Public comments on proposed ESSA-required tests waiver request
It’s actually rare for me to submit public comments to the State Board of Education but yesterday I offered feedback for a second time inside a month. … If you read my last letter on the state’s ESSA Plan proposals, thank you; and you’ll be pleased to know that this week’s letter is only half as long! That’s because the problems with the state’s proposals to change the Oklahoma School Testing Program are clear and easily documented.
In fact, these few highlighted portions of Title 70 sufficiently illustrate why the state’s accountability system cannot be “modernized” within a school year as well as who has the authority to do so.
Section 1210.508 of Oklahoma Statutes Title 70, The Oklahoma School Code, does not include the State Superintendent in the process of adopting a “statewide system of student assessments.”
The biggest problem with this waiver request (same as the state’s March 2025 request) is that it does not meet the requirements of the U.S. Secretary of Education. These are clear on page 4 of her July 29 invitation-to-waive letter. Oklahoma’s request does NOT describe:
HOW the waiving of requirements “will advance student academic achievement”
WHAT methods the OSDE and schools will “use to monitor and regularly evaluate the effectiveness of the implementation of the waiver”
WHETHER the Department will “maintain or improve transparency in reporting to parents and the public on student achievement and school performance”
To summarize why the state’s proposal should not be considered for 2025-26, I quoted Dr. Megan Oftedal, Executive Director, Office of Educational Quality and Accountability, who emailed the state superintendent about her concerns on August 13.
“We support bold, forward-thinking moves to improve education in Oklahoma. If the U.S. Department of Education approves Oklahoma’s ESSA waiver, we will fully back efforts to implement a locally-driven assessment system for grades 3–8. This would be a significant shift in how we measure and report student learning, and we want to work alongside you to ensure it delivers the results Oklahomans expect: stronger schools, better outcomes for students, and greater accountability to taxpayers.”
And while student assessment data contributes to all of these goals (bold emphasis mine), no one likes state tests. I could write many more pages on how the OSTP needs to change. That is why it is a good idea for the Oklahoma Legislature to consider next year, possibly in the manner of Texas lawmakers this year. To that end, my email this morning went to all State Board members and was copied to State Superintendent Ryan Walters, my representative, senator, governor and congressman, among interested others.
FYI - Here are the email attachments:
Letter to parents (on or about Aug. 8, 2025) and snip of appropriations in Senate Bill 1126 (May 29, 2025)
Email from the Executive Director of the Office of Educational Quality and Accountability (Aug. 13, 2025)
Report to the Commission for Educational Quality and Accountability (Aug. 12, 2025)
Title 70 Oklahoma Statutes related to the OSTP and state accountability system under ESSA (Aug. 8, 2025)
Let me know any remaining questions you have on this topic, and feel free to steal my evidence to support your public comments that should be submitted by Monday, Sept. 8. As the public’s non-attorney spokesperson, I thank you!
