Meeting of the Board of Regents | September 2007
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THE STATE EDUCATION DEPARTMENT / THE UNIVERSITY OF THE STATE OF NEW YORK / ALBANY, NY 12234 |
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TO: |
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FROM: |
Johanna Duncan-Poitier
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SUBJECT: |
Identification of Ability-to-Benefit Tests |
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DATE: |
August 29, 2007 |
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STRATEGIC GOAL: |
Goals 2 and 4 |
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AUTHORIZATION(S): |
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SUMMARY
Issue for Decision (Consent Agenda)
What federally approved ability-to-benefit tests should the Board of Regents identify to determine eligibility for State financial aid for students without a U.S. high school diploma or its recognized equivalent?
Reason(s) for Consideration
Required by State statute.
Proposed Handling
This question will come before the full Board for action at its September 2007 meeting.
Procedural History
At its June 2007 meeting, the Board took emergency action to approve regulations to implement provisions of Chapter 57 of the Laws of 2007 that address ability-to-benefit tests. One provision of the new law and regulations requires students seeking Tuition Assistance Program (TAP) awards and other State financial aid for the first time in the 2007-08 academic year to pass a federally approved ability-to-benefit (ATB) test identified by the Board of Regents if those students do not possess a U.S. high school diploma or its equivalent. The purpose of this item is to identify acceptable ATB tests.
Background Information
Under the Federal Higher Education Act, students seeking to qualify for Pell grants or other Title IV aid and who do not have a high school diploma must demonstrate an ability to benefit from education or training by achieving a passing score, as identified by the Secretary of the United States Department of Education (“Secretary”), on an ability-to-benefit test (ATB) approved by the Secretary. At this time, the following ATB tests are approved by the Secretary:
- Accuplacer
- ASSET
- Career Programs Assessment (CPAt)
- Combined English Language Skills Assessment (CELSA)
- COMPASS
- Descriptive Tests of Language Skills (DTLS) and Descriptive Tests of Mathematical Skills (DTMS)
- Wonderlic Basic Skills Test
- WorkKeys Program
In addition, any student applying for TAP or other State student financial aid who does not possess a U.S. high school diploma or its equivalent must achieve a passing score (as set by the Secretary) on one of those tests. Chapter 57 of the Laws of 2007 modifies this State requirement for students first receiving aid under Section 661 of the Education Law (e.g., TAP) in the 2007-2008 academic year and each academic year thereafter. One modification is that students impacted by the law must receive a passing score on a federally approved ability-to-benefit test identified by the Board of Regents as satisfying eligibility requirements. This requirement applies to eligible degree-granting institutions.
For the fall semester of the academic year 2007-2008, institutions may use all federally approved ability-to-benefit tests. For academic terms after the fall semester of academic year 2007-2008, however, only those approved ATB tests identified by the Regents will be acceptable to determine eligibility for State financial aid for students without a U.S. high school diploma or its equivalent. Tests identified by the Regents can be used by institutions until such time as the Regents determine that a test is no longer satisfactory in determining eligibility for awards and loans under Education Law. The Board may also identify additional tests in the future as merited.
To assist in implementing the requirements of the new State law, the Department convened a workgroup of representatives from the four sectors of higher education. These SUNY, CUNY, independent institution, and proprietary college administrators were selected because of their oversight of student financial aid and academic affairs.
Based on the workgroup's guidance as well as the Department's discussions with selected test providers and institution representatives, and informed by the Department's experiences with institutions that employ the various tests, the Department has identified Accuplacer, Asset, CELSA, and Compass as the most suitable ATB tests at this time. The CELSA test (for ESL students), which measures English language skills, is recommended with the condition that it must be accompanied by the numerical/quantitative elements of the Accuplacer, ASSET, or COMPASS tests at pass scores approved by the Regents. Regents action on this recommendation will eliminate institutions' ability to use the CPAt, the Descriptive Tests, Wonderlic, and WorkKeys to qualify non-high school graduates for State financial aid awards.
Recommendation
Based on information provided to date by the test publishers, analysis by the ATB workgroup, and the Department's experiences with institutions and the tests currently employed, it is recommended that the Board of Regents identify Accuplacer, ASSET, and COMPASS as acceptable ability-to-benefit tests, as required under Section 661(4)(d) and (e) of the Education Law (as added by Chapter 57 of the Laws of 2007) and Section 145-2.15 of the Regulations of the Commissioner of Education, and identify CELSA as an acceptable ability-to-benefit test with the condition that passing scores approved by the Regents for that test be accompanied by Regents-approved passing scores on the numerical/qualitative elements of the Accuplacer, ASSET, or COMPASS tests.
Timetable for Implementation
The Department will publish the list of acceptable ability-to-benefit tests, as required under law and regulation, following the Board's identification of those tests. Institutions and students subject to the law will be limited to ATB tests identified by the Board of Regents starting after the fall semester of academic year 2007-2008.
Information in Support of Recommendation
Currently, any student applying for TAP or other State student financial aid and who does not possess a high school diploma or its equivalent from the United States must achieve a passing score (as set by the Secretary of Education) on an approved ability-to-benefit test:
- Accuplacer
- ASSET
- Career Programs Assessment (CPAt)
- Combined English Language Skills Assessment (CELSA)
- COMPASS
- Descriptive Tests of Language Skills (DTLS) and Descriptive Tests of Mathematical Skills (DTMS)
- Wonderlic Basic Skills Test
- WorkKeys Program
The Department estimates that 22 SUNY campuses and community colleges, 15 independent colleges and universities, and at least 17 proprietary colleges use one of the identified tests in either their admission process, in student aid decisions, or for placement of students. The following table illustrates the distribution of credential types of full-time, first-time enrollees:
Full-time, First-time Enrollment by Type of Credential, Fall 2006
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SUNY |
CUNY |
Independent |
Proprietary |
State Total |
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U.S. |
64,290 |
25,136 |
55,205 |
7,406 |
152,037 (94.1%) |
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817 |
3,388 |
1,582 |
446 |
6,233 (3.8%) |
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No Credential |
484 |
0 |
1,042 |
1,860 |
3,386 (2.1%) |
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All |
65,591 |
28,524 |
57,829 |
9,712 |
161,656 |
Effective July 1, 2007, students receiving their first award under Section 661 of the Education Law (e.g., TAP awards) in the 2007-2008 academic year must have a high school diploma or its equivalent from the United States or receive a passing score on a federally approved ability-to-benefit test identified by the Board of Regents.
The new requirement only applies to eligibility for State student aid programs for students first applying in the 2007-2008 academic year or thereafter. As a result, the change does not affect the following:
- admission of students to institutions
- student placement into particular courses
- student eligibility for federal Title IV student aid
continuing eligibility for students who received State financial aid prior to the 2007-2008 academic year- non-degree schools
Examples of Test Usage
CUNY makes "extensive use" of COMPASS assessments in reading and mathematics to determine the college readiness of its undergraduate students. In mathematics, for example, baccalaureate students who have not met CUNY's Regents exam or SAT admission standards may demonstrate mathematics proficiency on the COMPASS pre-algebra and algebra modules. The math tests are also used to place students pursuing associate degrees. Based on their performance on those tests, students may be eligible for credit coursework in mathematics, or they may be directed to remedial coursework. In addition, CUNY uses the tests to confirm the proficiency of students exiting remedial instruction and to place students in credit courses. According to CUNY, the University continually reviews its assessment program to determine the appropriateness of cut points and to provide departments with the data they need to place students in credit courses; likewise, test scores "are routinely correlated with performance in courses…."
Tompkins Cortland Community College reports that it uses Accuplacer, ASSET, and CELSA for ATB purposes (all exams) and for placement purposes in college-level coursework (Accuplacer and ASSET). Less than two percent of students admitted to the College each year are admitted on the basis of ATB scores. College representatives noted that the process of aligning cut-off scores with curriculum is ongoing and essential. They described, for example, how a decision to discontinue use of the COMPASS test was made after two years of adjusting that test and the cut-off scores used. That example underscores the importance of ongoing institutional efforts to align cut-off scores with curricula and the purpose for which the test is being used.
At Cayuga Community College, officials use Accuplacer for both placement testing and ATB testing. The cut scores for ATB purposes established by the federal government were incorporated into the College’s placement testing cut scores. The placement testing cut scores were determined through an "examination of national reference data, proficiency statements provided by the College Board [the test publisher], and a review of the established cut scores and placement rules of SUNY community colleges and other institutions which use Accuplacer." Reviews of placements are "conducted periodically to determine whether cut scores are appropriate, and to revise them as necessary." English and mathematics faculty, for example, have provided analyses that have led to adjustments in relating test scores to course placements.
Identification of Appropriate ATB Tests
For the fall semester of the academic year 2007-2008, all federally approved ability-to-benefit tests may be used. For academic terms following the fall semester of academic year 2007-2008, however, only those ATB tests identified by the Regents will be acceptable to determine eligibility for State financial aid for students without a U.S. high school diploma or its recognized equivalent.
Staff provided information about the tests (including sample test questions) to the ATB workgroup along with materials supplied by test publishers. Based on the workgroup's analysis as well as the Department's discussions with selected test providers and institution representatives, and informed by the Department's experiences with institutions that employ the various tests, the Department has identified Accuplacer, Asset, CELSA (in conjunction with the numerical/quantitative elements of another approved test), and COMPASS as the most suitable ATB tests at this time.
Regents action on the Department's recommendation will eliminate institutions' ability to use the CPAt, the Descriptive Tests, Wonderlic, and WorkKeys to qualify non-high school graduates for State financial aid awards. Department data shows that 24 colleges admitted 25 or more students in fall 2006 with no high school credential. Of those, 11 institutions (includes independent and proprietary colleges) used the CPAt for admissions purposes and would be impacted by the recommended action. Based on feedback from the workgroup, however, the recommended ATB tests align well with the tests currently employed by SUNY and CUNY, as well as with the choices made by independent institutions that use such tests.
One independent college represented on the workgroup asked us to retain the CPAt as a qualifying test. They argued that they could raise their pass point for that test to better assess potential students. We did not accept that recommendation because we saw no evidence that this would address the fundamental nature of the test or help the institution to assess the college readiness of its ATB students. Should the CPAt (or other tests) merit identification by the Regents as acceptable tests in the future the Regents can add them to the list of identified tests at that time.
Next Steps and Related Provisions of Law and Regulation
With Regents approval of the recommended ATB tests, the Department will publish the list of identified ability-to-benefit tests, as required under law and regulation. Institutions and students subject to the law will then be limited to ATB tests identified by the Board starting after the fall semester of academic year 2007-2008.
The new regulation also requires each eligible institution to seek Regents approval of the passing score it proposes to use for the approved test(s). Proposed scores cannot be lower than a test's federally approved score. For the fall 2007 term, and until the Department approves a new pass point for a given institution, institutions may use any score that is not lower than the federally approved score. When submitting their proposed scores, institutions must explain their rationale for their choice(s). Passing scores approved by the Regents will remain in place unless:
- the Department finds that the score is no longer satisfactory for determining eligibility for State awards or loans;
- the institution seeks to change the passing score; or
- the institution ceases to offer the approved test.
The Department is developing guidance on the process of identifying pass points. Consistent with the terms of the regulations amended in June 2007 (emergency action), the Department will consider the following elements when evaluating an institution's proposed ATB test scores, among others:
- the levels of curricula the institution offers;
- admission criteria and procedures used in evaluating the capacity of a student to undertake a course of study—and the capacity of the institution to provide instructional and other support the student needs to complete the program;
- the adequacy of academic support services, as indicated by the institution's record in promoting successful student outcomes—evidenced by such measures as the percentage of full-time students enrolling in noncredit remedial courses; the percentage of first-time students returning at the beginning of the next academic year; and the percentage of first-time students who earn their degrees within three years (associate degree) and six years (bachelor's degree) after their entry;
- evidence that the institution evaluates the success of its academic and other support services and uses that data to improve those services and to modify its admission criteria and procedures; and
- the process used in setting proposed pass scores.
The new regulations also specify that ATB tests must be independently administered. These tests could be offered on the institution's campus and considered to be independently administered if the institution's chief executive officer certifies annually to the Department that the administration of the tests meets 12 criteria defined in regulation. The Department will issue guidelines about the content, form, and timing of those annual certifications. This certification will not be required for the fall 2007 semester. The test will be deemed independently administered if its administration meets Federal criteria. If the Department finds that an institution has not complied with the annual certification process or the federal ability-to-benefit procedures, it may require the institution to use an assessment center external to the institution.
The new regulation refers to a "school providing secondary education from a state within the United States," which means "a school authorized, recognized or approved by a State of the Union, American Samoa, the Commonwealth of Puerto Rico, the District of Columbia, Guam, the United States Virgin Islands, the Commonwealth of the Northern Mariana Islands, the Republic of the Marshall Islands, the Federated States of Micronesia, or the Republic of Palau."
In fall 2006, 112 institutions enrolled students based on foreign credentials.
From http://www.act.org/cpat/index.html (August 1, 2007)
From http://www.wonderlic.com/products/selection/wbst/ (August 1, 2007).
From http://www.act.org/workkeys/ (August 1, 2007)
Under Federal regulations, the passing score on each approved test is one standard deviation below the mean for students with high school diplomas who have taken the test within three years before the date on which the test was submitted for Federal approval.