Timeline for Proposed Rules

The latest Iowa Administrative Bulletin was published yesterday, but the State Board of Education’s proposed rules adopting the Smarter Balanced Assessments were not published in it, as the State Board met after the September 11th submission deadline for inclusion in the September 30th bulletin. I believe this means that comment period for the proposed rules has not yet opened.

If the proposed rules are published October 14th, the comment period would open and run until November 3rd. The earliest possible adoption date would be November 18th, which happens to be the date of the State Board’s November meeting.

If the proposed rules aren’t published on October 14th, look for a new comment period and hearing date, with adoption no sooner than the January 21, 2016 State Board meeting.

Governor’s Office for Bullying Prevention

Governor Branstad signed Executive Order 86 yesterday, establishing the Governor’s Office for Bullying Prevention. The only copy of Executive Order 86 I can find today is oriented sideways, which makes it difficult to read, so I have uploaded a rotated copy here.

Below are the details of Executive Order 86, with comparisons to the provisions of the proposed Bully Free Iowa Act of 2015 (HSB 39). [Note that HSB 39 is currently numbered HF 490 and SF 345, but here, I just want to compare the bill as proposed by the Governor to Executive Order 86, as signed by the Governor.]

Executive Order 86 establishes the Governor’s Office for Bullying Prevention (“the Office”) within the University of Northern Iowa’s Center for Violence Prevention (“the Center”).


Ensure schools have access to training on establishing anti-bullying policies and conducting investigations of complaints pursuant to Iowa Code section 280.28.

HSB 39 would have required the director of the DE to ensure each district had adequate training, subject to appropriations of funds. HSB 39 would have appropriated $150,000 for training programs.

24-hour Hotline

Work with the Iowa DE and Iowa Department of Public Health to promote YourLifeIowa.org, an existing hotline.

Reporting Procedures

Work with the Iowa DE to develop a procedure for prompt notification of parents or guardians of the victims and alleged perpetrators in reported incidents of harassment of bullying.

HSB 39 would have required prompt notifications, but included an exception if a school official or a student who is a target of harassment or bullying reasonably believes notification would subject the targeted student to rejection, abuse, or neglect related to actual or perceived sexual orientation, gender identity, or gender expression.

As I recall, the notification provision was a point of contention in the Legislature. This puts the development of notification procedures with a non-elected body.


Develop guidelines promoting safety from cyberbullying and how to respond to bullying that takes place electronically and interferes with learning at school.

HSB 39 would have expanded the definition of “electronic” to include social networking sites “or any other electronic communication site, device, or means.” HSB 39 would also have granted school officials express authority to investigate and impose school discipline for alleged incidents of harassment or bullying that occurs outside of school, off of school property, or away from a school function or school-sponsored activity.

As I recall, authority off school grounds was another point of contention in the Legislature. Again, this puts development of guidelines in a non-elected body. Question: does this provide sufficient assurance to school officials that they won’t be held liable for exercising authority off school grounds, such that they would feel comfortable adopting and acting according to guidelines as developed by the Office?

Data Collection

Work with schools and the Iowa DE to address inconsistencies in school reporting of bullying and harassment data.

Varsity Interscholastic Athletic Participation

Convene a working group to propose administrative rules to the State Board of Education to allow students subjected to harassment or bullying to open enroll to a new district and immediately participate in varsity athletics.

HSB 39 had a similar provision that would have required a founded incident of harassment or bullying in the resident district, and agreement from both the resident district and the receiving district that the student should be permitted to participate immediately in varsity athletics.

Bullying and prevention student mentoring pilot program

Promote a student mentoring program to promote student leadership to prevent and respond to bullying and violence in schools, and to spread best practices for preventing bullying and violence for middle and high school students.

HSB 39 would have required the DE to establish a student mentoring pilot program, subject to appropriations. HSB 39 would have appropriated $50,000 for the pilot program.

Radio Iowa reports that UNI will pay the initial costs of the Office and that Governor Branstad will request additional funding for the Office from the Legislature.

Proposed Rules and the Iowa Code

As expected, the State Board of Education reviewed a notice of intended action for proposed rules, meant to implement Iowa Code 256.7(21), last week.

The complete text of the proposed rules:

ITEM 1. Amend subrule 281—12.8(1) by adding the following new paragraph “h”:

h. Designation of “at least one districtwide assessment.”

(1) For purposes of Iowa code section 256.7, at least one of the districtwide assessments used to measure student progress in core academic indicators in reading and math shall be the assessment developed by the Smarter Balanced Assessment Consortium (“SBAC”).

(2) The department shall select a vendor to administer SBAC through a request-for-proposal process.

(3) The assessment task force shall review SBAC administration and make a recommendation pursuant to Iowa code section 256.7, subsection 21, paragraph b, subparagraph 3, on or before June 30, 2020.

I have two initial thoughts. One is that the proposed rules appear to be in direct conflict with the Iowa Code subsection they are meant to implement. See subparagraph (1) which reads as follows:

(1) Annually, the department shall report state data for each indicator in the condition of education report. Rules adopted pursuant to this subsection shall specify that the approved district-wide assessment of student progress administered for purposes of the core academic indicators shall be the assessment utilized by school districts statewide in the school year beginning July 1, 2011, or a successor assessment administered by the same assessment provider.

The other is that the proposed rules, which are presumably meant to provide guidance, are incomplete with regard to other requirements specified in subparagraph (2), in that they don’t specify a required science assessment, don’t specify the grade levels required to be assessed, don’t specify timing of the assessment administration (last quarter of the school year), and don’t specify an effective date (the school year beginning July 1, 2016).

It may be of interest to revisit discussion that the State Board had, or didn’t have, regarding costs, technology readiness, and implementation experiences in other states. Some of my observations from the August meeting can be found here or here.


If you are so inclined, please take the time to comment. In my experience, rules are sometimes changed–or even withdrawn to be rewritten and renoticed–in response to comments. In addition, the comments will at least be summarized and presented to the board (and thus the public) when the rules are in front of the board for adoption and filing. Finally, consider the following from a document posted on the Iowa Legislature’s website outlining the elements of the rulemaking process:

In a rulemaking preceding [sic] the public is not entitled to a decision based on the evidence in the record, but the public can demand that the agency create a record, based on its decision. Any interested person {meaning literally anybody} may request that the agency prepare: “A concise statement of the principal reasons for and against the rule it adopted, incorporating therein the reasons for overruling considerations urged against the rule.” This provision requires a synopsis of the most important arguments for and against the proposal. The request may be made at any time during the rulemaking, up to 30 days after the final adoption. The statement must be completed with 35 days of the request. [Emphasis in the original changed to bold.]

The comment period is open until November 3rd at 4:30 pm, which is also the date set for the public hearing, which will be held in the State Board Room of the Grimes Building from 1:00 pm to 2:00 pm. Find details for submitting comments (from the first page of the notice of intended action) below or try your luck with the new administrative rules site (though as of right now, the proposed rules are not yet posted). Find the LSA Fiscal Update News Article here.

Comments on the proposed amendments should be directed to Phil Wise, Administrative Rules Co-Coordinator, Iowa Department of Education, Second Floor, Grimes State Office Building, Des Moines, Iowa 50319- 0146; telephone (515) 281-4835; e-mail phil.wise@iowa.gov ; or fax (515)242-5988.

If you end up commenting and are inclined to share what you said, please leave a comment.

2015 State Report Card

The DE released the 2015 State Report Card for No Child Left Behind earlier this week. The report includes a list showing the status of every district and every school in the state. The designations are based on whether schools met or did not meet Adequate Yearly Progress (AYP) goals or Annual Measurable Objectives (AMO) proficiency targets in math and reading.

  • Met–school met AYP
  • SINA-X–school failed to meet AYP two years in a row, the value of X indicates how many years the school has had a SINA designation
  • Delay–school met AYP for one year, will be removed from SINA status if meets AYP again in the current year
  • Watch–school failed to meet AYP for one year, will be designated SINA status if fails to meet AYP again in the current year.
  • Removed–indicates that the school was removed from watch status after making AYP for one year, or removed from SINA status after making AYP for two years

Here, for what it is worth, is how ICCSD schools fared (school name followed by status for math, then status for reading):

  • City High School  SINA-6, SINA-6
  • West High School  SINA-2, SINA-9
  • Tate High School  SINA-9, SINA-9
  • NCJH  SINA-3, SINA-4
  • NWJH  SINA-9, SINA-11
  • SEJH  SINA-11, SINA-12
  • Borlaug  Removed-Watch, Removed-Watch
  • Coralville Central  SINA-5, SINA-4
  • Garner  SINA-3, Delay-2
  • Hills  SINA-3, Delay-2
  • Hoover  Delay-1, Delay-2
  • Horn  SINA-1, SINA-1
  • Kirkwood  SINA-7, SINA-7
  • Lemme  SINA-4, SINA-4
  • Lincoln  Watch, Met
  • Longfellow  Watch, Removed-SINA
  • Lucas  SINA-7, SINA-6
  • Mann  SINA-2, Delay-1
  • Penn  SINA-5, SINA-6
  • Shimek  Watch, SINA-1
  • Twain  SINA-7, SINA-8
  • Van Allen  Met, Delay-3
  • Weber  SINA-1, SINA-1
  • Wickham  Watch, Watch
  • Wood  SINA-7, SINA-7

The full list of districts starts here (with ICCSD here) and the full list of schools (by district) starts here (with the list of ICCSD schools starting here).

The Gazette has coverage here. The Press-Citizen has coverage here and a guest opinion piece from Mike Petrelli and Robert Pondisco (about Common Core test results generally), with which there is so much wrong, I’m not even going to get started commenting on it.

For a preview of what is coming to Iowa, as the State Board of Education moves ahead with adopting the Smarter Balanced Assessments, keep an eye on California, where, the LA Times reports in an article titled New California tests present sobering picture of student achievement, students “performed close to expectations based on a field test given in 21 states two years ago.”

So I’ll leave you with a few charts I made last fall on predicted SBAC performance based on information released when cut scores were announced last year and a question: how will labeling even more Iowa students not proficient help Iowa students and their schools?

Possible changes in Iowa proficiency rates based on predicted SBAC performance compared to Iowa Assessments results for 2011-2013:

Math 2

Reading 2

New Science Standards and Implications for Assessment

The Assessment Task Force is getting back together this fall to make recommendations for science assessments now that the State Board of Education has adopted the Next Generation Science Standards, as modified and recommended by the Science Standards Review Team, as the new Iowa Core science standards.

As part of my preparation for this next stage of our work, I’m reading the Science Standards Review Team Report 2015 and trying to make sense of the implications of the new standards for statewide standardized (accountability) assessment. I was also fortunate to have been able to sit down this week with Solon’s Matt Townsley, a knowledgeable, thoughtful, and patient local administrator and assessment enthusiast, who graciously agreed to talk over the new science standards and some implications for assessment with me.

Here’s where I am at in my understanding so far (and, note, that any misunderstandings are my own–if you see any, please leave an explanation in the comments):

The Next Generation Science Standards are made up of Disciplinary Core Ideas (what to teach), Science and Engineering Practices (how to teach), and Crosscutting Concepts (?). These (what and how to teach) have been combined into model Performance Expectations. These Performance Expectations are what have been adopted as Iowa’s science standards with, at least, two modifications.

First, the Science Standards Review Team organized the middle school grade band performance expectations into Iowa specific grade level standards for grades six, seven, and eight. Second, the Science Standards Review Team recommended adoption of the performance expectations without adopting the assessment boundaries and connection boxes.

The Science Standards Review Team did not organize the high school grade band performance expectations into specific grade level standards.

Implications for Statewide Standardized Assessments [more questions, than answers]

As I understand it, there are no NGSS-aligned large-scale standardized assessments currently ready for use and that it can take four or five years to properly develop new standardized assessment. Thus, it seems likely that statewide science assessments will not align with the new science standards for several years or more. [Question: because the Iowa Core standards are required to be implemented already, are changes to the standards required to be implemented immediately?]

Iowa Code 256.7(21)(b)(2) requires, beginning in the 2016-2017 school year, all students in grades three through eleven to be assessed annually in core academic indicators, which include science. In any case, some school districts may be assessing science annually to evaluate effectiveness of curriculum and/or to monitor annual student progress (are students making a year’s worth of progress each year?).

If other states are only assessing students in science in grades five, eight, and eleven, what are the prospects for Iowa working with other states to develop a large-scale science assessment aligned to the Next Generation Science Standards? Surely other states won’t want to share the costs of developing assessments at other grade levels they won’t be using.

Without specific grade level standards for grades nine, ten, and eleven, how should the assessment developer determine which standards to assess on each grade level assessment?

Conversely, if the Iowa Legislature were, for instance, to determine that science should only be assessed statewide at grades five, eight, and eleven after all, does that undermine the work of having made Iowa-specific changes to the NGSS? [Questions: should we make changes in Iowa for the purpose of working with other states? If we don’t, does that affect comparability of state assessment results? How much does that actually matter?]

Where does that leave Iowa districts in evaluating science curriculum and tracking annual progress of students? Possibly with non-aligned standardized science assessments? Locally created assessments? [Questions: is it essential or important to track annual student progress in science or is it qualitatively different than math and reading? What does that mean for statewide STEM initiatives–does not measuring annually devalue science in any important respects? How many data points are needed to effectively evaluate curriculum?]

The assessment boundaries, not required in Iowa, are apparently meant to guide the development of large scale assessments. See, for instance, this example used by NGSS in the document linked in the preceding sentence [click to make larger]:

NGSS example

As the assessment boundaries are not required (not adopted as part of the standards), should they still be used to guide development of statewide assessments? If they are used to guide statewide assessments, does that make them, in effect, required anyway? If they aren’t used to guide development of the assessments, then what?

What is (or should be) the purpose of statewide assessment in Iowa–accountability for what to teach or for what and how to teach? If students are content proficient, how much does how they were taught matter from a statewide, rather than local, perspective?

Performance assessments are significantly costlier in time to administer and money (particularly in human scoring of constructed responses). That suggests assessment at grades five, eight, and eleven rather than annually–unless school districts suddenly receive a state funding windfall that covers all assessment costs plus added time in the year to make up for instructional hours lost to statewide assessment. Assuming no funding windfall, do we gain enough from performance assessments to justify either the diversion of additional time and money from instruction or the loss of annual data?

What am I missing–or misunderstanding? What else should I know–or should I be reading up on–for this next round of Assessment Task Force work?

Added (9/24): If we assess only grades 5, 8, and 11, what do we assess? Just grade level content (leaving grade level content for grades 3, 4, 6, 7, 9, and 10 unassessed) or assess grade bands (perhaps spending only 1/3 of each assessment on each grade level and covering fewer of the grade level standards)? What are the “teaching to the test” implications of either of these decisions?

One question answered: full K-12 implementation of the new science standards is expected for the 2018-2019 school year. Question: what to use for science assessment until that year and can an NGSS-aligned assessment be properly developed in time to be used beginning in that year (roughly three years out, and assessments may take four to five years to develop).


A recent Iowa House Republican Newsletter has an update on state board action on science standards and statewide assessments: [The next three paragraphs are quoted directly from the newsletter (page 5), but I haven’t indented the whole thing, so that I can preserve the indented quote as it appears in the newsletter.]

“The authority for the State Board to determine Iowa’s next assessment without the legislature weighing in is still questionable. Iowa Code 256.7, which outlines the duties of the State Board, requires rules in sub-section 21 to implement a new assessment for the 2016/17 school year. This section also establishes the task force meant to make recommendations for the new assessment. The final language in the subsection states:

“The state board shall submit to the general assembly recommendations the state board deems appropriate for modifications of assessments of student progress . . .”

Whether the charge to the State Board in this last bit of language is to seek legisla-tive approval or merely to notify the legislature, the Department of Education has de-termined it is only for notification. As such, they have moved ahead with the develop-ment of rules.”