An Open Letter to New Hampshire Education Commissioner Edelblut

Commissioner Edelblut:

Please take a look at an article that was recently posted in regard to the Smarter Balanced Assessment  (SBA) :

As you can see, serious allegations have been made against the Smarter Balanced Assessment Consortium.

It is quite unlikely that the 2017 Smarter Balanced declines, based on roughly six million students tested, reflect actual performance declines for students and schools across all those states. This is, after all, the third year of this national testing program. Those who watch testing results would expect slight gains, not a drop or a plateau.

Smarter Balanced is stonewalling efforts to figure out what has occurred. It refuses to acknowledge that the 2017 scores are highly unusual and, instead, claims the scores are just normal year-to-year fluctuations of gain scores. That argument is hogwash. It is totally inconsistent with the actual 2017 consortium-wide gain data.

Others agree with us. For example, Ed Haertel, a Stanford University professor and a member of the Smarter Balanced Technical Advisory Committee, told, ‚ÄúThese are not merely random-chance fluctuations.‚ÄĚ He‚Äôs doubtful that ‚Äúthere was some slight overall decline in students‚Äô overall proficiency.‚ÄĚ

I have been an outspoken critic of the Smarter Balanced Assessment since it was chosen by our former¬†Education¬†Commissioner, Virginia Barry.¬† I have testified before the N. H. House and Senate¬† Education Committees requesting that the SBA be replaced with an “achievement test” versus a “psychometric assessment.”

New Hampshire State Law: RSA 193-C, requires statewide assessments to be valid, appropriate and objectively scored. Where were the INDEPENDENT validity studies on the Smarter Balanced Assessment that show it is in compliance with state law?

A study from the testing company that administers the assessment is not an independent study.  For instance, testimony from Scott Marion on the PACE assessment does not provide what we should be able to accessРindependent studies.  I continue to ask how PACE or any other assessment described as one that measures “attributes, dispositions, social skills, attitudes and intra personal resources> can be objectively scored?  This is why the grading system is changing in New Hampshire.  It was difficult to score these behaviors when it was done under the Outcome Based Education model.  A model that was eventually abandoned years ago.

According to this letter from education researcher Jayson Seamon,  Ph.D., the Smarter Balanced Assessment was not validated. Does this mean that administering the Smarter Balanced Assessment violated state law?

Dr. Seaman goes on to explain the ethical standards required when administering psychometric assessments : ‚Äúit is required practice to secure consent from research participants and to let them opt out at any time with no penalty. Smarter Balanced is such an assessment and should be held to the same ethical standard as all research on human subjects.‚ÄĚ

Parents have never been required to consent to the Smarter Balanced Assessment, PACE or the SAT.¬† This isn’t a matter of state law. It should be a matter of ethical practice followed by the New Hampshire Department of Education and EVERY public school administrator in the state of New Hampshire.

Parents deserve to have complete confidence in the tests that are administered in their local public schools.¬† The “opt-out” movement began for various reasons. ¬† One reason some parents refused to let their children take the SBA is that the parents had no confidence in the test itself.¬† In the past, partisan legislators and bureaucrats ignored concerns from parents over these assessments. It is good to see that New Hampshire will no longer be using children as guinea pigs with the Smarter Balanced Assessment.

Since N.H. was part of the Smarter Balanced Assessment Consortium for several years, will you add your voice to those who are demanding answers and transparency from the SBAC?  It is important that the SBAC answer the concerns raised by Douglas J. McRae & Williamson M. Evers.

These scores are used in as an accountability tool.  They are used to rank schools and, if schools are ranked at the bottom, the New Hampshire Department of Education steps in with remedies.  Faith in the rankings of schools, reporting on the proficiency of students, current and future assessments, is further diminished when there is a lack of transparency and when testing experts see a disturbing trend.

I am also requesting that the Department of Education analyze the current law and ethical practices in testing.¬† I’ve heard from other testing experts that they would be required to seek written consent from parents before they could administer a psychometric assessment on their patients or subjects.

From my prior testimony on HB 538 (2015): Dr. Gary Thompson, clinical psychologist in Utah, cited in his testimony before the Utah legislature …… Common Core state standards will authorize the use of testing instruments that will measure ‚Äúattributes, dispositions, social skills, attitudes and intra personal resources.‚ÄĚ

In other words, this assessment will measure exactly what legislators serving on the House Education Committee in the prior session said they did not want measured.

He stated that, ‚ÄúThe level of information these provide about a particular child is both highly sensitive and extremely personal in nature. In a clinical setting these mental health records are strictly protected by multiple federal state and professional association regulations, including HIPAA.‚ÄĚ

Parents want to know that their children can compute math problems.They are not sending their children to school for mental health evaluations, especially without parental knowledge or consent.  If a Child Psychologist would lose professional licensure in a private practice for doing what our public schools do routinely, that should concern all of us.

I hope you, the State Board of Education Members and our elected officials will begin taking this issue seriously.  From some of the proposed legislation on privacy and parental notification, I can see that some legislators are just as concerned.  My hope is that as you move forward, you will take this information under consideration and make better- informed decisions on testing companies and practices.


Ann Marie Banfield
Education Liaison, Cornerstone Action