Dear Senator Cassidy,

We, the undersigned education advocacy organizations, greatly appreciate the opportunity to provide comments related to the important issue of measuring student growth. As you note in the request for information, measuring growth is essential for providing families and policymakers with data about how students are progressing in their learning over time. This information can be used to determine where to target resources and supports to ensure students are making adequate progress towards proficiency against academic standards.

Importantly, while states should continue to consider how best to incorporate student growth into their accountability, school support, and reporting systems, no changes to federal law are required to do so. Congress explicitly recognized the limitations of accountability systems based solely on proficiency when it reauthorized the Elementary and Secondary Education Act (ESEA) through the bipartisan Every Student Succeeds Act (ESSA). As a result, ESSA provides states with clear flexibility to include measures of student growth as part of their accountability frameworks.

Specifically, ESSA permits states to incorporate growth in addition to proficiency on annual assessments (ESEA section 1111(c)(4)(B)(i)(II)) and ESEA section 1111(c)(4)(B)(ii)(I)) in their accountability systems. These provisions reflect Congress’s intent to move beyond a narrow focus on proficiency alone and empower states to design more nuanced systems that recognize progress, promote continuous improvement, and provide families and policymakers with a fuller picture of school performance. The fact that nearly every state incorporates growth in their accountability system demonstrates that further Congressional action to incentivize the use of growth is unnecessary. However, the presence of a strong U.S. Department of Education is necessary to foster the goals of Chairman Cassidy’s information request, including sharing  effective practices among states regarding effective practices pertaining to the use of growth measures and ensuring the continued administration of the National Assessment of Educational Progress (NAEP).

States’ ability to measure growth accurately and use it meaningfully depends on the continued enforcement of key federal guardrails embedded in ESSA. Without consistent statewide assessments, transparent accountability requirements, and a strong federal role in implementation and oversight, the growth measures Congress intended to enable cannot function as designed. For these reasons, protecting and enforcing existing federal requirements is essential to ensuring student growth data remains valid, comparable, and actionable.

Federal Guardrails Essential for Growth

Measuring student growth and incorporating this into state accountability systems is only possible when all students annually take the same assessment across the state, as required by federal law. This consistency is what produces achievement and growth data that can be validly compared across student groups, classrooms, schools and districts, which allows educators, administrators, and policymakers to make decisions about how to best support the needs of all students. Without this, it would be impossible to understand where to target limited supports and resources, including the use of disaggregated data to identify and address  opportunity gaps between student groups. This data also helps identify which schools and districts are most effectively supporting students who have fallen furthest behind – informing advocates, educators, and policymakers about which strategies should be scaled, and helping parents understand where their children are most likely to thrive.

However, this consistency needed for comparability is increasingly under threat. In July 2025 the Trump Administration issued a Dear Colleague letter encouraging states to seek flexibility from federal requirements under ESSA, which includes assessment and accountability requirements. Already, Indiana has requested flexibility from accountability requirements that would allow schools to hold students to different standards, particularly in high school, and Idaho is proposing flexibility from assessment requirements that would make it impossible to compare the achievement of high school students across the state and–to the point of this RFI–limit the ability to validly measure growth in elementary school by replacing their current 3rd grade assessment. We urge the committee to tell the US Department of Education (ED) to uphold these essential guardrails in federal law to enable the comparable data needed to hold schools accountable for supporting the growth and achievement of all students.

Considerations for Growth Models

Including growth in state accountability systems alongside achievement also provides a fairer measure of school quality by giving schools credit for the progress students make from year to year, particularly when schools have large numbers of students that are starting the year far below grade level. Yet another important aspect of fairness is providing honest information to families about student progress–with clarity about whether students are making progress towards grade-level standards, not just in comparison to other students or schools.

The RFI alludes to the various ways in which states measure and report student growth. In 2024, EdTrust conducted a review of state accountability systems and found that a plurality of states (24) use student growth percentile (SGP), 13 use value-tables, 10 use growth to standard, and 8 use value-added models. There was also a slight shift toward the use of SGP, with four states shifting to that model between 2019 and 2024.

Each of these growth measures say something different about how students are progressing in their learning:

• Value-added models use advanced statistics to determine the impact of students’ school and educators on their academic growth. This is helpful, particularly in comparing schools across a district or state. However, these use complicated statistics, which makes them difficult to communicate to families and communities. Additionally, they are designed to compare different schools’ impact, rather than whether students are making adequate progress toward grade-level standards.
• SGP is similarly a comparative, or normative, measure and provides a score that indicates how students’ growth compares to other students with similar achievement in the previous year. These models are popular because families are familiar with receiving information about their children in percentile terms. However, like value-added models, SGP doesn’t provide any information about whether students are actually moving towards proficiency. In fact, in instances when larger numbers of students are actually moving further away from proficiency (like the pandemic) a student could have a high SGP score while falling further behind.
• Growth to standard measures indicates the amount of progress students make towards grade-level standards, and may include an estimate of whether a student is on track to meet standards over a set period of time. Unlike the normative measures above, growth-to-standard focuses on moving students towards proficiency. However, given that students that start the year far below grade-level have to grow much more than students at grade level, these measures could be viewed as unfair by school leaders and educators with large proportions of students below grade level.
• Value tables, like growth to standard, measure whether students are making progress towards proficiency. Schools get credit for moving students from one proficiency level to another, and sometimes within a proficiency level. While value tables don’t isolate a school’s specific impact, they are fair for schools that serve high numbers of students entering school below grade level, by giving them credit for any progress students make over the course of the year. Value tables are also simple to calculate and understand by families and communities.

We believe that a state’s measure of growth should be of strong technical quality, easily understood by a wide range of stakeholders, and focus on whether student performance is progressing toward grade level standards. Given this, while we understand that states need to weigh their own priorities, and that ESSA prohibits the Secretary of Education from requiring states to use growth and from prescribing specific metrics used to measure growth (ESEA section 1111(e)(1)(B)(iii)(III)), we strongly believe that value-table measures best balance fairness, clarity, and focus on real progress towards proficiency.

Strong Accountability Systems Require Robust Federal Supports

In addition to selecting a growth measure, how much relative weight student growth and proficiency matters in how states determine school quality. Neither growth nor achievement alone tell the full story of school quality, which is why we believe states should have similar weights for each in their systems. According to EdTrust’s review of accountability systems, 13 states weigh growth within 5 percentage points of achievement, 8 weight growth above achievement between 5-10 percentage points more than growth, while just four weigh achievement substantially more than growth (10+ percentage points). No state weighed growth substantially more than achievement at the time of our study though Illinois has recently proposed a dramatic increase in the weight of growth (50% growth as compared to 15% for achievement in elementary and middle schools).

It is essential that states have robust technical assistance as they consider changes to their accountability systems, including how they are measuring and weighing student growth. One example of a current research investment—that thankfully is underway despite being under threat when ED nearly cancelled all grants under Part D of the Individuals with Disabilities Education Act last summer—is the MIDAS Project study, which reinforces the need to continue to support existing flexibilities in ESSA, and to ensure ED provides vigorous and ongoing technical assistance to states. This project is designed to help educators better use data from multiple measures of academic achievement to inform instructional decision making for students with disabilities, including English learners with disabilities, who move from the statewide alternate assessment based on alternate academic achievement standards to the general assessment. This is just one of many examples highlighting that ED is not simply a passthrough for federal grants: it is charged with providing support through the policy knowledge and technical expertise of their staff, including the implementation of ESSA-aligned assessment and accountability systems that include all students.

However, the current administration’s efforts to dismantle the Department –through the firing of countless staff and the illegal transfers of authority from ED into other federal departments–threaten the continuation of that support. Similarly, last year ED cancelled grants that supported national comprehensive centers and ten regional education labs. These entities convene state and district leaders with national experts to provide critical support with implementing federal law and addressing student needs in alignment with research-based best practices, including assessment and accountability requirements.

The administration has also gutted the Institute of Education Sciences (IES), a trusted, centralized source of high-quality research, used to identify effective strategies and scale practices that improve student achievement and close opportunity gaps. IES also administers the National Assessment of Educational Progress (NAEP), which provides the only data that compares the academic achievement of students across states. NAEP provides a consistent national measure of student achievement that enables policymakers and the public to hold states accountable for maintaining high standards for all students. Particularly important for understanding national academic growth, NAEP’s Long-Term Trends (LTT) assessments enable a longitudinal view of changes in student achievement across several decades. However, cuts by this administration have delayed NAEP results and resulted in scaling back plans for future administrations of the test, including Long Term Trends, limiting the public’s access to essential information on student achievement. We urge you, as the Chairman of the Senate HELP Committee, to conduct oversight in accordance with Congress’ Constitutionally defined role, and to use his platform to advocate for the reversal of   these damaging decisions and restore these essential supports for states.

Thank you again for the opportunity to weigh in on the importance of measures of student growth and the federal guardrails and supports required for strong state implementation. We welcome the opportunity to discuss our comments further with members of this committee.

Sincerely,

All4Ed
Center for Strong Public Schools
Council of Parent Attorneys and Advocates (COPAA)
EdTrust
Educators for Excellence
Families in Schools (FIS)
National Center for Learning Disabilities
The Center for Learner Equity
UnidosUS