Thank you for the opportunity to submit public comments through this Virginia Regulatory Town Hall forum. In finalizing revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia, Fairfax County Public Schools (FCPS) urges the Virginia Board of Education to be mindful of how outcomes will be measured for students with disabilities, including those taught using the Virginia Essentialized Standards of Learning (VESOL), and for multilingual/English learners, particularly Students with Limited or Interrupted Formal Education (SLIFE). 

Given the options presented to the Board, FCPS suggests adopting the equal Mastery index weighting system, providing even steps between points for each performance level. We highlight the need to ensure that expected Growth targets for students with disabilities and multilingual/English learners within Virginia’s Visualization and Analytics Solution (VVAAS) are appropriately normed to these unique student populations. FCPS supports the inclusion of Virginia Alternate Assessment Program (VAAP) performance within both Mastery and Growth calculations to ensure inclusion for students with significant cognitive disabilities and we recommend that, when reporting scores to the public, results for Standards of Learning (SOL) and VAAP be separated for transparency. Similarly, with the proposed system’s heavy reliance on standardized assessments, we advocate for the adoption of valid and reliable native language assessments--as encouraged within the Every Student Succeeds Act (ESSA) Consolidated State Plan template--to serve as testing accommodations to accurately measure multilingual/English learners' content knowledge and skills. FCPS supports greater implementation of universal design principles, such as "plain language" assessments and continued inclusion of Board-approved substitute exams (e.g., ACT WorkKeys, Advanced Placement) at the high school level, as these tests may offer a more relevant and authentic assessment experience to better reflect content knowledge and skills, including for twice exceptional students. 

Specifically with regard to multilingual/English learners, FCPS advocates for maximizing the percentage assigned to WIDA-based English Learner (EL) Progress within the Mastery indicator calculations (such as 15% rather than 5%). A focus on EL Progress recognizes the critical importance of timely language acquisition in preventing students from becoming Long-Term ELs, who have not reached proficiency after five consecutive years of English language supports. Further, FCPS advocates for maintaining the current research-based allowance of 11 semesters (5.5 years) for language acquisition before students are accountable to reach the proficient level on content standards assessments. If the Board determines it is necessary to reduce the multilingual/English learner adjustment, FCPS strongly encourages using only EL Progress outcomes within Mastery calculations and/or using only Growth calculations for the intervening years. FCPS also supports consistently including Formerly English Learners during their four years of monitoring within both Mastery and Growth calculations.

When making decisions about Readiness indicators in middle and high schools, FCPS urges the Board to consider how to appropriately accommodate students with disabilities and SLIFE students for whom traditional advanced courses may not be appropriate or may be accessed on an adjusted timeline. These Readiness measures should allow adjustments or alternatives for students assigned VAAP for their state assessments. FCPS asks the Board to consider how to adjust or accommodate alternative Readiness options for certain students with disabilities and SLIFE students for whom currently outlined pathways may not be appropriate. One such alternative would be continued acceptance of a student’s documented completion of a high-quality work-based learning or service learning experience within the proposed Ready for Life measure. FCPS likewise urges that the Board continue to recognize employment credentials that promote access for multilingual/English learners and students with disabilities, such as the National Career Readiness Certificate (NCRC), which is earned through qualifying results on multiple subtests in applied skills. Furthermore, we feel it is important to include the current Graduation and Completion Index (GCI) within the Readiness indicator as a way to reflect a full range of diploma and completer outcomes for students with disabilities and multilingual/English learners (e.g., Applied Studies Diploma, High School Equivalency, Certificate of Completion) while also providing students whose individualized education program (IEP) teams or EL committees have determined additional time is needed in high school to prepare for postsecondary success. 

Finally, recognizing the importance of parent/guardian involvement and decision-making regarding their students’ education--particularly for students with disabilities and multilingual/English learners--FCPS urges the Board to maintain current calculation adjustments in cases where a parent/guardian makes the choice to refuse participation for their student in SOL or VAAP assessments. FCPS supports the current accountability approach, in which a parent/guardian refusal counts to fulfill federal participation requirements but is removed from pass rate calculations, since the outcome does not reflect actual student performance. 

Thank you again for this opportunity to provide input in the process and we appreciate your consideration.

Fairfax County Public Schools, Office of Government Relations