Thank you for taking the time to participate in the public comment activity for the Michigan Department of Education's waiver extension request for the 1.0 cap on alternate assessment participation for 2023. A draft of the waiver request can be found on the MDE's website here. 

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* 1. MDE completed the following activities related to alternate assessment selection and the 1.0 percent cap during the 2021–2022 school year:

· Reduced statewide participation in the alternate assessments from 15,661 pre-pandemic, to 12,802 in the Spring of 2022; a reduction of 2,859 students being assessed based on alternate achievement standards.

· Made District and Intermediate School District (ISD) Spring 2022 alternate assessment participation rate data available on the special education electronic monitoring system.

· Provided universal professional development and technical assistance to special education administrators, teachers, related service providers, and parents.

· Directed local education agency staff to an online, interactive decision-making tool to assist with appropriate assessment selection and curriculum alignment.

Please provide comment on the activities completed in 2021–2022 and suggestions for additional activities for the 2022–2023 school year.

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* 2. The ESSA requires MDE to collect and submit justification for exceeding the 1 percent cap on alternate assessment. In 2022–2023, justification forms will be collected electronically using Catamaran, an electronic IDEA compliance monitoring system. Technical assistance was provided to ISDs and member districts on how to submit data using Catamaran. Technical assistance recommendations were made, and information shared between MDE and ISDs using Catamaran. Justification forms from the previous year (2021-2023) are available for review online: https://www.michigan.gov/mde/0,4615,7-140-22709_28463-459598--,00.html.
Please provide comment on the use of Catamaran to meet justification requirements.

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* 3. Given the lack of testing in Spring 2020 and lower overall participation in Spring 2021, there is less reliable statewide assessment data available to provide justification to MDE regarding assessment participation rates. For this year’s application, projected rates from the 2020–2021 school year, provided by districts and aggregated by MDE, were used to compare year-over-year progress, as the overall participation rates in 2020-2021 were much lower due to roughly 25 percent of students still learning remotely and unavailable for in-person assessments. These projected rates included all publicly enrolled students, remote or otherwise, and provided a more complete picture of what alternate participation rates would have been if all students and schools were meeting in person and available for assessments during the pandemic. For the 2021–2022 school year, Michigan used actual alternate assessment participation information after all testing windows were complete. This data will:

·       Aid in the application to extend the U.S. Department of Education waiver for the 1% cap on participation in the alternate assessment, due January 10, 2023.

·       Provide the most current information on participation rates to districts, leading up to the next testing cycle. This information can help districts determine training needs and support the monitoring of participation rates.

Please provide comment on the use of projected participation rates from 2020-2021 compared to actual participation rates for Spring 2022.

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* 4. The MDE's focus regarding participation in the alternate assessment (MI-Access) will continue to use a tiered support system to ISDs and districts.

Tier 1. For districts with alternate assessment rates between 1.1% and 1.5% or with 5 or fewer students taking alternate assessments all together, and no disproportionality issues, these districts will receive universal supports and guidance, including technical assistance for IEP teams to make decisions about the appropriate assessments.
 
Tier 2. For districts with either alternate assessment rates between 1.6% and 2.9% or for districts merely over 1.0 percent if they have disproportionately over-designated some demographic sub-group of students (e.g., Hispanic students) to take alternate assessments. These districts will review with their ISD the IEPs of students who have disability types, general educational placement statues, or alternate assessment performance statuses that may not be compatible with a designation as a student with the most significant disability.
 
Tier 3. For districts with alternate assessment rates of > 3.0%, or who have both disproportionately over assigned a demographic subgroup of students to alternate assessments and had overall alternate assessment rates > 1.5%. These districts will review and submit directly to MDE for approval, the IEPs of students who have disability types, general educational placement statues, or alternate assessment performance statuses that may not be compatible with a designation as a student with the most significant disability.

Please provide comment on MDE’s focus regarding participation in the alternate assessment.

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* 5. Please use this space to provide any additional comments regarding the waiver and/justification form and approval process.

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