Hello, I write in opposition to this guidance. I am concerned that this guidance could be used by school teams to fail to identify and offer services to students with learning disabilities. No studies are cited to support the specific claims, which could represent as much as 2 and 1/3 standard deviations.
I note that this guidance will apply not only to standardized tests, but also to the norm-referenced assessments commonly used in schools precisely to identify students at early age for learning disabilities. If bias exists in the instruments, then let's fix the instruments. However, far greater harm will be done to students with specific learning disabilities by failing to identify them based on undocumented claims of bias in the instrument.
Please support the important progress being made in critical early identification and intervention of ALL students with learning disabilities and do not adopt this guidance.