ERN DC Submits Comments on Annual Assessment Waivers

Dear Interim State Superintendent of Education Shana Young,

I am pleased to submit a public comment on behalf of Education Reform Now DC (ERN DC) about the Office of the State Superintendent of Education (OSSE) State Plan Addendum and Waiver. ERN DC is a non-profit organization that fights to ensure DC’s public education system justly and equitably serves all students. We are committed to advancing racial equity in public education and regularly evaluating education reforms to see if they are working as intended for student groups who are most marginalized — students who are Black, Brown, English Learners, and those who have different abilities.

Racial equity is defined as “when race can no longer be used to predict life outcomes and outcomes for all groups are improved.”[1] In the District of Columbia, we are a long way from that reality. Currently, there are unacceptable opportunity gaps between student groups, as demonstrated by numerous indicators: graduation rates, attainment of advanced degrees, employment, health outcomes, and life expectancy. Advancing racial equity in DC is urgent, and deeply personal for us.

We cannot change what we do not measure, and measurement is a key component of racial equity. Comprehensive end-of-year state assessments allow states to gather information, target support, advance equity, and track progress — all for the purpose of improving learning and opportunities for each student. The District uses the Partnership for Assessment of Readiness for College and Careers (PARCC) exam for this. For the past four years, DC students have made steady improvement on the PARCC exam, but the percentage of students on track for college and career remains low. In school year 2018-2019:

  • Only 37.1% of DC students scored a 4 or higher in English Language Arts (ELA) and 30.5% in Math.[2]
  • Hispanic/Latino students have made large gains, but still only 37.3% in ELA and 30.5% in Math earned a 4 or higher.
  • 8% of Black students scored a four or higher on ELA and 21.8% in Math.
  • 1% of “at-risk” students scored a four or higher on the ELA and 16.3% in Math.
  • Only 7.9% of students with special needs scored a four or higher in ELA and only 7.2% in Math.
  • 7% of English Learners scored a four or higher in ELA and 22.7 % in Math.
  • And an overwhelming majority, 85%, of White students scored a 4 or higher on ELA and 78.8% on Math.

The differences in these scores are profound and underscore how much work is left to achieve racial equity in DC.

District residents have experienced enormous challenges due to the novel coronavirus (COVID-19) pandemic but Black, Brown, and immigrant communities have been disproportionately impacted. In December, EmpowerK12 released a report showing that DC students are in a COVID learning and mental wellness slide. Their report revealed an overall loss of four months of learning in math and one month of reading, and that “at-risk students have lost five months of learning in math and four months of learning in reading and are falling significantly behind.”[3] Further, “77 % of students reported they are concerned that their family will be exposed to COVID-19 and 45% report that their family’s financial situation has become somewhat or significantly more stressful.”[4] Without assessments, we would not be able to comprehensively measure learning loss and provide support to those who need it the most.

OSSE, like all other states, requested, and was granted in the spring of 2020, waivers of federal requirements relating to assessment, accountability, and some reporting components on state report cards for school year 2019-2020. We commend OSSE for making that decision, as we are advocates of strong, but just accountability. Recognizing that some of the same challenges are still present in school year 2020-2021, we understand why OSSE is once again requesting flexibility in implementing components of the School Transparency and Reporting (STAR) Framework and other accountability elements required in the District’s Every Student Succeeds Act (ESSA)  plan. As such, we commend OSSE for holding firm on its commitment to administer the ELA and math assessments. While we are disappointed that OSSE is waiving the science exam again, we understand that it can only be administered in-person. With that said, we have been unable to track student progress with data for two school years now and are deeply concerned about our students’ future. We urge OSSE to clearly stipulate that these are temporary one-year waivers, and would strongly object to waiving PARCC scores for perpetuity.

Given the COVID-19 related challenges, it is essential for the District to use reliable data from assessments this spring to begin the long and critical process of recovery and to ensure our most marginalized students and schools receive the support and resources they need to succeed. Thank you for your service on behalf of all students. We stand ready and willing to be a partner in achieving racial equity in the District.


Jessica Giles

Deputy Director

Education Reform Now DC

[1] “Advancing Racial Equity and Transforming Government: A Resource Guide to Put Ideas into Action.” p. 9

[2] OSSE. 2018-19 PARCC Results and Resources. Website:

[3] EmpowerK12. December 2020. “COVID-19’s Impact on Student Achievement and Academic Growth in DC.” Website: pg. 1

[4] Ibid pg. 4