the CDE on  
            the districts' progress toward implementation of a  
            technology-enabled assessment, to determine whether the state  
            shall fully implement the operational consortium  
            computer-adaptive summative assessments in English language  
            arts and mathematics in grades 3 to 8, inclusive, and grade 11  
            for the 2014-15 school year.

          41)Makes the MAPP assessments inoperative on July 1, 2021, and  
            then repeals the MAPP on January 1, 2022, unless legislative  
            action is taken to extend the operative date.

          42)Specifies, that for the purpose of the EAP and beginning in  
            the 2014-15 school year, it is the grade 11 consortium  
            computer-adaptive assessments in English language arts and  
            mathematics that may be used to replace the California  
            Standards Test and the augmented California Standards Tests. 

          43)Double joints this bill to SB 490 (Jackson) of the current  
            legislative session and specifies that if both bills are  
            enacted and this bill is enacted after SB 490, Section 28 of  
            this bill shall not become operative. 

          44)Makes technical, non-substantive changes to these sections.
           
          The Senate amendments  : 

          1)Amend Education Code Section 52052 to permit the SPI to make a  
            determination that an API score would be an invalid measure of  
            the performance of the school or school district based on a  
            finding that a transition to new standards-based assessments  
            compromises comparability of results across schools or school  
            districts.  This amendment limits the SPI's authority in this  
            subparagraph to the 2013-14 and 2014-15 school years only,  
            with approval of the SBE.

          2)Establish a repeal date of January 1, 2015, for the section of  
            this bill that calls for the adoption of the STAR program. 

          3)Rename the California Measurement of Academic Performance and  








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            Progress for the 21st Century (CalMAPP21) to the Measurement  
            of Academic Performance and Progress (MAPP).

          4)Add definitions for the following terms:  computer-adaptive  
            assessment, computer-based assessment, field test, LEA, MAPP,  
            matrix sampling, performance tasks, personally identifiable  
            information, populations sampling, recently arrived English  
            learner, state-determined assessment calendar, and summative  
            assessment.

          5)Replace the term "core curriculum areas" with the content  
            areas of reading, writing, mathematics, history-social  
            science, foreign languages, visual and performing arts, and  
            science.

          6)Delete the definitions of "Elementary and Secondary Education  
            Act (ESEA) non-required subject area" and "ESEA required  
            subject area."

          7)Require the SPI to design and implement a statewide pupil  
            assessment system that specifically contemplates summative  
            assessments or assessments that employ matrix sampling or  
            population sampling methods. 

          8)Require the SPI, when making information about and/or the  
            results of statewide summative assessments, to consider the  
            information already provided by assessment consortia of which  
            California is a member or the assessment contractor. 

          9)Specify that, commencing with the 2013-14 school year, the  
            MAPP shall be composed of all of the following: 

             a)   A consortium summative assessment in English language  
               arts and mathematics for grades 3 to 8, inclusive, and  
               grade 11 but further specifies that for the 2013-14 school  
               year, the consortium summative assessment in English  
               language arts and mathematics shall be a field test only;

             b)   Science grade level assessments in grades 5, 8, and 10;

             c)   The California Alternative Performance Assessment (CAPA)  
               in grades 2 to 11, inclusive, in English language arts and  
               mathematics and science in grades 5, 8, and 10; and

             d)   The EAP.








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          10)Permit the use of any data from the 2013-14 field tests of  
            the consortium assessment in ELA and mathematics to be used  
            only for the purpose of gauging the validity and reliability  
            of these assessment, conducting necessary psychometric  
            procedures and studies, and allowing the CDE to conduct  
            studies regarding full implementation of the assessment system  
            and specifies that the data shall not be used for any other  
            purpose, including the calculation of any accountability  
            measure.

          11)Require the SPI to make a recommendation to the SBE, as soon  
            as is feasible, regarding the assessment of Next Generation  
            Science Standards, adopted by the SBE on September 4, 2013.   
            The measure also requires the SPI, before making these  
            recommendations, to consult with stakeholders, as specified,  
            and requires the recommendation to include cost estimates and  
            a plan for implementation of at least one assessment in each  
            specified grade spans.

          12)Make mandatory the previously permissive language that  
            allowed the CDE to make available to LEAs a primary language  
            assessment for assessing pupils who are enrolled in a dual  
            language immersion program to require the CDE to provide this  
            assessment.

          13)Remove the date by which the SPI shall report and make  
            recommendations to the SBE regarding an implementation  
            timeline and estimated costs of a stand-alone language arts  
            summative assessment in primary languages other than English  
            and instead requires the SPI to have developed and the SBE to  
            have adopted this assessment so that it may be administered by  
            the SPI no later than the 2016-17 school year.

          14)Change the date by which the SPI is required to submit to the  
            SBE recommendations on expanding the MAPP to include  
            additional assessment (e.g., history-social science,  
            technology, visual and performing arts, and other subjects as  
            appropriate.  As passed by the Assembly, the SPI was required  
            to present the recommendation on or before January 15, 2015.   
            The Senate amendments require the recommendation be presented  
            to the SBE, Legislature, and Department of Finance no later  
            than March 1, 2016.

          15)Make mandatory the previously permissive language that  








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            permitted the CDE to make available to LEAs STAR Program test  
            forms no longer required by the MAPP, though if administered,  
            the costs of shipping, printing, scoring, and reporting per  
            pupil shall be borne by the LEA.  

          16)Require the SPI to make available a paper and pencil version  
            of any computer-based MAPP assessment for use by pupils who  
            are unable to access the computer-based version of the  
            assessment for a maximum of three years after a new  
            operational test is first administered.

          17)Require all LEAs, in the 2013-14 school year, to administer  
            the field tests in a manner described by the CDE in  
            consultation with the president or executive director of the  
            SBE.

          18)Allow the CDE to approve additional LEAs to participate in  
            the field test beyond the representative sample already chosen  
            for participation.

          19)Require the CDE to use existing contract savings to fund LEA  
            participation in one or more tests per participant for the  
            purpose of allowing maximum participation in the field test  
            across the state. 

          20)Specify that if savings in the current contract are not  
            available to fully fund  LEA participation in the field test,  
            the CDE is required to prorate available funds by test and  
            specifies that LEAs shall bear any additional costs to  
            administer these assessments that are in excess of the  
            contracted amount.

          21)Prohibit the generation of pupil-level data from the 2013-14  
            administration of the MAPP field tests unless it is determined  
            that these scores are valid and reliable. 

          22)Require the SPI to apportion funds to LEAs to enable them to  
            administer assessments used to satisfy the voluntary EAP in  
            the 2013-14 school year

          23)Require that when the SBE annually establishes the amount of  
            funding to be apportioned to LEAs for each test administered,  
            to take into account changes LEA test administration  
            activities under the MAPP, including, but not limited to, the  
            number, type of tests administered, and changes in  








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            computerized test registration and administration procedures.

          24)Prohibit state agencies or LEAs from using a comparison  
            resulting from the scores and results of the MAPP assessments  
            and the assessment scores and results from assessments that  
            measured previously adopted content standards. 

          25)Require the SBE to adopt regulations that outline a calendar  
            for delivery and receipt of summative assessment results at  
            the pupil, school, grade, district, county, and state levels.   
            Specifies that these regulations shall provide for the timely  
            return of assessment results, consider the amount of  
                                                                               paper-and-pencil administered assessments, and the number of  
            items requiring hand scoring.  Finally, the amendments require  
            the regulations to ensure that individual assessment results  
            are reported to LEAs within eight weeks of receipt by the  
            contractor for scoring. 

          26)Require the CDE to acquire, and offer at no cost to LEAs,  
            interim and formative assessment tools for kindergarten and  
            grades 1 to 12, inclusive, as provided through the consortium  
            membership. 

          27)Permit, in approving a contract amendment to an assessment  
            contract authorized pursuant to this section, the CDE, in  
            consultation with the SBE, to make material amendments to the  
            contract that do not increase the contract cost.  The Senate  
            amendments also specify that those contract amendments that  
            increase contract costs may only be made with the approval of  
            the SBE and the Department of Finance. 

          28)Require the CDE to use a competitive and open process  
            utilizing standardized scoring criteria through which to  
            select a potential administration contractor or contractors  
            for the purposes of this measure.  When approving any such  
            contract, the CDE is required to consider specified criteria.   


          29)Specify that the first full administration of assessments  
            aligned to the Common Core standards in English language arts  
            and mathematics shall occur in the 2014-15 school year unless  
            the SBE determines that the assessments cannot be fully  
            implemented.

          30)Change the date by which the CDE is required to determine and  








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            report on how school districts are progressing toward  
            implementation of a technology-enabled assessment system, from  
            January 31, 2014, until October 1, 2014. 

          31)Require the SBE, based on the report submitted by the CDE on  
            the progress toward districts' progress toward implementation  
            of a technology-enabled assessment, to determine whether the  
            state shall fully implement the operational consortium  
            computer-adaptive summative assessments in English language  
            arts and mathematics in grades 3 to 8, inclusive, and grade 11  
            for the 2014-15 school year.

          32)Change the date on which the statutes governing the  
            administration of the MAPP assessments become inoperative from  
            July 1, 2025, to July 1, 2021, and the repeal dates of these  
            statutes from January 1, 2026, to January 1, 2022.

          33)Specify that for the purpose of the EAP Program and beginning  
            in the 2014-15 school year, it is the grade 11 consortium  
            computer-adaptive assessments in English language arts and  
            mathematics that may be used to replace the California  
            Standards Test and the augmented California Standards Tests. 

          34)Remove the urgency clause.

          35)Make chaptering out amendments based on SB 490 (Jackson) and  
            specifies that if both bills are enacted and this bill is  
            enacted after SB 490, Section 28 of this bill shall not become  
            operative.  The provisions of SB 490 differ from the language  
            of this in so far as SB 490 references the California  
            Standards Test (CST) and the augmented CST, as referenced in  
            Education Code Section 60641, or a standards-aligned successor  
            assessment, whereas this bill references more generally the  
            assessments referenced in Education Code Section 60641.  

          36)Make chaptering out amendments based on SB 344 (Padilla) of  
            the current legislative session and specifies that if both  
            bills are enacted and become effective on or before January 1,  
            2014, and this bill is enacted after SB 344, in which case  
            Section 1 of this bill shall not become operative.  The  
            provisions of SB 344 differ from the language of this in so  
            far as SB 344 includes "reclassified English Learners" as a  
            subgroup for which a school or school district must  
            demonstrate comparable improvement in academic achievement as  
            measured by the API.








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          37)Make technical, non-substantive changes to this measure.

           FISCAL EFFECT  :  According to the Senate Appropriations  
          Committee, this bill, as amended, has the following costs:

          1)Assessment Suspensions:  Approximately $8 million in state  
            savings in 2013-14, and $1.5 million in state savings in  
            2014-15 (General Fund). 

          2)Field testing:  Substantial potential costs/savings, as this  
            bill does not require schools that are not field testing new  
            assessments to assess students in 2013-14.  Additionally,  
            schools that choose to field test the new assessments will not  
            have to double-test (by administering current STAR tests).  To  
            the extent that more schools want to field test the new  
            assessments, there will likely be additional state costs.  To  
            the extent that schools decline to participate in field  
            testing, there will likely be significant additional savings  
            from removing the testing requirements altogether for 2013-14.  


          3)Assessments:  Approximately $81 million in 2014-15, and $82  
            million - $105 million (General Fund) in 2015-16, and annually  
            thereafter. 

          4)Multi-year Evaluation:  Approximately $200,000 in 2013-14, and  
            $700,000 (General Fund) annually thereafter, to contract for  
            the independent evaluation required by this bill.

           COMMENTS  :  The Senate amendments make sweeping changes to this  
          bill namely the elimination of assessments in English language  
          arts and mathematics for the current school year, the ability of  
          the SBE to determine that California cannot implement the full  
          consortium assessment in the 2014-15 school year, and the  
          potential suspension of API calculations for the 2013-14 and  
          2014-15 school years.  

           English Language Arts and Mathematics Assessments in the Current  
          School Year  .  The Senate amendments significantly change the  
          assessments administered during the current school year.  The  
          Assembly considered language that kept in place those  
          assessments that met federal accountability requirements but  
          considered a transition to consortium assessments in the 2014-15  
          school year.  As amended, this bill eliminates the assessments  








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          in English language arts and mathematics for the current school  
          year and instead requires all LEAs to participate consortium  
          field tests in grades 3-8, and 11 in mathematics and English  
          language arts.  In an effort to encourage LEAs to provide Common  
          Core aligned instruction, the Senate has removed the incentive  
          to continue to provide instruction that is geared toward the  
          previous state adopted standards as measured by the STAR  
          program.  While this means that there will be no statewide  
          achievement data for English language arts and mathematics  
          during the 2013-14 school year, it will, arguably, better  
          prepare LEAs for the administration of the consortium assessment  
          in the 2014-15 school year.  It is important to note that this  
          bill will necessitate a request from California to the United  
          States Department of Education for a waiver from the federal  
          requirement that California demonstrate its success in terms of  
          the academic achievement of every student and that such evidence  
          be derived from testing data from every student's progress  
          toward state adopted standards by using assessments that are  
          aligned with the standards.   In the absence of this waiver, the  
          approximate $1.6 billion in Title I funds would be put in  
          jeopardy.  

           Consortium Testing in the 2014-15 School Year  .  The Senate  
          amendments require the CDE, no later than October 2014, to  
          produce a report that examines how LEAs are progressing toward  
          implementation of a technology-enabled assessment system, and  
          the extent to which the assessments aligned to the common core  
          standards in English language arts and mathematics can be fully  
          implemented.  Based on this report, the SBE is required to  
          determine, whether California shall fully implement the  
          operational consortium computer-adaptive summative assessments  
          in English language arts and mathematics in grades 3 to 8,  
          inclusive, and grade 11 for the 2014-15 school year.  This will  
          allow a thorough analysis of the ability of LEAs, based on the  
          field tests in the 2013-14 school year to fully access the  
          consortium assessment and provide relief if necessary.  

           Changes to the Academic Performance Index (API)  .  The Senate  
          amendments allow the SPI, with the approval of the SBE, to  
          withhold the calculation of API scores if the previous API  
          scores cannot be accurately compared to those scores under the  
          new assessment system.  This is limited to the 2013-14 and  
          2014-15 school years.  The Assembly considered language that  
          instead required the development of a transitional API.  The  
          Senate amendments specify that in the absence of these API  








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          calculations an LEA shall use its most recent API calculation,  
          an average of its three most recent annual API calculations, or  
          alternative measures that show increases in pupil academic  
          achievement for all groups of pupils both school-wide and among  
          significant subgroups.  While additional clean up language may  
          be required in the future to address those LEAS who have a  
          statutory requirement to demonstrate academic growth, but have  
          no such data available, this addresses the concerns of LEAs that  
          continued accountability in a time of tremendous change will do  
          more harm than good.


           Analysis Prepared by  :    Jill Rice / ED. / (916) 319-2087 


          FN:  
          0002691