BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  SB 754
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          Date of Hearing:   July 6, 2011

                           ASSEMBLY COMMITTEE ON EDUCATION
                                Julia Brownley, Chair
                    SB 754 (Padilla) - As Amended:  April 6, 2011

           SENATE VOTE :   40-0
           
          SUBJECT  :   Pupil assessment: California English Language 
          Development Test

           SUMMARY  :   Prohibits a pupil in any of grades 3 to 12, 
          inclusive, to the extent permitted by federal law, from being 
          required to retake portions of the English language development 
          test (ELDT) for which he or she has previously achieved the 
          early advanced or advanced proficiency level within each 
          appropriate grade span determined by the California Department 
          of Education (CDE) in accordance with current law requirements 
          that the test be age and developmentally appropriate for pupils. 
           Specifically,  this bill  :  

          1)Prohibits implementation of this bill until such time as the 
            current test publisher's contract expires. 

          2)Makes several findings and declarations relative to English 
            learners (ELs), the ELDT, and the economic losses resulting 
            from pupils that drop out of school.   

           EXISTING LAW  : 

          1)Requires each school district that has one or more pupils who 
            are ELs to assess the English language development of each of 
            those pupils within 30 days of initial enrollment in order to 
            determine the level of proficiency of those pupils, and 
            annually thereafter to assess each EL pupil until the pupil is 
            redesignated as fluent English proficient. 

          2)Requires the assessment to include but not be limited to an 
            assessment of achievement of these pupils in grades 2-12, 
            inclusive, in English listening, speaking, reading, and 
            writing skills, and pupils in kindergarten and grade 1 (K-1) 
            in English listening, speaking, and until July 1, 2012, early 
            literacy skills.

          3)Specifies that the ELDT shall be used for the following 








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            purposes: 
             a)   To identify pupils who are limited English proficient; 
             b)   To determine the level of English language proficiency 
               of these pupils; and,
             c)   To assess the progress of these students in acquiring 
               the skills of listening, speaking, reading, and writing in 
               English. 

          4)Requires the ELDT, among other specifications, to be aligned 
            with the English language development standards and be age and 
            developmentally appropriate for pupils.

           FISCAL EFFECT  :  This bill is keyed non-fiscal; however, due to 
          possible fiscal impacts, the Assembly Rules Committee has 
          determined that this bill, if passed by this committee, will be 
          re-referred to the Assembly Appropriations Committee.

           COMMENTS  :   Background  :  Nearly 1.5 million of the state's 6.2 
          million students were identified as ELs during the 2009-10 
          school year, representing approximately 24% of the state's total 
          public school enrollment.  Current federal and state law require 
          schools to assess the English proficiency of all pupils whose 
          primary language is not English, and the California English 
          Language Development Test (CELDT) is the required state test for 
          English language proficiency.  The CELDT, aligned to the English 
          language development (ELD) standards adopted by the State Board 
          of Education (SBE), is required to be administered within 30 
          calendar days after an EL pupil is enrolled in a California 
          public school for the first time and once each year until the 
          pupil is reclassified as fluent English proficient.  The CELDT 
          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.  English learners in grades 2-12 are 
          administered the CELDT in the four domains of speaking, 
          listening, reading and writing, and English learners in K-1 one 
          are currently assessed in English listening, speaking, and early 
          literacy skills.

          This bill prohibits a pupil in any of grades 3 to 12, inclusive, 
          to the extent permitted by federal law, from being required to 
          retake portions of the CELDT for which he or she has previously 
          tested as early advanced or advanced within each appropriate 
          grade span as determined by the CDE.  Under the provisions of 








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          this bill, an EL who has previously performed at the early 
          advanced or advanced level on any of the domains of the CELDT 
          would be prohibited from being retested in those domains until 
          he or she reaches the next grade span.  The grade spans of the 
          CELDT are K-1, grade 2, grades 3-5, grades 6-8, and grades 9-12. 
           This bill only applies to pupils in grades 3-12.   

          The CELDT results are reported by five performance levels: 
          beginning, early intermediate, intermediate, early advanced, and 
          advanced.  The scale score for determining the overall 
          performance level score is calculated by weighting the domain 
          scale scores at 25% for each of the four domains for grades 
          2-12.  School districts are required to use CELDT results as one 
          of four criteria when considering reclassifying English 
          learners.  The other three criteria include teacher evaluation, 
          parental opinion and consultation, and the comparison of the 
          pupil's performance in basic skills against an empirically 
          established range or performance of English proficient students 
          of the same age that demonstrates whether the pupil is 
          sufficiently proficient in English to participate effectively in 
          a curriculum designed for pupils of the same age whose native 
          language is English. 

           In conflict with federal law requirements  :  Federal law requires 
          states to annually assess all Title III-served limited English 
          proficient pupils in each of the four language domains of 
          speaking, listening, reading and writing.  Additionally, Title I 
          also requires an annual English language proficiency assessment 
          in four language domains for all limited English proficient 
          pupils.  The provisions of this bill are in conflict with 
          federal law.  Some states have asked the U.S. Department of 
          Education (USDOE) whether they could exempt some of their 
          students from annual English language proficiency test in any 
          domain in which the student scored proficient and "bank" scores 
          until the student is proficient in all domains.  The USDOE notes 
          that both Title I and Title III require the annual assessment in 
          all four domains and that "banking" of scores is not an 
          appropriate practice.  A notice of final interpretations in the 
          Federal Registry states that the banking of the proficient 
          scores of LEP �limited English proficient] students in 
          particular domains, in any given year, including banking of 
          scores within grade spans, is not permitted.  This bill 
          specifies that its provisions are operative to the extent 
          permitted by federal law, however federal law does not allow 
          this practice, and thus the provisions of this bill are 








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          currently not implementable.  

          Assuming this bill could be implemented, this Committee may wish 
          to consider the following two potential implications of the 
          proposed policy:  

          Impact on reclassification  :  Language proficiency at one grade 
          level in any domain may not necessarily indicate proficiency in 
          the next or any subsequent grade level within a CELDT grade 
          span.  While the test is the same throughout each grade span, 
          the scale score ranges and cut points for each of the 
          proficiency levels vary by grade level, as the language demands 
          increase grade level after grade level and the expectations are 
          for ELs to make continuous growth in language skills year to 
          year.  If a pupil achieves early advanced in one grade level one 
          year, that score will not necessarily be within the early 
          advanced or advanced proficiency level in the next grade level.  
          For example, if a pupil scores 522 in the speaking domain in 
          grade 6 which is considered early advanced in grade 6, in grade 
          7 that pupil is considered to be at the intermediate level.  
          Since, under the proposal in this bill, the pupil will not have 
          to retake the test in grade 7 nor grade 8, the 522 score will 
          follow him or her through grade 8 and will keep that pupil at 
          the intermediate level in that grade span.  The problem arises 
          in calculating a pupil's overall score, for purposes of 
          reclassification using prior year test results.  Because all 
          four domains are used to calculate the overall score, if one or 
          more domain scores from prior years are now "lower" than had 
          been considered the prior year, the overall score on CELDT can 
          be negatively impacted.  Presumably, under the provisions of 
          this bill, the score an EL receives at the time he or she 
          "tests-out" of a specific domain will follow that pupil year 
          after year during a particular grade span, as long as he or she 
          is classified as EL.  Using CELDT data that is a year or more 
          old, may potentially result in an EL's overall CELDT score not 
          reaching the early advanced or advanced level in that grade 
          span, and thus creates the possibility that an EL would miss out 
          on opportunities to be reclassified as fluent English 
          proficient.   

           Impact on instruction  ?  In consideration that the early advanced 
          proficiency level in one domain in one grade level does not 
          necessarily represent the same proficiency level in the next 
          grade level, a question can be raised as to what the 
          implications might be on instructional services.  To the extent 








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          that the CELDT has any impact on instruction, an argument could 
          be made that not assessing an EL in a particular domain once 
          that pupil achieves the early advanced or advanced proficiency 
          level in one grade within a grade span, could have the effect of 
          limiting access to certain data that could be used for purposes 
          of instruction.  The author's staff suggests that one of the 
          benefits of this bill is that teachers would be able to target 
          instruction in the areas in which an EL needs the most support 
          in, as demonstrated by the pupil's scores on each domain of the 
          CELDT.  The idea being that once a pupil achieves the early 
          advanced or advanced level in certain domains, instructional 
          services should be focused on the domains in which that pupil 
          has yet to achieve at those levels.  While there is merit to 
          this goal, considering the points made in the previous 
          paragraph, the result could also be the loss of instructional 
          services in areas that the pupil may still need to focus on but 
          that test data would not show because the test would no longer 
          be administered.  Because there would still be opportunities for 
          student growth, the lack of data may have a detrimental impact 
          on instructional services for some ELs.  

          In an effort to address the potential negative impact this bill 
          could have on both reclassification and provision of 
          instructional services for ELs, the author has suggested an 
           amendment  to only prohibit retesting of the CELDT domains in 
          which an EL has achieved the advanced proficiency level.  
          Committee staff agrees that this amendment would reduce the 
          aforementioned concerns.    

          Proponents of this bill would argue that ELs are overly assessed 
          and that this is an attempt to reduce the amount of time spent 
          on testing and instead use that time for instructional purposes. 
           Further the author states, "Currently an EL who fails any 
          section of the CELDT is required to retake the entire exam, 
          including sections the student has previously passed. This is 
          contrary to the standards of many other state exams that test 
          proficiency of a given skill. Examples where students or 
          applicants are not required to retake previously passed sections 
          include the California High School Exit Exam; and the California 
          Basic Education Skills Test (CBEST) which examines the basic 
          skills of prospective teachers."

           Additional amendments  :  The findings and declarations in this 
          bill note that being required to retake the entire CELDT every 
          year is preventing ELs from being reclassified.  However, 








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          reports have shown that it is not necessarily the CELDT that 
          keeps ELs from reclassification.  As the Legislative Analyst's 
          Office points out, "Our look at the progress of EL students also 
          showed that a notable number of students score at the two 
          advanced levels for several consecutive years. These data 
          suggest that while many EL students may make gains in attaining 
          English proficiency, they still lack the academic skills 
          required by their local districts to be reclassified FEP �fluent 
          English proficient].  In making conclusions about EL 
          reclassification, several other issues need to be taken into 
          account, including the fact that reclassification criteria 
          varies from district to district, hence it is difficult to make 
          such a general conclusion about the CELDT preventing 
          reclassification.  Staff recommends  an amendment to delete this 
          language from the findings and declarations on page 3 lines 6-9. 
           

          On page 2 of the findings and declarations subdivision (b) 
          states that when a pupil fails to attain a sufficient score in 
          one area of the CELDT, the pupil fails the test.  The CELDT is 
          used to determine levels of proficiency and it is not a "pass or 
          fail" test.  The findings also state that ELs are classified or 
          reclassified in four ways and lists the four criteria used for 
          reclassification.  However the process for identifying ELs is 
          different than the reclassification process and the criteria for 
          reclassification are not meant to be four different stand-alone 
          ways to reclassify ELs.   Staff recommends  the language in the 
          findings and declarations be amended for purposes of 
          clarification.  While the findings and declarations are 
          uncodified, they are official declarations of the Legislature 
          and are part of the statutes.  Hence it is important that they 
          are accurate.          

           Federal initiative  :  The United States Department of Education 
          (USDOE) issued a notice for proposed grant priorities published 
          in the Federal Register on January 7, 2011 announcing a grant 
          opportunity for the development of English-proficiency tests 
          based on the common core state standards.  Consortia of states 
          may apply for a grant to develop an English proficiency 
          assessment system that is aligned to a set of ELD standards and 
          to the common core standards.  California has submitted an 
          application, as a lead state, for this grant, and if the grant 
          is awarded, a new ELD test would be developed in the future.   

           Arguments in support  :  Public Advocates writes, "Requiring 








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          students to retake sections of the CELDT which they previously 
          passed is detrimental to students' motivation, which drops when 
          they are required to keep taking a test they have already passed 
          combined with retaking the same courses over and over.  The 
          change in SB 754 will contribute to EL students' motivation to 
          perform at Early Advanced/Advanced level on CELDT and may also 
          contribute to increased motivation to meet other 
          reclassification criteria. California has an interest in 
          eliminating unnecessary barriers in the reclassification 
          process.  

           Related legislation  :  SB 753 (Padilla) makes changes related to 
          the timing of the administration of the required English 
          language development (ELD) assessments. SB 753 is pending in 
          this Committee and it is also scheduled to be heard today.  

           Previous legislation  :  AB 2077 (Fuentes) of 2008 required the 
          CDE to seek approval from the United States Department of 
          Education (USDOE) to allow California to exempt ELs from the 
          annual administration of the CELDT once an EL pupil achieved a 
          specified overall score and a minimum score on each of the four 
          domains of the CELDT.  AB 2077 was held in the Senate 
          Appropriations Committee. 

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          Alliance for a Better Community 
          Association of California School Administrators 
          California School Boards Association
          California State PTA
          California Teachers Association
          Californians Together 
          Coalition for Humane Immigrant Rights of Los Angeles 
          Contra Costa County Superintendents' Coalition
          Fresno Unified School District 
          Lieutenant Governor Gavin Newsom
          Los Angeles Unified School District 
          Mexican American Legal Defense and Educational Fund
          Public Advocates 
          San Francisco Unified School District 
          The Latin Business Association 
          Visalia Unified School District
          Youth Policy Institute 








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            Opposition 
           
          None on file. 

           Analysis Prepared by  :    Marisol Avi�a / ED. / (916) 319-2087