The Tennessee Department of Education is working to modify some of its K-12 assessment practices to comply with federal law.
Following a performance review, the U.S. Department of Education found several inconsistencies with the way the state was administering parts of the Tennessee Comprehensive Assessment Program.
State officials had until Dec. 1 to submit evidence that the findings had been corrected -- or they risked losing millions in Title I grants, additional federal dollars allocated to high-poverty schools.
While not all evidence was submitted by the deadline, fixes are ongoing, state and federal officials said.
"The department has submitted evidence on the majority of the findings noted in the report," Brian Blackley, director of media for the Tennessee Department of Education, said in an email. "For the outstanding items, the department has been in regular communication with the U.S. Department of Education on our plan to address."
According to a Sept. 27 letter to Tennessee Education Commissioner Penny Schwinn, the state practices violated the Every Student Succeeds Act and compromised the accuracy of student performance reporting.
"The assessment and accountability compliance issues are significant because they not only impact the state's ability to provide clear and transparent information to the public about school performance but also result in the state using information that is not comparable across schools in TDOE's statewide accountability system," the Sept. 27 letter said.
Different tests
The Every Student Succeeds Act governs national education policy and provides protections for disadvantaged students. These protections extend to testing methods and stipulate that states receiving Title I funds must use the same statewide assessment for all students.
But Tennessee used several different tests for high schoolers and, in some circumstances, used students' ACT and SAT math scores in place of state-issued math assessments.
"TDOE administered multiple assessments to students in high schools, rather than one single statewide assessment as required," U.S. Department of Education officials said in an email. "While a state can certainly have multiple statewide assessments, every student needs to be included in all of the statewide assessments. TDOE was permitting students to take different assessments and not all students took all of the assessments."
(READ MORE: Tennessee report shows slow academic growth for Hamilton County students)
In high school, Tennessee Comprehensive Assessment Program exams are given as end-of-course assessments, meaning students take them once they complete a certain class. This can occur at any grade level.
Middle schoolers also have the option to complete end-of-course exams if they are enrolled in advanced courses, but states must request a waiver -- which Tennessee failed to do. This caused errors in the way participation rates were calculated.
"Generally, for states like Tennessee that utilize an end-of-course assessment, rather than a grade-level assessment, the way to ensure that all students are included in the assessment system is to create a high school cohort," U.S. Department of Education officials said. "For example, a state might look at all 11th graders in the state to see how many took the end-of-course assessment at any point in grades 9, 10 or 11 to calculate a participation rate. TDOE had been using enrollment in the course in the current year to calculate participation rate, which may result in students being excluded from the assessment."
The TCAP includes three high school mathematics assessments, each with two progressions, and two progressions of English language arts, English I and English II. Though the state was administering the tests, it was only reporting results from two of the mathematics tests and English II, which is inconsistent with the law.
(READ MORE: 30% of Hamilton County Schools third graders may need summer literacy tutoring)
The state is addressing its use of multiple assessments, officials said.
"The department has been soliciting feedback from superintendents and other stakeholders and will be submitting an amendment to address in early 2023," Blackley said.
As to why the state used some ACT and SAT math scores in lieu of TCAP results, Blackley said it was so 11th grade students who had previously taken the end-of-course assessment in middle school had a math score.
This practice will end this year, Blackley said.
"It should be noted that Tennessee's state plan was approved by (the U.S. Department of Education). These required changes are a result of additional follow-up requirements by (the department)," Blackley said. "Tennessee will continue to administer assessments aligned to our state's rigorous standards. The entirety of Tennessee's assessment program is annually reviewed by a technical advisory committee made up of national experts in the field of educational testing and measurement to ensure the suitability of our tests for high-stakes purposes."
He said the state will apply for the required waiver for next year's testing.
Contact Carmen Nesbitt at cnesbitt@timesfreepress.com or 423-757-6327. Follow her on Twitter @carmen_nesbitt.