State Board of Education amends, moves changes to Chapter 4 regulations for Keystone Exams

In May, 2012, the State Board of Education gave its initial approval to draft revisions to Chapter 4 regulations (Academic Standards and Assessment), with many of the changes relating to high school graduation requirements and Keystone Exams.  The draft included numerous changes to the version first discussed in March; the Chapter 4 revisions will now be subject to the first stage of the regulatory review process.  There will be additional opportunities for comment and change before the proposal becomes final and effective.

Among the changes under the revised Chapter 4 proposal:

Pennsylvania Common Core Standards/PSSA State Assessment Changes --The revised Chapter 4 proposal references the Common Core Standards as the Pennsylvania Common Core Standards and requires full implementation of the PA Common Core in English Language Arts and Mathematics by July 1, 2013. The regulations also address the alignment of the Pennsylvania System of School Assessment (PSSA) exams with the Pennsylvania Common Core Standards as they will be revised in these two content areas for students in grades 3-8. The regulations delete reference to the PSSA in Writing for grades 5, 8, and 11.  A writing component will be part of the PSSA in English Language Arts for grades 3-8; the 11th grade writing PSSA will be discontinued in favor of the Keystone Exam in Literature.

Assessment Security -- New language changes the existing test security policies by removing the current right of parents/guardians to review any state assessments two weeks prior to administration, except when necessary to determine whether the assessment conflicts with their religious beliefs. In asserting a religious objection to the assessment, the proposal adds a requirement that the parent/guardian explain the objection in their written request for excusal.

Elimination of Mandated Strategic Plan -- The proposal removes the requirement for districts to complete state-prescribed strategic planning every six years.  However, when a district's current strategic plan is expired it will have to submit five plans currently required under other regulations to the Department of Education for approval as follows:

• Every six years plans for teacher induction (Ch. 49), student services (Ch. 12) and gifted education (Ch. 16). 
• Every three years, plans for professional development (Ch. 49) and special education (Ch. 14).  

The following are some of the key changes to the current requirements regarding high school graduation requirements:

Charter School Clarification -- The proposal clarifies that the regulations regarding Keystone Exams and graduation requirements apply to charter and cyber charter schools, in addition to school districts and AVTSs.

Current Graduation Requirements Extended Through 2015-16 – The proposal extends the current Chapter 4 graduation requirements, currently effective through the Class of 2014, to the Class of 2016. Those requirements include:  1) Course completion and grades; 2) Completion of a culminating project; 3) Demonstration of proficiency in reading, writing and math on either the state assessments administered in grades 11 or 12 or local assessments aligned with the standards and state assessments.

School Board Approval – New language clarifies that high school graduation requirements and any revisions to them must be approved by the board of school directors.

Graduation Requirements Beginning in the 2016-17 School Year – Under the proposed Chapter 4 changes, PDE will eventually develop five Keystone Exams for graduation purposes, and students must score proficient or above in all five in order to graduate.  Use of all five exams will be phased-in, with just three Keystone Exams required for the Class of 2017, and additional exams added later. 

The requirement for the Keystone exam score to count as one-third of the student's grade is removed. Therefore, the use of the Keystone Exams will be as a stand-alone requirement for graduation.  Districts will retain the option for locally-developed and independently-validated local assessments to replace the Keystone Exams.  The proposal also eliminates the requirement for students to complete a culminating project in order to graduate.

Effective with the graduating Class of 2017, graduation requirements include the following: 1) Course completion and grades; 2) Demonstration of proficiency as determined by the school district or charter or cyber school in each of the state academic standards not assessed by a state assessment; and 4) Demonstration of proficiency in English language arts, math, and science as determined through any one or a combination of the following:

• Completion of secondary level coursework in English Language Arts (currently listed as English composition and literature), Algebra I and Biology and demonstrated proficiency on the associated Keystone Exam in those three content areas.
• Locally approved and administered assessments that they are independently and objectively validated once every six years in conjunction with submission of the school district's strategic plan. Local assessments may include a variety of assessment strategies and may include the use of one or more Keystone Exams.
• Completion of an Advanced Placement or International Baccalaureate Exam that includes academic content comparable to the appropriate Keystone Exam.

Additional Keystone Exams Phased-in -- Two additional Keystone Exams will be required contingent upon state funds being available for development of the exams, project-based assessments and funding to validate related local assessments for each:

• Beginning with the Class of 2019, students will also have to pass a Composition Keystone Exam. The test and related project-based assessment will be made available for use in the school year 2015-16.  (However, schools must administer the exam during the 2014-15 school year solely for the purpose of gathering data to set performance level cut scores.)
• Beginning with the Class of 2020, students will also have to pass a Keystone Exam in Civics and Government.  The test and related project-based assessment will be made available for use in the school year 2016-17. (However, schools must administer the exam during the 2015-16 school year solely for the purpose of gathering data to set performance level cut scores.)
• Therefore, beginning with the Class of 2020, students will have to pass five Keystone Exams in order to graduate.

Other Keystone Exams for Voluntary Use -- The department will develop five additional Keystone Exams that will be available for voluntary use by districts, subject to funding by the state.  

The tests and schedule is as follows: In school year 2016-17: Geometry; in 2017-18: U.S. History; in 2018-19: Algebra II; in 2019-20: Chemistry; and in 2020-21: World History. There will be no related project-based assessments or validation of local assessments for these exams.

Using Local Assessments for Graduation -- Locally approved and administered assessments may be used for graduation purposes provided that they are independently and objectively validated once every six years in conjunction with submission of the school district's strategic plan. The local assessments may be designed to include a variety of assessment strategies and may include use of one or more Keystone Exams. Schools must validate assessments used to determine student proficiency in the state academic standards in English language arts, algebra I and biology. School boards can only approve assessments that have been validated.

PDE will establish a list of entities approved to perform validations of local assessments. The cost to validate local assessments will be evenly divided between the school district and PDE and will be subject to appropriations provided by law. If PDE cannot provide sufficient funding to cover its share, local assessments submitted for validation will be deemed to be valid for the balance of the strategic plan period until either a new or mid-point update to the strategic plan is due to the department.  

Using AP or IB Exams – Completion of an Advanced Placement or International Baccalaureate exam that includes academic content comparable to the appropriate Keystone Exam may be used for graduation purposes.  The secretary of education will establish a score for these exams that would be considered comparable to the proficient level on the appropriate Keystone Exam.

Waivers for Extenuating Circumstances – The regulations maintain provisions for the secretary of education to waive one or more of these requirements on a case-by-case basis for good cause based upon receipt of a written request from the chief school administrator to accommodate students who experience extenuating circumstances, including but not limited to serious illness, death in immediate family, family emergency, or frequent transfers in schools.

Waivers for Out-of-State Transfer Students –The provisions allow any student who transfers from an out-of-state school and has demonstrated proficiency on an assessment congruent with the academic standards assessed by a Keystone Exam to have satisfied the requirements, subject to guidelines developed by the secretary and approved by the State Board of Education.

Transcripts – The proposal amends requirements of what must be included on student transcripts. As proposed, PSSA scores will continue to be included, and beginning in 2016-17, the performance level demonstrated, not the score, for each Keystone Exam will be on the transcript.

Transition -- To effect successful transition regarding requirements through the 2015-16 school year and requirements beginning in 2016-17, students who will graduate in the 2016-17 school year or thereafter, who successfully complete courses with the required academic content for which Keystone Exams or local validated assessments were not available at the time the course was completed, will be deemed proficient. This also covers additional requirements beginning in the 2018-19 and 2019-2020 school years.

Administration of Keystone Exams/Supplemental Instruction – The regulations call for PDE to offer administration of the Keystone Exams at least 3 times each year (fall, spring and summer). Scores will be provided to schools no later than 10 days prior to graduation. Schools may request the use of alternative test administration and scoring timeframes.

A student may retake an exam or exam module in which he or she did not score proficient or above, so long as the student received supplemental instruction. Students through grade 11 who did not score proficient on a Keystone Exams must participate in supplemental instruction prior to re-taking the Keystone/module.  The school must continue providing supplemental instruction either until the student demonstrates proficiency in the subject area or until the student meets the criteria for participating in a project-based assessment.

Project-Based Assessment – The regulations allow students who are unable to demonstrate proficiency on an exam or exam module to enter into a project-based assessment that is aligned with the eligible content in the designated Keystone Exam.  Except for high school seniors, students must have taken the course related to the Keystone Exam, met the district's attendance requirements, participated in at least two years of supplemental instruction and made two attempts at demonstrating proficiency on the exam.  Successful completion of a project-based assessment will satisfy the requirements for high school graduation. The project assessment system will be administered by schools and scored by statewide panels.

Emergency Waiver for Students Not Successful on Project – A new option is created for students who, after  attempting successful completion of exams and a project, still may be in danger of not being able to graduate. Under the proposal, the secretary of education may waive the requirement on a case-by-case basis for good cause for a 12th grade student who was not successful in completing a project-based assessment.

The emergency waivers would be based upon receipt of a written request from the chief school administrator. The waiver request would certify that the student: 1) has met the school's local requirements for graduation; 2) has not demonstrated proficiency on a Keystone Exam or module; 3) has participated in a satisfactory manner in supplemental instruction services; and 4) has not successfully completed a project-based assessment.

The Department of Education will review emergency waiver requests and decisions will be made no later than 10 calendar days prior to graduation.

A chief school administrator who requests waivers for more than 10% of students who participated in a project-based assessment must submit an action plan for approval to the secretary. The plan must identify improvements that school will implement to each course associated with the Keystone Exam content for which the waivers were requested.

Replacing the 11th Grade PSSA -- The department is seeking permission from the U.S. Department of Education to have the Keystone Exam system approved to replace the 11th grade PSSAs as the high school level single accountability system under the No Child Left Behind Act.  If approved, the Keystone Exams would be used to determine AYP. The biology Keystone Exam will be used as the high school level science assessment required by NCLB, although these scores are not used to determine AYP.

Dual use of Keystone Exams /Transition Plan

The Keystone Exams in Algebra I, Literature and Biology will be used for two purposes. The first is the proposed state graduation requirement. For this purpose, beginning next year, students who take courses that cover the content of any of the three Keystone Exams may take the exams. The second purpose is for federal accountability as required under the No Child Left Behind Act. The department has developed a proposed plan to transition the use of the Keystone Exams for AYP. The plan will be fully realized in 2016 when PDE will use the grade 11 enrollment as the population for AYP as is done currently.  However, since students will be taking these exams at various points between grades 7-11, PDE needs an interim method of defining the AYP population.

The department has developed a plan that is subject to approval from the USDOE. Under the plan, PDE intends to define the population as all Keystone Exam test takers in grades 9, 10 and 11. The department will bank the scores of students who take the exams in grades 8 and below.  Those scores will count when the students enter high school. PDE also is requesting approval to use students' best scores for those who retake the exams. Since these are new assessments, PDE will be able to set new annual measurable objectives for AYP purposes.

Therefore, beginning in the 2012-13 school year, students in grade 8 and below who take relevant courses may take the Keystone Exams to meet graduation requirements and those scores will also be banked for use later for AYP purposes when they get to high school.  Students in grades 9-11 who take relevant courses will take Keystone Exams for AYP purposes only..

Paths to Graduation: Major Changes to Chapter 4 Regulations
Revised: May 2012

(The term "school" as used in this chart refers to school districts, AVTSs, charter and cyber charter schools. Underlined language indicates notable changes in proposed changes.)