STATE BOARD OF EDUCATION
ADMINISTRATIVE CODE
COMMENT/RESPONSE FORM
This comment and response form contains comments since the April 6, 2016, State Board of Education meeting when the draft regulations were considered at Proposal Level.
Topic: Standards and Assessments Meeting Date: August 3, 2016
Code Citation: N.J.A.C. 6A:8 Level: Adoption
Division: Talent and Performance Completed by: Division of Talent
and Performance
Summary of Comments and Agency Responses:
The following is a summary of the comments received from members of the public and the Department’s responses. Each commenter is identified at the end of the comment by a number that corresponds to the following list:
1. Marlboro Township Board of Education
2. Livingston Board of Education
3. Township of Ocean Board of Education
4. Bridgewater-Raritan Regional School District Board of Education
5. Princeton Board of Education
6. Joy Schiavo
Roselle Public Schools
7. Veronica Kim,
River Edge Public Schools
8. Suzanne Manning
Waldwick School District
9. Rosemary Armstrong
Washington Township School District (Gloucester County)
10. Zul Kagalwalla
11. Gina Mark
12. Jean Public
13. Sari Santoro
14. Linda Mavretish
15. Nisha Zoeller
Morris Hills Regional School District
16. Anna Pietrocola
17. Bill Michaelson
18. Concerned Parent
19. Patrick McKnight, Chair
New Jersey Libertarian Party
20. Ann Hoag
21. Jeanine Branch
22. Patricia Fantulin
23. Bob Dailyda
24. Lellani Carson
25. Lori Grande
26. Marlene Burton
27. Lorraine Miller
28. Gary van Wyk Ph.D.
29. Sonya Bertini
30. Lucy Dolin
31. Audrey Oldoep
32. Rhonda Yabko
33. J.S. Prakash
34. Laura Begg
35. Joseph Connor
36. Laura Malcarney
37. Kara Doyle
38. Irene Salcito
39. Stacey DiMarco
40. Michele Fischer
41. Sarah Foye
42. Joanne McHugh
43. Dana Dentino
44. Frances and Gene Uziel
45. Shari Reeve
46. Belinda Edmondson
47. Ellen Dailey
48. Gerald and Melissa Decker
49. Meg Silverman
50. Randi Hersh
51. Stephanie Marulli
52. Melissa Joyner
53. Charity Reagan
54. Susanne Syben-Moscicki
55. Jane Rigney
56. Stephanie Cole Sanchez
57. Michael F. Mignone
58. Frank Schiavone Jr.
59. Ellen Tillson Parker
60. Maria O’Brien
61. Anonymous
62. Debbie Gries
63. Diane Otoole
64. Mary O’Grady
65. Michael Warholak
66. Marla Nierenberg Hanan
67. Dianne Douthat
68. Julie Nealon
New Jersey Education Association
69. Jose Maravi
Morris Hills Regional School District
70. Cranford Board of Education
71. South Brunswick Township Board of Education
72. Montville Township Board of Education
73. Amy Smaldone
74. New Jersey School Boards Association
75. Elizabeth Franks
NJTESOL/NJBE
76. Noreen Drucker
NJTESOL/NJBE
77. Suzan Cole
Township of Ocean School District
78. Stephanie Myers
North Plainfield School District
79. Sharon Fischer
80. Hanna Prashker
NJTESOL/NJBE
81. Carolyn Hughes
NJTESOL/NJBE
82. Madji Fall
NJTESOL/NJBE
83. Monica Schnee
NJTESOL/NJBE
84. Regelio Suarez
Hackensack Public Schools, NJTESOL/NJBE
85. Katherine Stotler
Bernards School District
86. Sandra Nunes
87. Kelly Yang
Manalapan-Englishtown School District
88. Caren Kalman
North Bergen School District
89. Gary Seid
NJTESOL/NJBE
90. Regina Paglia-Smoler
NJTESOL/NJBE
91. Judie Haynes
NJTESOL/NJBE
92. Michelle Land
93. Monroe Township Board of Education (Middlesex County)
94. Lois Salvatore
95. Lisa Aditto
96. Donna Andreen
97. Maria Loikith
98. Christopher Ryan
99. Eric Milou
100. Bonnie Parks
101. Christina Moreira
102. Sarah Petersen
103. Catherine E. DeGenova
104. Diane Bessette
105. Christy DeMarco
106. Jodi Hoover
107. Kristina Wetter
108. Donna Troller
109. Kristen
110. Save Our Schools
111. Michael Mandica
112. R.V.
113. Carol Tagoe
114. Beverly Clancy
115. Georgia Bulko
116. Kathleen Belko
117. Annette
118. Anonymous
119. Christine McGoey
120. Dawn Tapp
121. Connie Brown
122. Lillian Vollmann
123. Anonymous
124. Linda Lance
125. Jackie
126. Amanda Smith
127. Diane Mess
128. Sherry Miller
129. Julie Borst
130. Marilyn Silva-Sessa
131. Justin Escher Alpert
132. Jeanne Vollmann
133. Laura Begg
134. Jen Korn
135. Michelle McFadden-DiNicola
136. Lisa Marie Fuchs
137. Karen Vanoppen
138. Mike Ryan
139. Kathleen Papp
140. Heather Brustowicz
141. Isabel Ortega
142. Jill DeMaio
143. Angela McVerry
144. Colleen Daly Martinez
145. Heidi Olson
146. Save Our Schools 2
147. Jody Demas
148. Katherine Stein
149. Marie Corfield
150. Regan Kaiden
151. Virginia Manzeri
152. Dan Masi
153. Drew Escaldi
154. Griffin Willner
155. Jennifer Korn
156. Julie Borst
157. Katie Salvo
158. Dawn Tapp
159. Heidi Brown
160. Jon Coniglio
161. Jon Woodward
162. Kathryn Laczynski
163. Laura Begg
164. Lisa Wolff
165. Liz Mulholland
166. Martha Luszcz
167. Monique Andrews
168. Sarah Blaine
169. Marie Blistan, Vice President
New Jersey Education Association
170. Ginny Murphy, President
Washington Township Board of Education (Gloucester County)
171. Julie Borst
172. Rosie Grant, Executive Director
Paterson Education Fund
173. Susan Cauldwell, Executive Director
Save Our Schools New Jersey
174. Darcie Cimarusti, President
Highland Park Board of Education
175. Jennifer Keyes-Maloney, Assistant Director of Government Relations
New Jersey Principals and Supervisors Association
176. Julia Rubin
177. Lynn Szczeck
178. Becky Bates
179. Heather Hicks
180. James Riley
181. Jennifer Grana
182. Jody Demas
183. Sue Altman
184. Stan Karp
Education Law Center
185. Bonnie Gabizon
186. Kathleen Dalessio
187. Lisa M. Rodgers
188. Rhianon Midas
189. Tamara Gross
190. Virginia Grossman
191. Gina Verdibello
192. Linda Reid
193. Hana Prashker
NJTESOL/NJBE
194. Stan Karp and Jessica Levin Esq., Education Law Center, and Edward Barocas Esq., American Civil Liberties Union of New Jersey
1. COMMENT: The commenters opposed the Partnership for Assessment of Readiness for College and Career (PARCC) assessment and requested the Department withdraw the proposed amendments regarding high school graduation requirements. (1, 2, 4, 5, 11, 14, 19 through 25, 27, 28, 32 through 38, 41, 43 through 46, 49 through 57, 59, 60, 61, 63, 66, 72, 73, 95, 100, 101, 104, 105, 107 through 139, 141, 143, 146 through 149, 150 through 158, 161, 163, 165, 168, 170 through 174, 177 through 192, 194)
RESPONSE: The Department disagrees with the commenters’ suggestion to eliminate the PARCC assessment as a graduation requirement. The State statute governing high school graduation standards, N.J.S.A. 18A:7C-1 et seq., requires “[t]he development of a Statewide assessment test in reading, writing and computational skills,” as well as clear and explicit Statewide levels of proficiency to be demonstrated as a minimum requirement for high school graduation. As the use of a Statewide standardized assessment for graduation is a statutory requirement, the Department cannot do away with the requirement.
2. COMMENT: The commenter opposed the proposed requirement for students to pass or demonstrate proficiency on the PARCC assessment as a graduation requirement but supported requiring students to take the assessment without achieving a certain score to graduate. (40)
RESPONSE: The State statute governing high school graduation standards, N.J.S.A. 18A:7C-1 et seq., requires “[t]he development of a Statewide assessment test in reading, writing and computational skills,” as well as clear and explicit Statewide levels of proficiency to be demonstrated as a minimum requirement for high school graduation. As the use of a Statewide standardized assessment for graduation is a statutory requirement, the Department cannot do away with this requirement.
3. COMMENT: The commenters opposed the PARCC assessment as the only means of earning a high school diploma. (22, 96, 98, 102, 103, 105, 116, 117, 140, 151, 169, 172, 174)
RESPONSE: Students who are unable to demonstrate graduation proficiency through the Statewide standardized assessment can utilize the portfolio appeals process, which includes a review of student coursework and performance-based assessments. As the use of a Statewide standardized assessment for graduation is a statutory requirement, the Department cannot do away with this requirement.
4. COMMENT: The commenter opposed the proposed requirement for students to take all end-of-course PARCC assessments as a condition to graduate and said there is no basis for the requirement in N.J.S.A. 18A:7C-1 et seq. (152, 168)
RESPONSE: State and Federal regulations call for all students to take the Statewide assessment, and the Department must abide by that expectation. The PARCC assessment is designed as the benchmark assessment of college and career readiness. Students who do not achieve a certain level in the PARCC assessment may utilize the portfolio appeals process for the graduation assessment requirement.
5. COMMENT: The commenter said the PARCC assessments are not a fair graduation requirement since they are computer based, which gives an advantage to students with access to better quality and more consistent use of computers. The commenter further stated assessments taken on paper provide every student equal testing equipment, which PARCC does not. (158)
RESPONSE: The Department is mindful of concerns regarding the use of a new assessment system as a graduation requirement. New Jersey students are accustomed to learning in a technology-rich environment. More than 20 years ago, New Jersey embarked on an initiative to infuse technology in the classroom, and technology has been among the State’s student learning standards for 12 years. The vast majority of New Jersey students (approximately 98 percent) took the PARCC assessment on computer. Students who require paper PARCC assessments have the ability to do so. Computer-based assessments are becoming the norm among national assessments.
6. COMMENT: The commenters stated the designation of end-of-course PARCC Algebra I and ELA 10 assessments violate the statutory requirement to administer a single, comprehensive graduation assessment in 11th grade. (165, 168, 169, 174)
RESPONSE: Due to pending litigation over the subject matter of this comment, the Department is unable to respond at this time.
7. COMMENT: The commenters stated the PARCC assessments gauge college and career readiness, which is a higher standard than the assessment of minimum basic skills required by State law. The commenter further stated State law does not allow the State Board to raise the standard. (168, 174)
RESPONSE: A foundational concept of a quality assessment is that preparing a student for success in college and career should be the minimum standard. The State’s assessments are designed to accurately measure mastery of the State’s academic standards, and the State Board of Education can, and has, improved the standards numerous times since they were created two decades ago.
8. COMMENT: The commenter said adopting the PARCC assessment as a graduation requirement will increase the achievement gap in New Jersey and lead to more students dropping out of school. (172)
RESPONSE: The Department appreciates the commenter’s concerns about the achievement gap in New Jersey, but is not aware of any evidence that suggests the commenter’s predictions will occur. To the contrary, the Department’s recent experience with portfolio appeals suggests that students have a viable option in addition to the PARCC to meet the graduation assessment requirement.
9. COMMENT: The commenter expressed appreciation for the Department’s efforts to ensure stakeholder input and for the gradual migration to the new graduation requirements, which will allow for an ample transition period for students, school leaders, and teachers. (175)
RESPONSE: The Department appreciates the commenter’s support.
10. COMMENT: The commenter expressed support for the adoption of PARCC ELA 10 and Algebra I as the benchmark for determining student proficiency. The commenter also expressed appreciation for the Department’s plan to reexamine the benchmarks in the future. (175)
RESPONSE: The Department appreciates the commenter’s support.
11. COMMENT: The commenter expressed support for the retention of multiple pathways for students to show mastery through the transition period as utilizing alternative assessments and the portfolio appeals process to demonstrate proficiency are critical during the transition process. (175)
RESPONSE: The Department appreciates the commenter’s support.
12. COMMENT: The commenter stated the PARCC assessment should be an optional graduation assessment and the SAT, ACT, PSAT, AP, and Accuplacer, which are currently being used during the transition period, should be permanent elective assessments for graduation. (71)
RESPONSE: The Department is mindful of the use of a new assessment system as a graduation requirement and has proposed a lengthy transition plan to ensure students have sufficient time to get accustomed to the new assessment system prior to making the end-of-course PARCC in ELA 10 and Algebra I graduation requirements. The Department will continue to review implementation of the transition plan as it progresses. However, the State statute governing high school graduation standards, N.J.S.A. 18A:7C-1 et seq., requires “[t]he development of a Statewide assessment test in reading, writing and computational skills,” as well as clear and explicit Statewide levels of proficiency to be demonstrated as a minimum requirement for high school graduation.
13. COMMENT: The commenters requested that students be allowed to graduate during the transition period on the basis of credits earned, grade point averages, and successful completion of all attendance, service, and other local graduation requirements. (1, 2, 5, 169)
RESPONSE: The Department is mindful of the use of a new assessment system as a graduation requirement and, as a result, has proposed a lengthy transition plan to ensure students have sufficient time to get accustomed to the new assessment system prior to making the end-of-course tests in ELA 10 and Algebra I graduation requirements. Students who are unable to demonstrate graduation proficiency through the Statewide standardized assessment can utilize the portfolio appeals process, which includes a review of student coursework and performance-based assessments. As the use of a Statewide standardized assessment for graduation is a statutory requirement, the Department cannot do away with this requirement.
14. COMMENT: The commenters requested a multi-year transition to a new assessment system be used to conduct a broad public dialogue with stakeholders to develop a consensus about transparent and equitable assessment policies. (1, 2, 5, 70, 110)
RESPONSE: The Department is mindful of and has taken into account all comments and opinions received regarding PARCC. The Study Commission on the Use of Student Assessments in New Jersey (Study Commission) held multiple public testimony sessions throughout the State. The concerns and opinions expressed at the sessions were considered when drafting the proposed amendments. The State Board also accepted testimony and written comments from members of the public regarding the proposed amendments, and the comments have been considered by the Department during the rulemaking process. However, the State statute governing high school graduation standards, N.J.S.A. 18A:7C-1 et seq., requires “[t]he development of a Statewide assessment test in reading, writing and computational skills,” as well as clear and explicit Statewide levels of proficiency to be demonstrated as a minimum requirement for high school graduation. The Department has selected PARCC as the requisite Statewide assessment.