Without a federal exemption from state testing for public schools in hand, Kentucky is moving ahead with exams this spring with a plan that includes flexible testing windows and in-person assessment for virtual students, among other changes.

At the same time, the state’s education commissioner is also seeking a temporary reprieve from identifying schools for Targeted Support and Improvement, a label that means one or more student subgroups within a school are performing as poorly as schools in the bottom 5% statewide.

Kentucky only labels TSI schools when it has three consecutive years of testing data to do so, Education Commissioner Jason Glass wrote in a letter to the U.S. Department of Education dated Feb. 15.

“In the spring of 2020, Kentucky received a waiver from federal testing and accountability requirements. This previous waiver also waived the requirements for the identification of federal classifications, including TSI, in the fall of 2020. Due to this waiver, Kentucky is unable to identify schools for TSI status in the fall of 2021 because it does not have three consecutive years of accountability data,” Glass wrote.

The Kentucky Department of Education is asking for public comment on its waiver request, and the public can submit feedback up to 5 p.m. Eastern time Tuesday. The full request is available here with this story online.

Comments can be emailed to kdecommunications@education.ky.gov or submitted to KDE General Counsel Todd Allen at the Kentucky Department of Education, 300 Sower Blvd, 5th Floor, Frankfort, KY 40601. Comments also may be submitted via fax at 502-564-9321.

If granted the federal waiver, Kentucky would not identify TSI schools until as late as the fall of 2024, due to the three-year reporting requirement, Glass noted in his letter.

That raises questions about how the state will ensure marginalized students don’t fall further behind after months of distance learning and limited in-person instruction.

In his letter, Glass wrote that Kentucky will continue to collect and monitor data relevant to school quality and student performance. The state’s partnership with Infinite Campus, an online student information portal, will ensure access to real-time student performance data.

“Kentucky remains committed to maintaining an accountability system that ensures equity for all students,” Glass wrote. “In July 2020, the Kentucky Board of Education adopted a resolution affirming its commitment to racial equity in Kentucky public schools. This commitment is evident through our accountability system. While new TSI schools would not be identified in 2021 under this waiver, Kentucky’s commitment to equity and service will continue to ensure that students from traditionally underserved backgrounds have their physical, emotional and instructional needs met during the 2021-22 school year.”

Additionally, the state won’t identify schools for Comprehensive Support and Improvement or Additional Targeted Support and Improvement this fall.

Currently, Kentucky hasn’t identified any schools for TSI, a label that invites the possibility for intervention from the Kentucky Department of Education.

Even amid the lingering uncertainty, Kentucky is planning to administer state tests this spring, issuing new, tentative guidance Feb. 15.

“Annual state testing provides critical information about school and student performance to parents, educators and state and district policy decision-makers,” the guidance document reads. “The assessment results can help determine if students are meeting academic expectations, identify holes in student learning, areas where supports or assistance are needed and identify gaps among different student groups (e.g., students of color, students with disabilities, students not yet proficient in English, economically disadvantaged students).”

Normally, when not plagued by disruptions driven by a pandemic, administering the state tests takes less than 1% of the entire instructional time set aside for the school year, according to the Kentucky Department of Education.

That said, the KDE “has worked internally and with test vendors to provide flexible testing windows and reduce the amount of time for assessment administration even further where possible,” according to the state guidance document.

The guidance sets out the expectations for schools as follows: “District and school staff should make a reasonable, dedicated effort to assess all students. All students attending school in-person full or part time should be scheduled for testing on their in-person days. Additionally, school administrators should plan, in conjunction with district administrators, to bring in small groups of students who are in a full-time virtual setting for testing. Students served in a homebound or hospital setting who are provided with in-person services should also be scheduled to take the state assessment. School and district testing plans should be communicated to parents in advance of testing windows. Remote proctoring with students taking assessments at home without a trained administrator is not an option on state assessments for the 2020-2021 school year.”

– Follow education reporter Aaron Mudd on Twitter @NewsByAaron or visit bgdailynews.com.

Education reporter. Covers education and related issues, focusing primarily on the Bowling Green and Warren County public school districts and Western Kentucky University.