Autism Alliance submits Blueprint for Alternate Assessment Cap Compliance

Delivering on advocacy action as a result of findings from the Special Education Experience Survey, Autism Alliance of Michigan sends recommendations for proactive steps to decrease the overuse of alternate assessment for students with disabilities

Letter to MDE_AAoM Blueprint for Alternate Assessment Cap Compliance

November 1, 2024

Superintendent Dr. Michael Rice – Michigan Department of Education

608 W. Allegan Street, Lansing, MI 48933

Transmitted via email: MDE-ESSA@michigan.gov

Autism Alliance of Michigan Blueprint for Alternate Assessment Cap Compliance

Dear Superintendent Dr. Michael Rice:

In anticipation of the Michigan Dept. of Education (MDE) submitting a request for a waiver to exceed the 1% cap on alternate assessments (AA) in 2024-2025, the Autism Alliance of Michigan (AAoM) offers these suggestions for ways that MDE might come into compliance.

Many of these suggestions were submitted as public comment to previous waiver requests.

The table below lays out the history of alternate assessment administration (known as the MI-ACCESS) in Michigan since the 1% cap requirement took effect in the 2017-2018 school year.

MICHIGAN HISTORY OF ALTERNATE ASSESSMENT (MI-ACCESS)

Source: State Requests for Waivers of ESEA Provisions for SSA-Administered Programs

#1: AAOM suggested that MDE “should assemble an Alternate Assessment Advisory Group to review all current resources and make recommendations for new or improved resources. Such a group should include representatives of state disability organizations (Autism Alliance of Michigan, The Arc, etc.), the state’s parent training and information center (Michigan Alliance for Families), the state protection and advocacy organization (Disability Rights Michigan).”

MDE RESPONSE: “MDE will explore forming an alternate assessment advisory group to develop and coordinate guidance on appropriate statewide assessment decision making.”

[Source: https://www.ed.gov/sites/ed/files/2024/03/MI1cap2024.pdf]

AAOM once again encourages MDE to assemble an Alternate Assessment Advisory Group. It appears that MDE is relying solely on the state’s Special Education Advisory Committee (SEAC) for feedback on materials and activities. This provides a narrow view of these critical resources, particularly given that the SEAC does not invite public comment during its meetings.

#2: AAOM continues to suggest that Michigan should further collaborations with the Michigan Alliance for Families including providing supplemental funding to support the development and dissemination of information on the alternate assessment and the important process of determining how students will participate in the state’s assessments. Currently the only information offered on the Michigan Alliance for Families website involves links to information on the MDE website. Additionally, the Michigan Alliance for Families 2024-2025 calendar of events does not include a single event focused on making assessment participation decisions. It is critical that MDE step up its activities aimed at parents.

#3: AAOM continues to suggest that MDE engage in several in-depth data reviews in order to establish the impact of the various alternate assessments currently being offered. These would include (a) examine the participation rate for each of the AAs, (b) further examine participation rate for each AA by disability category (making this disaggregated data publicly available) and (c) further examine participation rate for each AA by student subgroup. To date, no waiver requests have provided a breakdown of AA participation by disability category.

#4: AAOM continues to suggest that MDE examine the three alternate assessments currently offered by the state: MI-ACCESS Functional Independence (FI), MI-ACCESS Supported Independence (SI) and MI-ACCESS Participation (P). To our knowledge, no other state offers three alternate assessments. MDE’s current plan to require ISD’s “to conduct an educational benefit review for all students surpassing the Functional Independence level of alternate achievement expectations, based on test performance on MIAccess, Functional Independence assessments and share the results for approval with the ISD”(page 26)  is not adequate to uncover root causes of over-identification of students assigned to the alternate assessment.

We hope the MDE will consider including these activities in any further waiver request.

Please feel free to contact Colleen Allen, President & CEO of the Autism Alliance of Michigan, at colleen.allen@aaomi.org, and Heather Eckner, Director of Statewide Education, at heather.eckner@aaomi.org, with any questions or concerns.