BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  SB 753
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          Date of Hearing:   July 6, 2011

                           ASSEMBLY COMMITTEE ON EDUCATION
                                Julia Brownley, Chair
                     SB 753 (Padilla) - As Amended:  May 31, 2011

           SENATE VOTE :   39-0
           
          SUBJECT  :   Pupils: English learners: assessment

           SUMMARY  :   Makes changes related to the timing of the 
          administration of the required English language development 
          (ELD) assessments.  Specifically,  this bill  :   

          1)Makes current law, with respect to the timing of ELD 
            assessments of English learners (ELs), inoperable following 
            the 2012-13 school year.

          2)Requires, commencing with the 2013-14 school year, the annual 
            ELD assessment of ELs, using the test specified for that 
            purpose, to be conducted annually during a three-month testing 
            window that begins with the day upon which 65 percent of the 
            instructional year is completed.

          3)Requires a school district to conduct an assessment of a pupil 
            at the pupil's initial enrollment to determine if the pupil is 
            an EL; also requires the prior year's test, for the grade in 
            which the pupil is being enrolled, to be used for this initial 
            assessment.

           EXISTING LAW  :

          1)Requires each school district that has one or more pupils who 
            are ELs to assess each pupil's ELD, using a test acquired or 
            developed by the Superintendent of Public Instruction (SPI) 
            with the approval of the State Board of Education (SBE), in 
            order to determine the level of proficiency upon initial 
            enrollment, and annually, thereafter, until the pupil is 
            redesignated as English proficient. 

          2)Requires the SPI and the SBE to establish procedures for 
            conducting the ELD assessments, including determining the 
            period of time within which the annual ELD testing is required 
            to be conducted. 









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          3)Requires the California Department of Education (CDE) to 
            develop reclassification procedures that utilize multiple 
            criteria in determining whether to reclassify a pupil as 
            proficient in English, including, but not be limited to, the 
            following:
             a)   Assessment of language proficiency.  
             b)   Teacher evaluation.
             c)   Parental opinion and consultation.
             d)   Comparison of the pupil's performance in basic skills 
               that demonstrates whether the pupil is sufficiently 
               proficient in English to participate effectively in a 
               curriculum designed for native English speaking pupils of 
               the same age.

           FISCAL EFFECT  :   According to a Senate Appropriations Committee 
          analysis of a similar proposal in 2008, "The bill's requirement 
          to move the testing window to at least 65 percent of the way 
          into the school year would result in one-time costs for standard 
          setting (essentially, this means adjusting results based on the 
          age of test takers) of $200,000 or $300,000.  Also, �CDE] is 
          concerned that the later testing window would compel a second 
          administration of the test to some pupils in order to comply 
          with Federal law, resulting in a cost of $1 million." 

           COMMENTS  :   Nearly one quarter of the student population in 
          California's public schools are classified as ELs and closer to 
          one half of the state's pupils come from homes where English is 
          not the primary language.  Current law requires schools to 
          assess the English proficiency of all pupils whose primary 
          language is not English, using an ELD test acquired or developed 
          by the SPI with the approval of the SBE; the California English 
          Language Development Test (CELDT) was developed and is required 
          as the assessment to be used for this purpose.  The ELD test is 
          used for three purposes:  (1) to identify new students who are 
          English learners in kindergarten through grade twelve; (2) to 
          determine the level of English-language proficiency; and (3) to 
          annually assess ELs progress in learning English until they are 
          reclassified.  

          ELs in grades 2-12 are administered the ELD test, which assesses 
          those pupils in four domains: speaking, listening, reading and 
          writing.  ELs in kindergarten and grade one are also assessed in 
          English listening and speaking, and, since 2009, have also been 
          assessed in early literacy skills, including the areas of 
          reading and writing.  The changes in 2009 were made in order to 








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          conform to the requirements of Title III under the federal 
          Elementary and Secondary Education Act, the current version of 
          which is known as the No Child Left Behind Act (NCLB).

          Current law requires annual ELD testing to be conducted during a 
          period determined by the SPI and SBE; the annual testing window 
          for the CELDT is currently from July 1 to October 31.  This bill 
          proposes to specify in statute and change that testing window 
          for the annual administration of the ELD test to be a three 
          month period commencing with the day upon which 65 percent of 
          the instructional year is completed.  This approach to setting a 
          testing window is fairly standard and sound from a policy 
          perspective, in that it ensures that testing of pupils occurs 
          after approximately the same amount of instructional time in the 
          year has elapsed, independent of any variations in school 
          calendars across schools and districts.  The approach is also 
          used in other California testing programs; for example, in the 
          Standardized Testing and Reporting (STAR) Program, the testing 
          window is specified to be a 25-day period comprised of the 12 
          days before and 12 days after the day on which 85 percent of the 
          instructional year is completed.  For a school district offering 
          180 days of instruction, this proposal would lead to a 
          three-month testing window opening on the 117th day of 
          instruction; for most school calendars this would mean testing 
          would occur sometime between late February and the end of May. 

          According to the author, the change in the testing window from 
          the fall to the spring is needed because "ELs are required to 
          take the CELDT immediately following their summer break. This 
          time of year does not allow ELs to prepare or practice their 
          English language skills at their new grade level."  The author 
          goes on to say that, "Moving the CELDT to the Spring would give 
          teachers more opportunity to prepare students for the test which 
          would increase the reclassification rate."  However, 
          implementing a policy in order to generate a test preparation 
          effect may not be good policy, in that it may artificially 
          inflate pupils' test results, lead to results that do not 
          reflect a pupil's true language proficiency, and thus not be in 
          the pupil's best interests.

          The sponsor of the bill, the Los Angeles Unified School 
          District, states that the proposed change in the testing window 
          would "assist our teachers in accessing timely CELDT scores for 
          purposes of appropriate placement and reclassification of our 
          �ELs] in the fall?"  Effectively the argument is that spring 








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          testing means that test results are returned in time to provide 
          input into decisions about pupils that are made prior to the 
          beginning of the next school year in the fall; though that is 
          also true of testing in the previous fall, fall testing would 
          provide results that are potentially stale in that they would 
          not reflect any gains made by the student in the school year in 
          which he or she were tested.  The author supports this point by 
          stating that the change "would provide teachers a more current 
          status of language skills of EL students?"

          The issue that this bill would resolve was noted in the 
          Proposition 227 Year Five evaluation report, published by the 
          American Institutes for Research (AIR) in 2006; AIR found that 
          the deadline for reporting reclassification results is out of 
          sync with the calendar of required assessments, and that the 
          timing and availability of assessment results complicate local 
          reclassification procedures.  The report states, "School 
          Districts experience significant pressure carrying out 
          redesignation procedures and completing counts of redesignated 
          students in time for the Language Census February 28 deadline.  
          Moreover, some districts noted that this short February time 
          window is further compressed as they also require parents to 
          meet one-on-one with educators, participate in the redesignation 
          process, and/or sign off approving the decision to redesignate." 
          In addition, the report further points out that "several 
          districts in the study noted that they have had to grossly 
          underreport the number of students redesignated in those years 
          where the test publisher delayed providing their particular 
          results."

          There are three technical issues that the bill potentially 
          raises, though it is uncertain that these problems would arise.
          1)The proposed ELD testing window would overlap with the testing 
            window for several other tests administered as part of the 
            state testing program.  For example, all of the tests 
            administered in the STAR program, as mentioned above, are 
            administered in a 25-day window centered on the instructional 
            day that falls 85 percent of way through the instructional 
            year (in most districts this would be in an April-May window), 
            the high school exit examination generally has two spring 
            administration dates established by the SPI, the state's 
            physical fitness testing is administered in February through 
            May, and both Advanced Placement (AP) and SAT examinations, 
            used for college admission purposes, are administered in the 
            spring.  Since these other tests, some with higher stakes for 








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            the individual pupil, are administered in the spring, an 
            argument could be made that adding another test during the 
            same period of time may result in additional testing fatigue, 
            which could have an effect on pupils' test results; in 
            addition, clustering all of the state testing in the spring 
            means that any instructional time lost to testing occurs 
            during that single semester.

          2)There also may be technical psychometric issues that arise 
            from moving the testing window.  For example, the scores or 
            score scale, as well as the resulting standard setting that 
            ties those scores to a reported outcome level, for large 
            assessments is often sensitive to the time the test is 
            administered; in other words, the scores and levels reported 
            for the current ELD test have been established based on data 
            generated by testing in the fall, thus a given score may not 
            represent the same level of language proficiency if it is 
            achieved as a result of testing at a different time of the 
            year.  The author effectively acknowledges that scores may be 
            different, by stating that "Moving the CELDT to the Spring 
            would give teachers more opportunity to prepare students for 
            the test which would increase the reclassification rate."  
            This would be beneficial if the change reflects a true 
            increase in language proficiency, but not necessarily 
            beneficial if the higher reclassification rate is only related 
            to moving the test to a later date.  In order to examine this 
            issue, it may be necessary for the CDE to conduct additional 
            statistical research or to reset the standard levels on the 
            test.

          3)Enactment of this proposal may potentially create a conflict 
            with federal requirements for ELD testing of EL pupils under 
            NCLB that specify that such testing must be administered to 
            each EL pupil annually.  Under this bill, existing EL pupils 
            will be tested during the current fall 2012 testing window, 
            but would then not be tested again until the new spring 2014 
            testing window; if the interpretation of the federal 
            requirement is that "annual" testing implies either testing on 
            a twelve month cycle or testing at some point during each 
            calendar year, then the federal requirement would not be met 
            during 2013.  If, however, the federal interpretation of this 
            requirement is that "annual" means that ELD testing is 
            administered to EL pupils at some point during each school or 
            fiscal year, then the transition proposed by this bill would 
            meet the federal requirement.  Committee staff recommends that 








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            the Chair ask the SPI and SBE to clarify this requirement with 
            the U.S. Department of Education.  If that clarification 
            indicates that this transition does not comply with the 
            federal requirement, then one of two courses of action could 
            be followed prior to the 2013-14 change in the testing window: 
            1) the state could seek a federal waiver from this requirement 
            for the purposes of making the transition from a fall to a 
            spring testing window, or 2) absent a federal waiver, clean-up 
            legislation might be necessary to allow additional fall 
            testing administration in 2013 only.

          Committee amendments:  Committee staff recommends that the bill 
          be amended to address the following issues:

          1)Clarify, consistent with the original intent of the 
            legislature, that all ELs in school districts, county offices 
            of education or charter schools be assessed using the English 
            language development test required to be used. 

          2)The bill requires ELD testing of all pupils, regardless of 
            apparent language proficiency, upon their initial enrollment; 
            this requirement exceeds current law and would dramatically 
            increase costs for administration of the program.  The bill 
            should be amended so as to require, as under current law, that 
            all new pupils be tested if they would also be tested in the 
            annual ELD assessment.

          3)The ELD test is not required to be the sole source of 
            information used by an LEA to determine whether a pupil is an 
            EL (see subdivision (d) of Education Code Section 313), nor 
            would that practice be advisable from an educational or 
            assessment policy perspective; the bill, however, implies this 
            by requiring that a district conduct the initial ELD 
            assessment of a pupil " to determine if the pupil is an 
            English learner?".  The bill should be amended to clarify that 
            the initial assessment provides information for that 
            determination, rather than directly determines the pupil's 
            language proficiency classification. 

          4)The bill requires the prior year's test, for the grade in 
            which the pupil is being enrolled, to be used for the initial 
            assessment of a newly enrolled pupil; however, if the pupil is 
            initially enrolling during the testing window for the current 
            year, then that initial testing could be conducted as part of 
            the annual testing, thus reducing costs and testing time; the 








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            bill should be amended to allow for this exception to the 
            requirement that initial testing use the prior year's test.

           Previous legislation  : SB 521 (Romero) held in the Senate 
          Appropriations Committee in 2009, was substantially similar to 
          this bill.  AB 2077 (Fuentes), held in the Senate Appropriations 
          Committee in 2008, would have made changes related to the 
          administration and scoring of the English language development 
          test, including moving the testing window to a three-month 
          period in the spring.  AB 748 (Escutia), Chapter 936, Statutes 
          of 1997, requires the development of a statewide test of English 
          language development for English learners and requires all 
          districts to use it to assess their English learners.

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          Boyle Heights Learning Collaborative
          California Association for Bilingual Education
          California Federation of Teachers
          California State PTA
          California Teachers of English to Speakers of Other Languages
          Californians Together
          Central American Resource Center - Los Angeles
          Coalition of Humane Immigrant Rights of Los Angeles
          Fresno Unified School District
          Green Dot Public Schools
          Hispanas Organized for Political Equality
          InnerCity Struggle
          Latin Business Association
          Lieutenant Governor Gavin Newsome
          Long Beach Unified School District
          Los Angeles Area Chamber of Commerce
          Los Angeles Unified School District (Sponsor)
          Mayor Antonio Villaraigosa
          Mexican American Legal Defense and Educational Fund
          National Council of La Raza
          Parent Revolution
          Public Advocates
          San Francisco Unified School District
          Service Employees International Union
          United Teachers of Los Angeles
          Vaughn Next Century
          Youth Policy Institute








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            Opposition 
           
          Association of California State Administrators

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