Autism Alliance submits public comments on Michigan’s Waiver Request to Exceed 1% Cap on Alternate Assessment in 2024-25

2024.1218 AAoM Public Comment on Michigan One Percent Alternate Assessment Waiver

• AAoM submitted public comments via the Online Survey link provided on the MDE site, per its stated process.
• AAoM also submitted our organization’s comments via email (MDE-ESSA@michigan.gov) as we find the survey platform to be somewhat limiting for the purposes of this communication.

December 18, 2024

Superintendent Dr. Michael Rice – Michigan Department of Education

608 W. Allegan Street, Lansing, MI 48933

Public Comment on Michigan’s Waiver Request to Exceed 1% Cap on Alternate Assessment in 2024-25

Dear Superintendent Dr. Michael Rice:

The Autism Alliance of Michigan (AAoM) respectfully submits the following comments in response to Michigan’s notice of Waiver Request to Exceed the 1% Cap on Alternate Assessments in 2024-25.

AAoM is a statewide nonprofit with a mission to lead efforts to raise expectations and expand opportunities for autistic individuals across the lifespan. We have been engaged in systems change across Michigan since 2009. One of our core pillars focuses on education, raising expectations for ALL students with disabilities in accessing high-quality, inclusive education that has resulted (e.g., graduation rates, post-secondary opportunities) on par with their neurotypical peers.

As outlined in Michigan’s Public Comment online survey form found at https://www.research.net/r/27KM82L.

1. Please share your comments regarding MDE applying again this year for a waiver to the ESSA 1% cap on alternate assessments.

AAoM COMMENT:

It is clear from the alternate assessment (AA) participation rate data shown in the table below that Michigan’s activities to address and reduce AA participation have been largely ineffective. In fact, AA participation has remained unchanged for three consecutive years (2021-2022, 2022-2023, and 2023-2024). Michigan also administers one of the highest rates of AAs of any state in the nation.

Many states were under the 1% cap when the provision took effect in 2017-2018 and several states that were over the cap have been able to bring their AA rates into compliance.

Meanwhile, Michigan’s ongoing lack of progress results in thousands of students with disabilities being funneled to an assessment with much lower expectations, exposure to the general education academic content standards, and limited access to satisfy the requirements for a regular high school diploma.

2. Please share your comments regarding MDE’s plan for reducing the use of alternate assessments and balancing high expectations for students with support needs of students with disabilities.

AAoM COMMENT:

One of the factors driving Michigan’s high AA participation rate is very likely the assortment of AAs offered by the state: MI-ACCESS Functional Independence (FI), MI-ACCESS Supported Independence (SI) and MI-ACCESS Participation (P). It is highly likely that many students assigned to the MI-ACCESS Functional Independence (roughly half of all SWDs assigned to an AA) should, in fact, be assessed on Michigan’s regular assessment. Yet MDE consistently fails to address this issue in its plans for reducing the use of AAs.

The Autism Alliance suggests that MDE engage in several in-depth data reviews in order to establish the impact of the three 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.

Relying on local education agencies (LEAs) to develop and implement a “standard parent information and consent form” is inappropriate. The MDE should develop these important documents and require all LEAs to use them. This is likely to lead to confusion among parents who move across LEAs in the state.

The newly developed “decision-making rubric” appears to be overly complicated and will likely be very intimidating to parents. It is unclear who will score the rubric and how parents will play an equal role in this procedure.

3. Please share any other comments or thoughts regarding the waiver to test more than 1% of students using alternate standards for instruction and assessment.

AAoM COMMENT:

The Autism Alliance continues to encourage the MDE to 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).

AAoM strongly encourages MDE to strengthen its collaboration with organizations that work on behalf of parents of students with disabilities. In particular, enhance work with 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. Activities might include podcasts, webinars, and YouTube videos showing the use of the decision flow chart “Should My Student Take the Alternate Assessment?” in action. It is critical that MDE step up its activities aimed at parents.

Many of these suggestions were submitted as public comments on previous waiver requests. Additionally, we would like to refer the Michigan Department of Education to the AAoM Blueprint for Alternate Assessment Cap Compliance that was sent on November 1, 2024.

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 colleen.allen@aaomi.org and Heather Eckner, Director of Statewide Education heather.eckner@aaomi.org with any questions or concerns.