Autism Alliance provides public comment to the State Board of Education on the overuse of Alternate Assessments (April 8, 2025)
Autism Alliance of Michigan Public Comment
State Board of Education
April 8, 2025
Good afternoon board members, Superintendent, and department staff.
My name is Jenna Friedman. I am a graduate student at Wayne State University, a member of the Michigan Parent, Advocate & Attorney Coalition (MiPAAC), and an Education Intern at the Autism Alliance of Michigan.
Last month, the Autism Alliance continued to provide public comment about the findings from our Special Education Experience (SEE) Survey bit.ly/AAOM-SEE, and highlighted the unacceptable graduation rates of students with disabilities in Michigan—some of the lowest in the nation.
Today, I would like to address an interconnected disparity: The overuse of alternate assessments for students with disabilities.
The overuse of alternate assessments is contributing to the lower graduation rates of students with disabilities because it takes them off the graduation track to earn a high school diploma.
Alternate assessment participation in our state has remained unchanged for three consecutive years (2021-2022, 2022-2023, and 2023-2024). Michigan also administers one of the highest rates of alternate assessments of any state in the nation.
Michigan’s ongoing lack of progress results in thousands of students with disabilities being funneled to an assessment with much lower expectations, less exposure to the general education academic content standards, and limited access to satisfy requirements for a regular high school diploma.
Michigan implements three different levels of alternate assessment: “Functional Independence,” “Supported Independence,” and “Participation.”
It is highly likely that many students placed on the MI-ACCESS Functional Independence assessment (used for about half of all students with disabilities on alternate assessments) should be taking Michigan’s regular assessment instead.
To date, none of the waiver requests from the Michigan Department of Education to exceed the ESSA 1% cap on alternate assessments have provided a breakdown of participation by disability category. Without publicly available, disaggregated data, it is difficult to assess which students are being inappropriately placed on alternate assessments, and why.
It is also critical that MDE step up its activities aimed at parents. The current materials and processes are overly complex and exclude many families from meaningful participation in decisions about graduation paths.
This is not AAoM’s first call to action: The Autism Alliance submitted a Blueprint for Alternate Assessment Cap Compliance to the Department in November 2024, and followed with public comment on the state’s waiver request in December which outlined steps the state department can take to address this issue.
We call upon the Michigan Department of Education to listen to the voices of lived experience.
We urge the Department to act with urgency to move students who have been inappropriately placed on alternate assessments back onto the regular assessment track by addressing the issues that allow these patterned inequities to persist.
Thank you for your time and consideration.
View the April 8, 2025 Michigan State Board of Education meeting –
AAoM’s public comments are at the start of the afternoon session (9:16-15:20):
- Michigan State Board of Education Meeting for April 8, 2025 – Morning Session
- Michigan State Board of Education Meeting for April 8, 2025 – Afternoon Session
About the Autism Alliance of Michigan
The Autism Alliance of Michigan (AAoM) is a 501(c)(3) organization serving as a trusted ally and partner for thousands of families across the state. AAoM’s mission is to lead efforts to raise expectations and expand opportunities for people connected to autism across their lifespan. The organization’s Education pillar drives initiatives that address systemic barriers to education, focuses on student-centered advocacy, and educates families on related topics – working towards its goal to make Michigan a top 10 state for special education outcomes. For help finding resources, providers and information contact our AAoM Navigators at 877-463-2266 (AAOM) or email at navigator@aaomi.org. More information about AAoM’s Education pillar can be found at www.autismallianceofmichigan.org/education-initiatives.
###
Are you a parent, advocate, or attorney dedicated to student-centered advocacy?
Join MiPAAC! mipaac.org/join-mipaac