BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 173
                                                                  Page  1

          Date of Hearing:   April 29, 2009

                           ASSEMBLY COMMITTEE ON EDUCATION
                                Julia Brownley, Chair
                     AB 173 (Price) - As Amended:  April 14, 2009
           
          SUBJECT  : Low performing schools

           SUMMARY  : Requires the California Department of Education (CDE)  
          to contract for the development of a new measure to replace the  
          Academic Performance Index (API), and requires the CDE to  
          convene a new advisory board to provide general guidance and  
          make recommendations toward that end.  Specifically,  this bill  :   


          1)States Legislative intent to adopt a new indicator of academic  
            performance that measures pupil-level growth over time,  
            replaces the API, serves state and federal accountability  
            functions, and is ready for implementation by the 2015-16  
            fiscal year.

          2)Requires, subject to the availability of federal funds for  
            this purpose, the CDE to contract for the development of a new  
            indicator that:

             a)   Measures pupil-level growth on the Standardized Testing  
               and Reporting (STAR) tests, the English language  
               development test, and the high school exit examination.

             b)   Evaluates and determines the most effective way to  
               modify existing tests to allow the indicator to measure  
               pupil growth over time

             c)   Allows the state to measure Adequate Yearly Progress,  
               identify schools for Program Improvement, and otherwise  
               comply with the federal No Child Left Behind Act (NCLB).

             d)   Serves state accountability functions

             e)   Allows the state to make required assurances under the  
               American Recovery and Reinvestment Act. 

             f)   Distinguish among low-performing schools and local  
               education agencies and streamline eligibility requirements  
               in order to better target state resources.








                                                                  AB 173
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          3)Requires the CDE to convene a broadly representative advisory  
            board consisting of representatives from the state board, the  
            Secretary for Education, the Department of Finance, the  
            Legislative Analyst's Office, parent groups, school districts,  
            and education researchers to provide general guidance and make  
            recommendations relative to modifying assessments, academic  
            content standards, performance expectations, and eligibility  
            criteria for state support and resources.

          4)Requires, subject to a budget appropriation, the CDE to  
            contract with a consultant for independent oversight of the  
            project to develop a new academic performance indicator,  
            requires the Director of Finance (DOF) to review the request  
            for proposals for the contract, and requires specified written  
            reports from the consultant.

          5)Requires these provisions to be implemented using federal  
            funds received under NCLB upon the approval of an expenditure  
            plan by DOF. 

           EXISTING LAW  

          1)Requires the Superintendent of Public Instruction (SPI), with  
            the approval of the State Board of Education (SBE), to develop  
            and implement the API to measure the performance of schools,  
            and to include a variety of indicators, including achievement  
            test results, attendance rates, and graduation rates in that  
            measure.

          2)Requires the SPI to establish an advisory committee to provide  
            advice on all appropriate matters relative to the creation of  
            the API.

          3)Directs the advisory committee by July 1, 2005, to make  
            recommendations to the SPI on the appropriateness and  
            feasibility of a methodology for generating a measurement of  
            academic performance by using unique pupil identifiers and  
            annual academic achievement growth to provide a more accurate  
            measure of a school's growth over time.

          4)Establishes the STAR program to test academic skills in grades  
            2-11 and to report individual and aggregate results, the  
            English language development test to test the acquisition of  
            English skills and to report individual results, and the high  








                                                                  AB 173
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            school exit examination as a high school graduation  
            requirement to report individual and aggregate results.

           FISCAL EFFECT  : Unknown

           COMMENTS  : The SPI established, pursuant to SB 1 X1 (Alpert),  
          Chapter 3, Statutes of 1999-2000 First Extraordinary Session, an  
          advisory committee to advise the SPI and the SBE on all  
          appropriate matters relative to the creation of the API.  SB 1  
          X1 also requires the SPI, with the approval of the SBE, to  
          develop the API to measure the performance of schools, and to  
          include a variety of indicators in that measure, including, but  
          not limited to, achievement test results, attendance rates, and  
          graduation rates.  Currently only achievement test results are  
          incorporated into the API, and the API is configured to produce  
          scores measuring a school's static performance at each grade  
          level, in each content area, in each year, at one point in time.  
           In addition the SPI also produces a "Growth API" that compares  
          this static performance from one year to the next by comparing  
          cohort or group scores.  This growth API, however, does not  
          measure true value added for a specific group of students and is  
          not based on the year-to-year information for individual pupils;  
          in other words that measure may only be reflecting the  
          differences in cohorts of pupils that were in one grade level  
          over two different years, rather than actual growth for a fixed  
          set of students over time.

          What is the impact of not being able to compare individual test  
          scores or the aggregate API over time?  Even though individual  
          STAR test scores look the same from one year to the next and  
          allow a relative comparison to other students in the same grade  
          level in a given year, a student's scores are not comparable  
          across grade levels; this means that the student, parents, and  
          teachers can not tell if a student has improved or is achieving  
          at a lower level from one year to the next based on the test  
          scores that they receive.  In short, we don't know whether the  
          520 that a student scores this year is higher, lower, or the  
          same as the 500 that student scored in the previous grade.  The  
          primary impact of this shortcoming is that we are unable to  
          determine whether a specific instructional program designed to  
          maintain a student's academic growth or to accelerate that  
          student's growth is actually doing so.  In the same way, the  
          inability to compare API results from one year to the next,  
          except through the current growth API that effectively measures  
          the results in one grade level for two successive and different  








                                                                  AB 173
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          cohorts of students, restricts the state's ability to make  
          judgments about how a school's or district's instructional  
          program impacts its students' academic progress over time.  In  
          other words, we are unable to tell whether school reform or  
          school improvement efforts are actually achieving results in  
          terms of academic growth in a school or district; even if we  
          could see growth, we are unable to really measure how great that  
          growth is.  Clearly very large changes from one year to the next  
          would show up as very large changes in individual scores and in  
          the API, but large dramatic changes in one year are not  
          generally the result of school improvement.  The lack of ability  
          to make comparisons over time has also hurt the state in terms  
          of its ability to take advantage of opportunities, provided as  
          part of the federal accountability system defined under No Child  
          Left Behind, to adopt more flexibility in establishing how  
          schools and districts meet the standard of Adequate Yearly  
          Progress (AYP); this in turn has implications for schools and  
          districts moving into Program Improvement status and eventually  
          being mandated to accept various forms of state intervention,  
          including the possibility of state takeover.

          Why can't we make these comparisons over time?  There are three  
          primary obstacles that face any large-scale assessment and  
          accountability system that attempts to generate measures that  
          allow valid comparisons of achievement over time: cohort  
          instability, content discontinuity, and score incomparability.   
          Cohort instability simply refers to the fact that a school or  
          district won't have the same set of students in one grade this  
          year that it had in the previous grade the year before; in other  
          words, students move in and students move out of schools and  
          districts.  This means that an aggregate measure, like the API,  
          is based on a different set of student scores in each of those  
          two years, and if the students from one year to the next are  
          different, then we can not know whether a change in the API  
          results from the work that the school, district, students and  
          parents have done or simply from the fact that the academic  
          achievement of the two sets of students is different.  While  
          this problem may have an insignificant effect in some schools  
          and districts, California has schools and districts with  
          year-to-year turnover that exceeds 100 percent - meaning that  
          more students have left and come into the school or district  
          over the last year than were enrolled last year.

          Content discontinuity refers to the fact that content upon which  
          scores and measures are based may not create a continuous  








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          progression across all grade levels; the simplest examples of  
          this are in the California mathematics standards beginning at  
          grade 8 and in the English language arts standards beginning at  
          grade 9.  The standards above those grade levels were developed  
          to recognize the variety of courses and course sequences that  
          exist across California middle and high schools, so the  
          standards exist more as a grade level block, rather than a  
          sequence of grade levels or content.  In a school one student  
          may take a math sequence of algebra, geometry, second-year  
          algebra and pre-calculus, while another takes pre-algebra,  
          algebra, statistics and no math class; this content  
          discontinuity creates an oranges and apples problem that  
          complicates and possibly invalidates comparisons of aggregate  
          achievement across the grade levels for that school.  This also  
          creates a problem for comparing individual scores; for example  
          the student taking geometry and then second-year algebra sees  
          their test scores go up from one grade to the next, but if that  
          same student had taken second-year algebra first and then  
          geometry (as sequenced in some schools), that student's scores  
          would have gone down from one year to the next.  In addition,  
          since the individual grade level tests in a given content area  
          can not, in the time allotted for testing, test all of the  
          content standards for that grade level and content area, there  
          is a sampling of content done for inclusion on the tests.  So  
          even if the content standards were completely sequenced across  
          grade levels, the tests drawn from those standards still may not  
          reflect a continuous sequence of content.  Any discontinuity in  
          content creates an oranges and apples problem such that growth  
          in achievement is not reflected in a student's scores across two  
          years - what would be reflected would simply be that student's  
          achievement on two different sets of content.

          Score incomparability refers to how the underlying scores on the  
          tests are created.  Even if content discontinuity were not at  
          issue, in order to compare an individual student's test scores  
          over time the scales on which the test scores are measured at  
          each grade level would have had to have been statistically  
          produced together for all of the grade levels so that there was  
          a progression of possible scores up the grades (one process for  
          producing a score scale that has this progression is referred to  
          as vertical scaling); other statistical mediation approaches  
          might also be used in order to make those scores comparable.  As  
          an example, take two teachers who both grade their students'  
          tests on a scale of 0 to 100; can we say that a 90 on one  
          teacher's test is the same as a 90 on the other?  Clearly not,  








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          even if the test content were the same, because we know that  
          teachers grade differently and that their perceptions of what  
          gets a score of 90 may be different. However, if we took all of  
          the tests from both classrooms and examined the results, we  
          could produce a common scale that reflected the difference  
          between the two scores of 90 and every other score in the two  
          classes, and that allowed cross-class comparisons.  This same  
          sort of statistical process would have to be used to allow  
          scores on a series of grade-level tests to be compared across  
          those grade levels.  The scale scores on the tests in the STAR  
          program were developed independent of each other and thus do not  
          validly support this type of cross grade level comparison.  Some  
          would argue that the cut-point or level setting process that is  
          used to establish the STAR performance levels (e.g., basic,  
          proficient, advanced) mediates this shortcoming in the scale  
          scores, but the judgmental nature of such a standard setting  
          would require extensive statistical validation before it was  
          determined that this process supports comparisons over time.  In  
          addition, the individual scores produced in the STAR program  
          form the basis for both the API and for measuring AYP; if the  
          underlying test scores do not support comparisons over time,  
          then these resulting aggregate measures will suffer from the  
          same problem.

          How can the test scores and aggregate growth measures be made to  
          be comparable over time?  There are many methodologies across a  
          broad spectrum of approaches that could be employed to either  
          eliminate or work around this problem.  On one end of that  
          spectrum might be a full vertical scaling effort. In this  
          approach test questions from one grade level test would be  
          administered to students in adjacent grades and the results  
          would be used to create a common scale across the grade levels.   
          Thus a student's growth could be tracked as the student moves up  
          the common scale that runs from the lowest grade level up  
          through the highest scores at the highest grade level.  This  
          approach is dependent upon the underlying content of the tests  
          being continuous; in other words movement on the common scale  
          has to reflect a progression through the content. It is possible  
          that applying this approach to California might mean a  
          re-examination of the content standards and test content in  
          order to ensure that this content continuity exists.  Since the  
          API is an aggregation of STAR test scores, vertical scaling of  
          the test scores would eliminate most of the problems associated  
          with using the API to compare school and district performance  
          across time.  At the other end of the spectrum might lay  








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          approaches that rely on statistical procedures to estimate or  
          project what score, on the average, should be achieved in a  
          given year based on the previous year's score or other  
          information.  In this way a student's actual score can be  
          compared to the projected score, and a judgment could be made  
          about whether the student grew at a greater or lesser rate than  
          the average.  This same sort of statistical mediation could be  
          used directly on an aggregate measure, such as the API, without  
          applying the approach to individual test scores.

          There are also many other approaches and methodologies that  
          could be employed to allow comparisons over time.  As with any  
          large-scale statistical procedure, the trade-off among these  
          procedures is generally between the increased validity and  
          accuracy of the resulting measures and the comparisons that are  
          made using them, and the cost and time involved in implementing  
          that approach.  At the two ends of the spectrum, a vertical  
          scaling process would be the most involved of the approaches,  
          while direct statistical mediations would be less costly and  
          faster.  On the other hand statistical mediation does not solve  
          the underlying problems, but works around them; thus problems  
          such as content discontinuity would still exist and pose a  
          potential threat to the validity of the conclusions and  
          comparisons that we make with these test scores and  
          accountability measures.

          In calling for the development of a new indicator, this bill  
          does not presume that any of these approaches are best, it does,  
          however, constrain the contractor and advisory board to develop  
          an indicator that measures both growth and performance at both  
          the pupil and aggregate level.  In fact, the bill requires that  
          a single measure be developed to reflect both individual  
          performance and growth on all tests and aggregate performance  
          and growth across all tests.  This one-size-fits-all approach  
          may be overly restrictive, since test scores are specific to a  
          test, a score scale, and a set of content in a grade level  
          (e.g., grade 6 mathematics); aggregate measures, however, by  
          their nature combine the information from a number of different  
          component tests to indicate overall performance.  An analogy  
          making this point might be the evaluation of an automobile.   
          Tests might generate information measured in miles per gallon,  
          miles per hour, time elapsed, cost per repair, or number of  
          injury accidents per thousand miles, but we could not build an  
          overall indicator of performance for that automobile using any  
          of those specific measures; instead we would need an overall  








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          aggregate measure that appropriately reflected all of the  
          component information.

          The bill is very specific in stating that this new measure  
          replaces the current API, and thus rules out any approach that  
          would simply provide a direct statistical mediation of the API  
          in order to establish longitudinal comparability of that  
          aggregate measure of performance.

          This bill also requires the engagement of two contractors and  
          the appointment of a new advisory board.  It is unclear what  
          differentiates the work of the main contractor developing the  
          new indicator and the advisory board. Since the end product of  
          this development process is simply a statistical methodology,  
          and not a physical deliverable such as an extensive software  
          system or hard product, which would be implemented by the CDE,  
          either the contractor or the advisory board (with CDE support)  
          could undertake this task.  Also, the addition of an independent  
          oversight contractor may be more useful in situations of  
          large-scale development such as software or product development,  
          rather in a more research based activity such as this; for  
          example, the independent oversight might be more appropriate if  
          targeted at the CDE implementation of the methodology, rather  
          than at the development of the methodology itself.

          The bill creates potential problems with timing by expressing  
          the intent of the Legislature that the new indicator be operable  
          by 2015-16, but also requiring the appropriation of funds and  
          the approval of the DOF before any of the provisions of this  
          bill are implemented or either the development or oversight  
          contract can be let.  This requirement could mean that the  
          Legislature's intent is not acted upon, or that development work  
          on the new indicator could be delayed until funds are available  
          or until DOF provides approval.  An additional issue of timing  
          is created by the lack of direction in the bill as to when and  
          how the new indicator would be implemented or integrated into  
          use; there is also no direction in the bill as to who would have  
          the responsibility or authority for implementing this new  
          indicator.  Making a change in how we measure progress of both  
          students and schools potentially has significant impacts on  
          individual students, schools and school districts in terms both  
          the state and the federal accountability system, as well as in  
          overall school reform; a change of this significance should have  
          the involvement of the Legislature.









                                                                  AB 173
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          Related legislation: This bill is one of four bills that propose  
          changes to the state's accountability system, specifically to  
          the API measure, and that will be heard by the Assembly  
          Education Committee this month.  Those four bills are AB 173  
          (Price), AB 429 (Brownley), AB 1130 (Solorio), and AB 1435 (V.  
          Manuel Perez).  The last page of this analysis provides a  
          side-by-side comparison of key features of these bills.  AB 429  
          (Brownley), pending in the Assembly Education Committee,  
          requires examination of methods for making and reporting valid  
          comparisons of individual academic performance over time and for  
          making potential improvements in the API, so as to be able to  
          measure and report both a student's and a school's academic  
          growth over time.  AB 1130 (Solorio), pending in the Assembly  
          Education Committee, requires examination of methods for making  
          and reporting comparisons of school and district academic  
          achievement over time based on a cohort growth measure.  AB 1435  
          (V. M. Perez), pending in the Assembly Education Committee,  
          requires the examination of assessment data related to the  
          acquisition of English language by English learners (EL) and of  
          EL proficiency with respect to making potential improvements in  
          the API.

          Previous legislation: AB 2776 (Mullin), held in the Senate  
          Appropriations Committee in 2008, would have required  
          examination of the collection of individual student data, the  
          state's emerging data systems, the possibility of making real  
          comparisons of student performance over time, and the long-term  
          availability of assessment data related to the acquisition of  
          English language by English learners with respect to making  
          potential improvements in the API.  AB 2478 (Huffman), held in  
          the Assembly Appropriations Committee in 2008, makes changes in  
          the issues on which the advisory committee advising the SPI on  
                                                                       the API is required to make recommendations.  AB 519 (Mendoza)  
          would have required the incorporation of data regarding the  
          availability in high schools of a course of study that fulfills  
          University of California and California State University  
          admission requirements into the API, and the submission of a  
          plan for incorporating dropout data into the API.  This bill was  
          later amended into different subject matter and author  
          (Committee on the Budget), and enacted as Chapter 757, Statutes  
          of 2008.  SB 219 (Steinberg), Chapter 731, Statutes of 2007,  
          makes changes in the calculation of and in the process for  
          revising the API.  AB 400 (Nunez), vetoed in 2007, would have  
          required the incorporation of additional measures of performance  
          into the API, including the rate at which pupils are offered a  








                                                                  AB 173
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          course of study that fulfills University of California and  
          California State University admission requirements.  AB 2167  
          (Arambula), Chapter 743, Statutes of 2006, establishes a  
          specific methodology for including graduation rates, as  
          previously required, in the API; also requires the SPI to report  
          annually to the Legislature on graduation and dropout rates in  
          the state.  SB 1284 (Scott), held in the Assembly Appropriations  
          Committee in 2006, would have updated and made technical  
          amendments to statutes that establish the API.  SB 1448  
          (Alpert), Chapter 233, Statutes of 2004, reauthorized the STAR  
          Program.  SB 257 (Alpert), Chapter 782, Statutes of 2003,  
          requires the advisory committee established to advise the SPI on  
          the API to make recommendations to the SPI on a methodology for  
          generating a "gain" score measurement to provide more accurate  
          measure of a school's growth over time.  AB 1295 (Thomson),  
          Chapter 887, Statutes of 2001, makes changes to the API to allow  
          small school districts to receive an API score, receive growth  
          targets, and performance awards.  SB 1 X1 (Alpert), Chapter 3,  
          Statutes of 1999-2000 First Extraordinary Session, known as the  
          Public Schools Accountability Act (PSAA), authorizes the state's  
          current accountability program, including establishment of the  
          PSAA Advisory Committee and development of the API.  SB 2 X1  
          (O'Connell), Chapter 1, Statutes of 1999-2000, authorized  
          development of the high school exit examination, and established  
          a timeline for requiring passage of that examination in order to  
          qualify for the high school diploma. SB 376 (Alpert), Chapter  
          828, Statutes of 1997, authorized development and implementation  
          of the STAR Program.

           REGISTERED SUPPORT / OPPOSITION  :   

          Support 
           
          None on file

           Opposition 
           
          None on file
           
          Analysis Prepared by  :    Gerald Shelton / ED. / (916) 319-2087 













                                                             AB 173
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        Comparisons of Current Law, AB 429, AB 1130, AB 1435, and AB 173 on 
         Key Elements in the Proposals to Improve California Assessment and  
                              Accountability Measures
                                   
          ------------------------------------------------------------------------------------------ 
         |               |  Current  |    AB 173    |    AB 429     |AB 1130 (4/22/09 |   AB 1435   |
         |               |    Law    |   (4/14/09   | (introduced)  |      ver.)      |(introduced) |
         |               |           |    ver.)     |               |                 |             |
         |---------------+-----------+--------------+---------------+-----------------+-------------|
         |Primary        |Developed  |Replace API   |Facilitate     |Facilitate       |Add CELDT    |
         |proposal       |API and    |with new      |growth         |growth           |and EL       |
         |               |advises    |measure       |comparisons    |comparisons      |proficiency  |
         |               |SPI on     |              |               |                 |to API       |
         |               |relevant   |              |               |                 |             |
         |               |matters    |              |               |                 |             |
         |---------------+-----------+--------------+---------------+-----------------+-------------|
         |Improves       |Created    |Both with a   |Both           |Aggregate        |Aggregate    |
         |individual or  |aggregate  |single        |individual     |accountability   |accountabilit|
         |aggregate      |accountabil|measure       |test scores    |measure          |y measure    |
         |measures?      |ity        |              |and aggregate  |                 |             |
         |               |measure    |              |accountability |                 |             |
         |               |           |              |measure        |                 |             |
         |---------------+-----------+--------------+---------------+-----------------+-------------|
         |Who makes      |API        |New advisory  |API advisory   |API advisory     |API advisory |
         |recommendations|advisory   |board with    |committee      |committee        |committee    |
         |?              |committee  |independent   |               |                 |             |
         |               |           |oversight     |               |                 |             |
         |               |           |consultant    |               |                 |             |
         |---------------+-----------+--------------+---------------+-----------------+-------------|
         |Deadline for   |July 1,    |None - not    |July 1, 2011   |None             |July 1, 2010 |
         |recommendations|2005       |implemented   |               |                 |             |
         |?              |           |until the     |               |                 |             |
         |               |           |Legislature   |               |                 |             |
         |               |           |appropriates  |               |                 |             |
         |               |           |federal funds |               |                 |             |
         |               |           |for this      |               |                 |             |
         |               |           |purpose with  |               |                 |             |
         |               |           |DOF approval  |               |                 |             |
         |---------------+-----------+--------------+---------------+-----------------+-------------|










                                                             AB 173
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         |Recommendations|SPI        |Not specified |SPI who        |SPI and SBE      |SPI          |
         | provided to   |           |              |forwards to    |                 |             |
         |whom?          |           |              |SBE,           |                 |             |
         |               |           |              |Legislature,   |                 |             |
         |               |           |              |Dept of        |                 |             |
         |               |           |              |Finance        |                 |             |
         |---------------+-----------+--------------+---------------+-----------------+-------------|
         |How are        |SPI may    |Not specified |Upon           |SPI may          |SPI may      |
         |recommendations|implement  |              |Legislative    |implement with   |implement    |
         | implemented   |with SBE   |              |action that    |SBE approval,    |with SBE     |
         |and when?      |approval   |              |appropriates   |SBE may          |approval     |
         |               |           |              |funds for this |implement as     |             |
         |               |           |              |purpose        |part of NCLB     |             |
         |               |           |              |               |plan, or state   |             |
         |               |           |              |               |may as part of   |             |
         |               |           |              |               |any other        |             |
         |               |           |              |               |federal plan     |             |
         |               |           |              |               |submitted        |             |
          ------------------------------------------------------------------------------------------