BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  SB 547
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          Date of Hearing:   July 6, 2011

                           ASSEMBLY COMMITTEE ON EDUCATION
                                Julia Brownley, Chair
                   SB 547 (Steinberg) - As Amended:  June 13, 2011

           SENATE VOTE  :   Vote not relevant
           
          SUBJECT  :   Public school performance accountability

           SUMMARY  :   Replaces the state's current measure of school and 
          school district academic performance, the Academic Performance 
          Index (API), with the Education Quality Index (EQI), an index of 
          school and school district quality that is comprised of multiple 
          indices, each reflecting a different dimension of school or 
          district performance.  Specifically,  this bill  :   

          1)Makes findings and declarations as to the challenges faced by 
            and the needs of California's pupils.

          2)Makes findings and declarations regarding the state's current 
            accountability system and the opportunity presented to 
            transition to a new approach.

          3)States Legislative intent that the API evolve to encompass 
            other valuable metrics in addition to test scores, graduation 
            rates and dropout rates, and that a more comprehensive set of 
            expectations and aspirations for California's public schools 
            be reflected in the state's school accountability system.

          4)Makes current law implementing the API inoperative on July 1, 
            2013 and repealed as of January 1, 2014.

          5)Requires the Superintendent of Public Instruction (SPI), in 
            consultation with the current Public School Accountability Act 
            (PSAA) advisory committee, to develop the EQI system for 
            schools and school districts, and requires the State Board of 
            Education (SBE) to adopt the EQI no later than August 1, 2013, 
            and after providing for public input.

          6)Requires, commencing with the 2013-14 school year, all schools 
            and school districts to be evaluated using the EQI.

          7)States Legislative intent that the EQI provide a comprehensive 
            and transparent measurement of pupil performance and school 








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            quality to better inform parents, pupils, teachers, school 
            administrators, policymakers, and the public about public 
            school performance using multiple indicators of pupil, school, 
            and school district quality and performance.

          8)Requires the EQI to be to be developed for each school type 
            and school district, and to include, but not be limited to, 
            the following:
             a)   For schools and school districts maintaining any of 
               grades 9 through 12, the: 
               i)     State Assessment Index (SAI).
               ii)    Graduation Rate Index (GRI).
               iii)   College Preparedness Index (CPI).
               iv)    Career Readiness Index (CRI).
             b)   For schools and school districts maintaining grade 8, 
               the:
               i)     SAI.
               ii)    GRI.
               iii)   A valid and reliable measure or measures of pupil 
                 access to and performance in college and career 
                 preparatory and exploratory experiences is to be 
                 considered, if maintained in that school.
             c)   For schools and school districts maintaining 
               kindergarten or any of grades 1 to 7, inclusive, the SAI.

          9)Requires the SPI, in consultation with the PSAA advisory 
            committee, to develop and recommend to the SBE for adoption:
             a)   The component indices listed in 8) a) above for school 
               districts and for each school type, including alternative 
               schools, as specified.
             b)   The relative weights of the component indices, and a 
               total value for the EQI, consistent with the following 
               requirements:
               i)     For schools and school districts maintaining 
                 kindergarten and any of grades 1 through 8, the SAI is 
                 required to comprise no less than 40 percent of the value 
                 of the EQI.
               ii)    For schools and school districts maintaining any of 
                 grades 9 through 12, the SAI is required to comprise no 
                 more than 40 percent of the value of the EQI.
               iii)   Within the EQI, the weights assigned to the CPI and 
                 CRI are required to be equal.
             c)   No less than one additional component index for schools 
               maintaining kindergarten or any of grades 1 through 7.
             d)   An annual ranking or evaluation system for the EQI.








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             e)   An annual growth target for the SAI and the GRI, 
               including targets for numerically significant pupil 
               subgroups, defined to be subgroups with more than 50 pupils 
               with valid test scores.
             f)   Whether a growth target or an annual measurement of the 
               narrowing of the achievement gap should be established for 
               each additional component index, including targets for 
               numerically significant pupil subgroups.
             g)   The relevant indices and indicators necessary to meet 
               and comply with federal law.
             h)   Any additional data elements, and connections between 
               existing data systems, that are identified as needed, after 
               consulting with the state's three higher education 
               segments, the Employment Development Department, and other 
               appropriate entities.

          10)Requires the SPI to annually release results and supporting 
            information on the EQI and its component indices.

          11)Requires the SPI, in consultation with the PSAA advisory 
            committee and when additional valid and reliable data become 
            available, to develop and recommend to the SBE additional 
            indices, as specified, and to take into account the 
            appropriateness of particular indices and indicators to grade 
            spans and school types; also prohibits any additional 
            component index from being included in the EQI until one full 
            school year after its adoption by the SBE.

          12)Requires the SPI, no later than July 1, 2014, to report to 
            the Governor and the Legislature on the development, 
            implementation and impacts of the EQI and its component 
            indices, and requires the SPI, in consultation with the PSAA 
            advisory committee and no later than July 1, 2018, to report 
            to the Governor and the Legislature on the effectiveness and 
            reliability of the EQI and any statutory changes needed for 
            improvement.

          13)Specifies that the SPI not be limited in the development of 
            the EQI by the scope of the California Longitudinal Pupil 
            Achievement Data System (CALPADS) or any other relevant data 
            system.

          14)Authorizes the SPI to develop and recommend to the SBE for 
            adoption any regulations necessary to implement these 
            provisions.








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          15)Requires the SAI to be comprised of pupil scores from the 
            state's current standards-based achievement tests or any valid 
            and reliable successor assessments adopted by the SBE, and the 
            high school exit examination; also specifies inclusion and 
            exclusion rules, disaggregation requirements, and reporting 
            requirements and authorities.

          16)Requires the GRI to be comprised, as appropriate to the grade 
            configuration of the school or school district, of:
             a)   Four-year, five-year, and six-year graduation rates, 
               that are appropriate to school types and where schools and 
               districts are required to be granted full value for 
               graduating, in five or more years, pupils with 
               disabilities.
             b)   Rates, as determined to be appropriate, at which pupils 
               successfully promote from one grade to the next.

          17)Requires the CPI to be comprised of multiple valid, reliable, 
            and stable measures of pupil preparedness for postsecondary 
            education, that may include, but is not limited to district, 
            school and subgroup rates reflecting completion of:
             a)   Courses that fulfill the admission requirements for 
               California's four-year public universities.
             b)   College preparedness assessments, such as the Early 
               Assessment Program (EAP), the Preliminary SAT (PSAT), the 
               SAT and the ACT, as administered to high school pupils, and 
               rates at which pupils who complete these assessments can 
               demonstrate they do not need remedial coursework in order 
               to perform college-level work.
             c)   College preparatory and accelerated learning 
               opportunities, at a satisfactory level.

          18)Requires the CRI to be comprised of multiple valid, reliable, 
            and stable measures of pupil readiness for career, including, 
            but not limited to:
             a)   Rates at which pupils satisfactorily complete a 
               designated career pathway.
             b)   Rates at which high school pupils earn an industry 
               validated certificate, license, or the equivalent in the 
               designated occupation for which it is issued, or rates at 
               which pupils are on track to earn such.
             c)   The performance of pupils on assessments designed to 
               assess the degree to which pupils have acquired the skills 
               and knowledge necessary to be successful in a specified 








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               occupation or in the general workforce.
             d)   Rates at which pupils move on to additional training or 
               employment, or generate earnings related to that training 
               and employment.  

           EXISTING LAW  requires:

          1)The SPI 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.  

          2)School districts to offer to all otherwise qualified pupils in 
            seventh through twelfth grades both of the following:

             a)   A course of study fulfilling the requirements and 
               prerequisites for admission to California's public 
               institutions of postsecondary education. 

             b)   A course of study that provides an opportunity to attain 
               entry-level employment skills in business or industry upon 
               graduation from high school.

           FISCAL EFFECT  :   Unknown

           COMMENTS  :   The SPI established, pursuant to SB 1 X1 (Alpert), 
          Chapter 3, Statutes of 1999-2000 First Extraordinary Session, 
          the PSAA 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 for 
          reporting and accountability purposes, 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.

          Having an API that focuses solely on achievement test results 
          may be too narrow in that it does not reflect information about 
          other student outcomes (e.g., dropout and graduation rates, 
          college readiness, preparation for the workplace) that is 
          important in measuring the performance of districts, schools and 
          subgroups.  In addition, focusing solely on test scores may 








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          actually lead to conclusions that are incorrect; as a perverse 
          example, a school that sees an increase in the number of 
          students dropping out could easily see a resulting increase in 
          test scores, and thus in the API for that school or district (if 
          the students dropping out tended to have below average test 
          scores), yet most would agree that this increase in test scores 
          and API are not reflective of an improvement in performance or 
          the quality of education in that school or district.  The 
          solution to this problem would be to broaden the set of measures 
          that are composited to form the accountability measure.  The 
          Legislature foresaw this when it initially authorized the 
          development of the API to be an index (i.e., a composite number 
          reflecting a number of component measures) based on data from 
          multiple measures, including achievement test results, 
          attendance rates, and graduation rates.

          Opponents of including anything other than results on the 
          state's achievement test results in the API argue that including 
          data on other assessments, dropouts, graduation rates, and other 
          non-testing dimensions of educational performance will both 
          dilute the meaning of the API and skew its emphasis toward high 
          schools, resulting in the focusing of more resources at that 
          level to the detriment of elementary and middle schools.  The 
          dilution argument assumes that state achievement test results 
          incorporate and reflect all aspects of school performance, or at 
          least the only important aspect; the increasing incidence of 
          high achieving pupils dropping out of high school is a counter 
          example to the claim that test scores alone show how well a 
          school is serving its pupils.  In addition, since the 
          Legislature can target the use of resources by grade span as 
          well as by API ranking, this effect, to the extent that it would 
          exist, could be easily moderated.

          Currently, California's public school accountability system has 
          no mechanism for measuring success in terms of outcomes or 
          opportunities beyond performance on core academic assessments, 
          including civic and community responsibility, career or college 
          readiness and acquisition of life skills; the current 
          accountability system also has no way of identifying or 
          rewarding those schools that educate the whole pupil in any way 
          other than is measured by testing skills and knowledge in 
          mathematics, language arts, history and science.

          The indices proposed in this bill are intended to replace and 
          augment the information composited in the current API, thus 








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          including information on student opportunities and student 
          success so as to provide broader and more comprehensive 
          information on school performance than is available from the API 
          focus on achievement test scores alone.  The proposed EQI would 
          aggregate information from at least four sub-indices, each 
          related to different dimensions of student performance and 
          opportunity, including academic performance, advancement and 
          graduation rates, preparation for career or post-secondary 
          education, and enhanced student learning opportunities.  
          Academic performance, in the form of STAR test results in a 
          limited number of subject areas, are included in the API; 
          attendance and graduation rates are authorized to be included in 
          the API by the SPI, but have never been so included.  The 
          remaining areas of performance or opportunity are not authorized 
          to be included in the API, although the state does produce 
          various individual indicators related to some of these 
          dimensions.

          According to the author, "The existing Academic Performance 
          Index (API) has encouraged schools/districts to focus so hard on 
          test scores that other important aspects of education have been 
          deemphasized. Career technical education, arts and music, work 
          experience and other important learning has been marginalized in 
          favor of coursework that improves scores in tested subjects. 
          Creativity, communication skills, the ability to work in teams, 
          soft skills (in addition to academic proficiency) - all are 
          important aspects of a well-rounded education, and our system of 
          public school accountability needs to better reflect that."  The 
          author also indicates that incorporating college and career 
          readiness indicators into accountability systems for high 
          schools is not a new idea, in that it has been used in other 
          states, including Florida, which began holding high schools 
          accountable for participation and performance in Advanced 
          Placement courses or completing other college-level work while 
          still in high school, and Colorado, which in 2009 incorporated 
          postsecondary and workforce readiness into its school ranking 
          system.

          The author summarizes the motivation for this bill by stating 
          that, " It is time for the API to evolve to what it was 
          originally intended to be: an index that encompasses other 
          valuable indicators in addition to student test scores. These 
          additional indicators should include rates of graduation and 
          promotion from one grade to the next; rates of student readiness 
          for college and career; and measures of student engagement and 








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          achievement in subjects areas outside the academic core 
          curriculum, including the arts."

          The proposal in this bill for a comprehensive expansion of the 
          accountability measure that are used to provide public 
          information on and make state-level accountability judgments 
          about the state's K-12 public schools, provides the clear 
          benefit of basing that information on and judgments about 
          schools on a broader base of multiple measures of the 
          characteristics that define school success or failure.  The lack 
          of this broad base of multiple measures has long been a 
          criticism of the API.  However, this proposal is not without its 
          problems, most of which could be overcome, or else ignored as 
          part of the tradeoff for better accountability information; 
          these problems include:

          1)The bill provides for a discrete transition from the API to 
            the EQI system, with no overlapping period when both measures 
            are being produced.  This means, unless the SAI exactly 
            reflects the current composition of the API, that there will 
            be no public comparability between the API accountability 
            information that is produced for the 2012-13 fiscal year and 
            that produced under the EQI system for the 2013-14 fiscal 
            year.  Certainly enough technical information on the API is 
            available to allow the research community to produce 2013-14 
            APIs for comparison purposes, but the Legislature may wish to 
            consider whether a one-year overlap in reporting for the two 
            measures would enhance public information and further the 
            understanding of the proposed new accountability measures.

          2)Descriptive statistics, such as rates, averages and indices, 
            are commonly used in public policy analysis and in many other 
            situations where there is a large amount of raw data that 
            would be difficult for any individual to process and 
            understand; descriptive statistics typically combine this data 
            into a single number that is easier to grasp.  However, the 
            downside of this approach is that when the data is combined or 
            composited into the descriptive statistic, information 
            embedded in the raw data is lost.   In the case of any index, 
            including the API or any of the EQI-related indices, changes 
            in any one of the dimensions measured in that index will lead 
            to changes in the value of the index, even if there are no 
            changes in any of the other dimensions.  Effectively this 
            means that as a greater number of dimensions are composited 
            into the index, it becomes more difficult to gain a detailed 








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            understanding of what is really happening at the school or 
            district from an examination of the value of the index alone.  
            The index basically becomes a pure number, and the reasons for 
            that number either rising or falling could be tied to so many 
            factors (and the interactions of those factors) that drawing 
            policy conclusions about what works or doesn't in that school 
            or district may be difficult.  This would be especially true 
            with the EQI, where so many different dimensions, each with a 
            number of specific pieces of data included, are composited 
            into the index; the production of the sub-indices (SAI, GRI, 
            CPI, and CRI)  proposed by this bill may mediate this problem 
            to some effect, but likely not entirely.

          3)The bill specifies what dimensions and, in some cases, data 
            should be included in the various indices in the EQI system, 
            but does not specify how those elements should be composited 
            into the indices.  Instead the bill leaves much of the 
            determination of how specified data elements are incorporated 
            into the various indices (i.e., the methodology for 
            calculating each index) up to the technical advisory group 
            that was formed to advise the SPI and SBE on the API.  On one 
            hand, this work is so technical that it should be ministerial 
            and not incorporated into statute.  At the same time, clearly 
            the results of any accountability index, and thus the 
            outcomes, rewards, interventions and sanctions that may be 
            part of the associated accountability system, will depend on 
            the specific methodology used to make the necessary 
            calculations.  The Legislature may want to consider whether it 
            wishes to grant complete authority to the SPI and SBE to 
            review and adopt the methodology for calculating the indices, 
            and thus for determining how schools and districts fare in any 
            resulting rankings or outcomes.

          4)Though inclusion of graduation rates in the API is in current 
            law, authority was provided to the SPI to determine when data 
            on graduation rates would be included in the API; at this 
            point in time, test scores remain as the only data on which 
            the API is based.  Opponents of past proposals to include 
            additional data, such as graduation rates or course completion 
            rates, in the API have argued that data on these other 
            dimensions suffer from three problems: a) non-testing data are 
            less objective in nature than testing data, and thus do not 
            reflect pure academic outcomes; b) data on other dimensions 
            are not robust enough for this type of use and thus may 
            reflect very different outcomes in different schools or 








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            districts; and c) it is unclear how the state would measure or 
            collect data on certain dimensions, such as whether courses of 
            study fulfill university admission requirements or how well 
            schools and districts prepare students for the workplace.
                                 
          5)With respect to the collection, or the existence of, specific 
            data elements, which are required by this bill to be included 
            in the EQI system, it is unclear that all of these data 
            elements are collected or available, or if they will be 
            available at any time in the near future.  To the extent that 
            some of these data are not available, that would either reduce 
            the base of multiple measures included in the EQI or have 
            clear cost implications for the implementation of this 
            proposal.

          6)Implementation of the EQI system, and the repeal of the 
            current API, would have ripple effects through the Education 
            Code (EC) and the programs that are authorized and mandated 
            therein.  A quick search of the EC shows that there are nearly 
            80 sections of code that reference either the API or the 
            Academic Performance Index; these references range from 
            non-substantive mentions to situations where the API is used 
            to define program eligibility or to condition funding or 
            compliance with a programmatic requirement.  Clearly an 
            extensive clean-up effort would be needed to conform the EC to 
            these changes.  The implementation timeline in the bill would 
            require that this clean-up effort occur during this 
            legislative session.

          Committee Amendments: Other issues in the bill can be addressed 
          through Committee amendments; Committee staff recommends the 
          following amendments to the bill:

          1)This bill proposes the transition between the API and the new 
            EQI measures to occur between the 2012-13 and 2013-14 fiscal 
            years.  Many aspects of assessment and accountability at the 
            state and federal level will be in transition in the near 
            future.  It is likely that the reauthorization of the federal 
            Elementary and Secondary Education Act (ESEA, though the 
            current authorization is referred to as NCLB) will move 
            forward during 2013, the main part of the state's testing 
            program becomes inoperable on July 1, 2013 (though pending 
            legislation approved by this Committee moves that date to 
            2014), and a national assessment consortium in which 
            California is participating will bring its work toward an end 








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            in 2014.  Changes, especially in the underlying assessment 
            system, should pre-date changes in the state's accountability 
            system so that the technical advisory committee developing the 
            methodology for calculating the EQI and its component indices 
            have knowledge of what the underlying data will look like.  In 
            addition, developing the proposed SAI in a post- ESEA 
            environment might increase the possibility of developing one 
            index that satisfies both state and federal needs, thus 
            eliminating the two measure federal/state approach that has 
            been confusing in recent years.  For these reasons, the bill 
            should be amended to move the transition timeline such that 
            the current API becomes inoperable on July 1, 2014, and the 
            new system comes on line for the 2014-15 fiscal year.

          2)If the amendment in 1) above is approved by the Committee, 
            then conforming amendments to timelines and deadlines 
            specified in other sections of the bill (e.g., reporting 
            timelines) should also be made.

          3)The bill requires the SPI to provide an annual status report 
            on various aspects of the EQI system and the related work of 
            the PSAA advisory committee to the Governor and the 
            legislature.  In order to ensure a full accounting of the 
            status of the system, technical clarifications concerning 
            specific report elements should be made. 

          4)The bill maintains the structure and charge of the PSAA 
            advisory committee; conforming amendments are necessary to 
            extend the authority of this committee to include work on the 
            EQI system that is referenced elsewhere in this bill.

          5)By making the current API system inoperable and repealed, the 
            bill eliminates the Alternative Schools Accountability Model 
            (ASAM).  Under the current system, the API scores of community 
            schools, continuation high schools and non-public schools that 
            serve special education pupils are not considered reliable due 
            to both small numbers of scores and the fact that most pupils 
            are placed in the schools for less than a year.  Accordingly, 
            the SPI is directed in current law to develop an alternative 
            accountability system under which these schools may receive an 
            API score, but are not included in API rankings.  The ASAM is 
            the alternative system developed by the SPI for this purpose.  
            This bill should be amended to provide an alternative method 
            for determining the success of alternative schools.









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          6)The bill makes a substantive change to reporting requirements 
            for subgroups that is not consistent with amendments that this 
            Committee took in support of additional reporting of subgroup 
            data during the Committee's consideration of SB 512 (Price); 
            this bill should be amended to maintain the current definition 
            of a numerically significant subgroup, and thus leave any 
            statutory changes in this area as an issue for SB 512 to 
            address.

          7)At the request of and as a courtesy to the author, Committee 
            staff recommends that the bill be amended to make technical 
            changes to the uncodified findings specified in Section 1 of 
            the bill.

          Previous and related legislation:  AB 224, (Bonilla), pending in 
          the Senate Education Committee, requires the SPI, in 
          consultation with the SBE, to incorporate both previously 
          specified, as well as additional, measures of performance into 
          the API, using the best available data and commencing in the 
          2012-13 fiscal year.  AB 400 (Nunez), vetoed in 2007, was 
          substantially similar to AB 224.  AB 519 (Mendoza), held in the 
          Senate Appropriations Committee in 2007 but later amended to a 
          different subject, would have required the incorporation into 
          the API of data regarding the availability in high schools of a 
          course of study that fulfills University of California and 
          California State University admission requirements, and the 
          submission of a plan for incorporating dropout data into the 
          API.  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 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  








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          PSAA Advisory Committee and development of the API.

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          America's Edge California
          Association of California School Administrators (if amended)
          California Agricultural Teachers' Association
          California Alliance for the Arts
          California Association of School Counselors
          California Business Education Association
          California Manufacturers and Technology Association
          California School Boards Association
          Hispanas Organized for Political Equality
          Los Angeles Unified School District
          Superintendent of Public Instruction Tome Torlakson (Sponsor)
          The University of California

           Opposition 
           
          None on file

           Analysis Prepared by  :    Gerald Shelton / ED. / (916) 319-2087