Raising Special Kids Comments on ADE Waiver Request


January 24, 2019

Audra Ahumada, Deputy Associate Superintendent of Assessments

Arizona Department of Education
Assessment Section
1535 W. Jefferson, Bin 6
Phoenix, Arizona 85007

RE: Raising Special Kids public comment

Dear Ms. Ahumada,

Raising Special Kids, the Arizona Parent Training and Information Center (PTI) operating under Section 671 of the Individuals with Disabilities Education Act 2004 (IDEA), appreciates the opportunity to provide public comment on the Arizona Department of Education’s request for a waiver from the requirement that our State submit evidence demonstrating that the chosen nationally recognized assessments meet the requirement of the Department’s peer review guidance prior to the first administration of the nationally recognized assessments in Spring 2019.

On behalf of the Raising Special Kids Board of Directors, staff and Arizona’s families of students with disabilities we thank the Arizona Department of Education (ADE) and the Arizona State Board of Education (ASBE) for their dedication to the success of all Arizona’s students including the more than 130,000 Arizona children eligible for special education and related services as defined in IDEA.

In 2018 an estimated 700,000 students in Arizona took the AzMERIT single statewide assessment that aligned with the rigorous AZ State standards adopted by the ASBE. Thousands of students with disabilities were eligible, and used, standard testing accommodations in order to demonstrate their proficiency on what they had been taught in their classrooms.

We are concerned that waiving the requirement for evidence of peer review of nationally recognized assessments, such as the ACT and the SAT, specifically to examine alignment with Arizona State content standards, places our students at a disadvantage as they may be assessed on content that they may not have had any explicit instruction on or even exposure to.

In addition to the specific concern above, we have broader concerns about the use of a menu of assessments available to Arizona’s traditional public and charter schools, outside the limited scope of this public comment, and look forward to future opportunities to expand on our more general concerns including:

  • Accountability – federal education, and special education, funding contingent on performance measured by a single statewide assessment.
  • Accommodations – accessing necessary accommodations for eligible students with disabilities. Though nationally recognized assessments, such as the ACT and SAT, allow for accommodations, the process for accessing accommodations may be unclear, or confusing, for teachers, parents and students.
  • Equity – it is unlikely that a student’s progress, from year to year, will be accurately captured using multiple assessment tools.
  • Protection of investment – the AzMERIT appears to be no longer be an option, of any kind, for public schools after November of 2019.

Thank you for this opportunity to provide public comment on this important issue. We look forward to our continued partnership with Arizona’s parents, teachers, administrators, the Arizona Department of Education and the Arizona State Board of Education in the education of students with disabilities.


Christopher Tiffany, M.A.Ed.
Executive Director
Raising Special Kids

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