Autism Alliance provides public comment to the State Board of Education calling for elimination of ‘Functional Independence’ tier of MI-ACCESS (May 13, 2025)
Autism Alliance of Michigan Public Comment
State Board of Education
May 13, 2025
Read here: 2025.0513 Autism Alliance Public Comment_State Board of Ed_Alternate Assessment Call to Action
Good afternoon board members, Superintendent, and department staff.
I’m Heather Eckner and I serve as the statewide director of education for the Autism Alliance of Michigan.
The Autism Alliance Education pillar advances a Whole Child vision for Michigan by catalyzing advocacy and engagement activities to move an equitable education agenda for children and youth with special education needs focused on funding reform, appropriate identification, access to interventions, system accountability, and decreasing disparities.
I am here again this month to address the critical issue of Michigan’s continued overreliance on the use of alternate assessment (known as MI-ACCESS) and its detrimental impact on students with disabilities.
The U.S. Department of Education’s Office of Elementary and Secondary Education (OESE) has denied Michigan’s waiver request to exceed the 1% cap on alternate assessment participation for the (third consecutive year) which includes this 2024–2025 school year, citing insufficient progress in reducing participation rates and failure to meet the 95% assessment requirement for students with disabilities in science.(1)
Michigan’s current participation rate in the MI-ACCESS significantly exceeds the federal cap.
In the 2022–2023 school year, approximately 1.8% of students participated in the alternate assessment. This overrepresentation suggests that many students with disabilities are being assigned to the alternate assessment without adequate justification, potentially leading to long-term educational disadvantages.
The consequences of this overreliance are profound. Students placed in the MI-ACCESS are often denied the opportunity to earn a regular high school diploma, receiving instead a Certificate of Completion. This credential is not recognized as equivalent to a high school diploma, severely limiting postsecondary educational and employment opportunities.
The state’s graduation rate for students with disabilities is among the lowest in the nation, with only 61% earning an on-time regular high school diploma compared to 86% of students without disabilities – a gap of 25 percentage points.
To address these issues, the Autism Alliance urges the Michigan Department of Education to take urgent action and calls to:
- Immediately withdraw the Functional Independence tier of the MI-ACCESS
- . This tier disproportionately includes students who may not meet the criteria for the alternate assessment, leading to unnecessary educational segregation.
- Provide regular briefings to the State Board of Education on the ongoing monitoring calls with the Office of Special Education Programs (OSEP). These updates should include data on participation rates, progress toward meeting the 1% cap, and strategies for reducing overreliance on the alternate assessment.
The continued overuse of the MI-ACCESS not only violates federal guidelines but also perpetuates inequities in educational outcomes for students with disabilities. It is imperative that Michigan takes immediate and decisive action to rectify this situation and ensure that all students have access to a meaningful high school diploma and the opportunities it affords.
Thank you for your attention to this urgent matter.
Again we make our call to action – Michigan must do better for students with disabilities.
We need strong leadership in our state willing to confront honest information about the evidence of outcomes for ALL students in our public schools. And, we need the courage to act with a sense of urgency.
The Autism Alliance is working toward our vision for education that will move Michigan from the bottom toward becoming a Top 10 state in preparing students with disabilities for the most independent life possible through accessible, high-quality, and inclusive education opportunities.
We appreciate your time and consideration.
(1) https://www.ed.gov/media/document/michigan-waiver-request-one-percent-cap-participation-alternate-assessment-sy-2024-25-april-8-2025-109965.pdf
View the May 13, 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 May 13, 2025 – Morning Session
- Michigan State Board of Education Meeting for May 13, 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.
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