Description of Proposed Systems Change:

        We propose a systems change in which teachers are provided with resources through Testing Accommodations Training (TAT) sessions and via an internet web site, to help them understand and become informed as to the many and various testing accommodations available for students with disabilities. We will help them to understand why accommodations should be used, and also how to decide which accommodations to use.

        First we will help teachers to understand the background reasons for testing accommodations and why they are necessary. The reauthorization of The Individuals with Disabilities Act (IDEA) in 1997 included the requirement that students with disabilities participate in state and district assessment. It requires that "children with disabilities are included in general State and district-wide assessment programs, with appropriate accommodations, where necessary" (IDEA, 1997). Students who are not in any special education program or do not have a current IEP, but who qualify under Section 504 of the Rehabilitation Act, are also eligible for test accommodations, which must be listed on the students 504 plan. If a student does not participate in state and district assessment, a statement of why participation is not appropriate and how the student will be assessed, must be included in the IEP.

        The State Board of Education Rule 6A-1.0943, Florida Administrative Code (FAC), provided the basis for accommodations to Florida's statewide assessment system for students with disabilities (see Appendix A). In addition, information about allowable accommodations is provided in the test administrator's manual for each of the statewide assessments. Some of the tests chosen by individual districts, however, may not allow accommodations similar to those described in rule 6A-1.0943, and the test manuals must be carefully consulted. If accommodations are used that are not allowed, the test administration will be invalid, and scores from any test using accommodations not listed in the test manual should be reported separately. The student's permanent record should also indicate any accommodations used during testing. (FLDOE, July 1998).

        Through the IEP process, a team of professionals, family members and the student, makes decisions about what accommodations are necessary for the student to be successful in both educational programs and state and district testing programs. This is done using information about the student's current level of performance and annual goals and objectives. Generally the IEP team recommends that the student be given the same types of accommodations for both instruction and assessment. For example, if the student needs extended time in the regular classroom to complete assignments and tests, then it is appropriate to use the same type of accommodation for the state and district assessments. When accommodations are being considered it is very important that input be obtained from everyone involved, including parents ESE staff, regular education teachers, and the student. IEP team members should be provided with information as to why students need specific accommodations as well as a list of possible accommodations. Any decisions on accommodations should be recorded on the IEP, and accommodations used in testing must be the same or nearly the same as those used by the student in classroom instruction and assessment activities (Beech, 1999).

        It is important that teachers understand the difference between accommodations and modifications. An accommodation is an alteration in the administration of an assessment that does not change what is being measured by the assessment. It is intended for those students who would be denied meaningful participation in an assessment without the accommodation. Accommodations allow a student with a disability the same access to an assessment as students without disabilities, and do not interfere with the validity of the test, change the content or level of skill being tested, or provide the student with an unfair advantage (Mastergeorge & Miyoshi, August 1999). They should not be used to compensate for lack of achievement, and are intended to remove or neutralize the limiting effects of the student's handicapping condition by altering the test administration in appropriate ways. They provide the student with the opportunity to demonstrate knowledge, ability, skill or mastery. Modifications on the other hand, are substantial changes in what a student is expected to learn and/or demonstrate. These include changes in instructional level, content, and performance criteria, and may also include changes in test form or format (FLDOE, August 2000). Some examples of testing modifications include reading items to a student when reading is being assessed, using an off-grade level assessment, and use of a calculator for basic computation. Modifications change the content, level of skill, or standard that is being tested, and are appropriate for students whose cognitive ability does not permit the learning of the same content or level of skill (Mastergeorge & Miyoshi, August 1999).

        There is a fine line of distinction between assisting a student to enable him/her to demonstrate individually the skills being assessed, and in providing assistance that in effect, leads directly to test answers. In that instance, the student is not really doing all the work. The accommodation is in effect a modification that disrupts the validity of the assessment or provides an advantage for the student that invalidates the purpose of the assessment. If this is the case, the IEP team should consider the use of an alternative assessment procedure to assess the student's progress (FLDOE, October 1999). Providing an alternate assessment is a modification to the standard approach, and assures that needed modifications to content, support, and level of functioning are individualized for each student (FLDOE, March 2000).

        Preparing the student for the assessment situation should also be considered a necessary accommodation that will provide the student with the tools needed to approach the assessment with confidence and knowledge of the assessment situation, and also the ability to use any necessary accommodations (FLDOE, July 1998). The student should be given the opportunity to learn test-taking skills and experience a practice test. Before the testing situation, the teacher may need to assist the student with relaxation and stress reduction techniques and discuss any motivational practices, such as verbal encouragement, that will encourage the student to do his or her best during the actual test. If accommodations are to be provided, the teacher may need to discuss with the student why they are appropriate, and why the student is being treated differently from his or her peers. The teacher needs to plan ahead for the implementation of accommodations, by determining what staff will be needed, what facilities will be used, and by preparing testing schedules (FLDOE, July 1998).

        Accommodations are changes in the way an assessment is administered. One way to think about accommodations is in terms of what is changed. There are four general categories of assessment accommodations: the setting in which the assessment is administered, the scheduling and timing of the assessment, how the assessment is presented, and the manner in which a student makes responses to an assessment (FLDOE, April 2000).  Appendix B lists many of the possible accommodations according to these categories. According to The Florida Department of Education (August 2000, p.4), Thurlow, Elliott, and Ysseldyke (1998) suggest sample questions to assist in determining the use of the various accommodation categories.

        For the accommodation category of flexible setting, the following questions are suggested:

• Can the student focus on his or her own work with 25 to 30 other students in a quiet setting?
• Does the student display behaviors that are distracting to other students?
• Can the student take the test in the same way as it is administered to other students?

        For the accommodation category of flexible scheduling, the following questions are suggested:

• Does the student take a medication that dissipates over time, so that optimal performance might occur at a certain time of day?
• Does the student's anxiety level increase dramatically when working in certain content areas, so that these should be administered after all other content areas are assessed?
• Can the student work continuously for the entire length of a typically administered portion of the test?
• Does the student use accommodations that require more time to complete individual test items (large print, or Braille, for example)?

        For the accommodation category of flexible presentation, the following questions are suggested:

• Can the student listen and follow oral directions given by an adult?
• Can the student read independently at the level of the test?
• Does the student use large print or Braille in classroom instruction?
• Are instructional materials provided orally to the student?

        For the accommodation category of flexible responding, the following questions are suggested:

• Can the student track from a test booklet to a test response form?
• Is the student able to manipulate a pencil or other writing implement?

        Teachers need to have a procedure in place for determining if an accommodation is reasonable. Such a procedure can be found in Guidelines for Determining Accommodations for Assessment of Students with Disabilities (Florida DOE, August 2000, p.3), and is outlined below:

    1. Determine what the assessment is designed to tell about a student (purpose of test). If the purpose of the assessment is not clear from the test administration manual, contact the test publisher for clarification.
    2. Determine what abilities (other than the skills being assessed) a student needs in order to participate in the assessment and perform the assessment tasks. For example, determine if the assessment requires bubbling in responses, using a pencil, communicating in writing, taking the test in a large group, or following complex directions.
    3. Compare the abilities required by the normal test administration with the abilities of the student. For example, determine if the student is able to bubble in responses, use a pencil, communicate in writing, take the test in a large group, or follow complex directions.
       4. Indicate needed accommodations and ask the following questions:

• Will the accommodation allow the student to demonstrate knowledge and skill fairly accurately?
• Does the accommodation respect the integrity of the assessment and maintain its validity?
• Is the accommodation designed to provide equity rather than advantage?
• Does the student typically use the accommodation in classroom instruction and assessment?
• Is the accommodation respectful of the student's feelings and integrity and in the best interest of the student?

Implementation Plan:

        In order to implement this change strategy, the teachers must first be made aware of the need for the change. This can be done during a regularly scheduled teacher's meeting or during a teacher planning day. During this meeting, the teachers need to first understand the need, for students with disabilities, to receive accommodations during standardized testing. Teachers must also be made aware of a students legal rights to accommodations as well as what they, as teachers, must do to be sure that the students are eligible for accommodations.

        Once the teachers have been educated about the need for accommodations and what is involved, it is time to start checking student records. If a student has a documented disability, there should also be an IEP on file. If that is not in place, it is the first thing to take care of. The special educator checking the records needs to create a master list of students with learning disabilities in each class or grade level. This list should include what disabilities the students are known to have and what accommodations each child is entitled to. Once this master list is compiled, it will be easier to determine the best way to provide the needed accommodations to each child (Appendix C).

Testing Accommodations Training "TAT":

        What is TAT?

        With the use of "high stakes" tests our regular education and special education teachers are given the additional responsibility of being the "testing expert". Now, with the ratification of IDEA, teachers have a new challenge of matching special education students with appropriate accommodations during testing. Research has found that there is a significant deficit in teacher knowledge about testing and the use of accommodations.

        According to a study by Hollenbeck (1998), there is a strong need for teacher in-service training on the acceptable accommodations for statewide testing. The "Testing Accommodations Training" (TAT), was established and designed to meet the needs of teachers throughout Florida who need additional training in the area of testing accommodations. Included in this training is an opportunity for teachers to be introduced to a web-site that will allow them easy access to an information system that will assist them when deciding on appropriate testing accommodations for their students.

        What do teachers want to know about testing accommodations?
The TAT workshop was designed to address and answer the multitude of questions and concerns teachers, parents and students have regarding testing accommodations. The following questions are among the most frequently asked:
    1. What is an accommodation?
    2. Why do we use accommodations?
    3. What is the difference between a testing accommodation and a testing modification?
    4. What does the current legislation say about individual accommodations needed for state and district testing?
    5. How are accommodations addressed through the IEP?
    6. How should teachers decide on appropriate accommodations?
    7. What accommodations are typically provided for students with disabilities?
    8. What are the allowable accommodations for the specific learning disability?

        What is TAT's unique information system?

        TAT presents a web-site that can be used by teachers, parents and students as a quick reference in determining appropriate testing accommodations. This web-site offers links to others sites that contain valuable information about testing accommodations.

        What is the goal of TAT?

        The TAT workshop was designed to inform and empower teachers about testing accommodations. The teacher training makes the teacher a resource so they in turn can educate and empower parents and students. This information is essential for the IEP team to make well-informed decisions about the implementation of testing accommodations. Another purpose for this workshop is help alleviate the confusion and frustration many teachers have with the inconsistencies of definitions and applications of accommodations. This training emphasizes the importance of using appropriate accommodations to increase the reliability and validity of test scores. TAT informs and promotes teachers to comply with state and federal laws with regard to testing requirements. Most importantly, TAT encourages the consistent and appropriate use of testing accommodations to increase the likelihood that formal assessments will demonstrate the student's knowledge ability rather than disability.

        TAT Workshops.

        The Testing Accommodations Training or TAT is a program designed to address the questions and concerns of regular education and special education teachers on the use of testing accommodations. The training program is set-up to provide 15 regional workshops throughout the state of Florida. TAT workshops consist of approximately 35 participants per class ancover a half-day format. This program is designed to coincide with statewide early release days and scheduled within the staff development time frame. Group interaction and participation is encouraged and facilitated by four state certified TAT trainers. The training is funded through a state grant from the Florida Department of Special Education with a no cost provision to the individual regions. TAT requires a collaborative effort on the part of the region to appoint a regional representative to accept certain responsibilities and maintain close communication in setting up the workshop. It is the responsibility of each region to provide the TAT facilitator with information on potential participants in the region, gather names for a class list and find a location that will accommodate 35 people. A checklist of needed accommodations and supplies will be sent prior to the training.
The TAT workshop uses basic adult learning principles to make the training enjoyable, interactive, and meaningful. TAT promotes a positive, non-threatening environment in which teachers can feel comfortable to share their feelings and experiences. Activities are varied to hold the interests of the participants and to keep the learning active. TAT focuses on keeping the subject matter useful and relevant so that teachers can use what they have learned in their classrooms.

        Workshop Costs.

        The TAT workshops have been funded through a state grant from the Department of Special Education and are provided cost-free to the regions they serve. This program consists of 15 workshops that are held in various sites throughout the state of Florida. The workshop sites for the 2000-2001 fiscal year will be held in the following cities; Daytona Beach, Jacksonville, St. Augustine, Gainesville, Tallahassee, Pensacola, Panama City, Ocala, Tampa, Miami, Fort Lauderdale, West Palm Beach, Sarasota, Vero Beach and Orlando. Joan Mathews, Denise Velsor, Susan Ward Davis and Lauren Werch are full-time special education teachers who also hold state certification in TAT training. The four TAT trainers work in teams of two, in which, each team facilitates approximately 7 workshops each. Each trainer has made agreements with their respective districts to work "in kind" during training days. The workshops are scheduled during the region's staff development time frame. The TAT grant money pays for all travel fees, materials and resources (Appendix D). This is a collaborative effort with shared responsibilities and costs for the region being served. The on-site region will be required to absorb any incidental costs accrued during the workshop.

Benefits to Students in Special Education:

        There are many benefits of the proposed system change to students in special education.  A system to access information on appropriate accommodations for students with disabilities should result in more accommodations being used on assessments. This will benefit students with disabilities by assuring their right to testing accommodations and equal treatment in state assessments. Students will be assessed in a way that allows their abilities to be assessed rather than their disabilities, which will give a more accurate evaluation of whether students are attaining academic standards. The increased use of appropriate accommodations should also impact the attitudes of students with disabilities. Many student frustrations should be eliminated which will result in improved performance on the assessment.

Benefits to Schools and School Personnel:

        The benefits of the system change to schools and school personnel will be increased information about testing accommodations for students with disabilities in a format that is easily accessible. Teachers will be able to easily identify accommodations they are able to make for students with a minimum of effort. This should facilitate increased use of accommodations for students with disabilities and will reflect a more accurate demonstration of school performance.

        In addition, teachers will have the information needed to assure compliance with legal obligations.  With the prevalence of testing in schools, schools officials must ensure teachers, parents and students understand testing accommodations and how they should be used. This system will help eliminate teacher frustration and time spent sorting through documentation and information relating to each student's appropriate and allowable accommodations.

Benefits to Community:

        The proposed system change will also provide benefits to the community. In addition, to a shared information base for accessing information for all schools and school personnel in the district, the community will gain the advantage of increased accurate results on assessments. Stability and consistency must be guaranteed across the district, and a unified system to communicate testing accommodation policies will provide the data for teachers to access the information required. The consistency and increased use of accommodations for students with disabilities in schools will result in an improved representation of how the district performs and serves all students in the community.

Obstacles and Challenges and How to Address Them:

        One of the biggest obstacles to providing accommodations is that teachers may find it overwhelming to try to meet the needs of the students. Some accommodations require very little effort on the part of the teacher. In fact, most accommodations just require careful planning and organization.

        For instance, some children will need preferential seating so that they can hear better, read lips, or concentrate better. In the case of a mobility problem, the student may need the easiest place to sit or perhaps a table instead of a desk.

        Additional break time is an accommodation that can be provided without much difficulty. For some children, these breaks can be scheduled, but for others, that may not be possible. For example, if a student has an asthma attack, seizure, or needs an extra restroom break due to incontinence, that student would need to be permitted the extra break. The rest of the group can continue testing while this student takes a break. The teacher would need to write down the time that the student took a break and the time of return to testing.  In this way, the student can be permitted to have that time back when the others are finished with that section of the test.

        Additional time can be permitted at the end of each test segment by allowing the other students a longer break time between tests. It is important that the quiet testing atmosphere be maintained so students who are not testing should be permitted to read silently, draw, or do some other quiet activity. It should also be noted that they should not be given extra seatwork during this time as this can result in frustration and tension between students.

        If a student requires an interpreter, this accommodation is most likely already in place, but if for some reason the student is taking a test at a location other than the classroom, arrangements will need to be made for an interpreter to be present.

        A few accommodations will require some extra work on the part of the teacher either prior to or following testing. A student can be provided with enlarged print by making copies of all needed materials prior to the testing dates. If a student needs a test in Braille, this will need to be requested ahead of time as well. If a student is permitted to write in the test booklet, the teacher will need to act as a scribe and record the answers on the appropriate answer document after the test has been completed.

        One accommodation which can be the most difficult is that some students are provided the accommodation of having test material read to them while other students in the same room must read the material to themselves.

        One possible solution to this is to compile the lists of students with disabilities within each grade level. It may be possible, in a grade level that has three or four teachers, for one teacher to test all of the students who are entitled to a reader during the test. At the same time that teacher's remaining students would be divided among the other teachers administering the test on the same grade level.

        Another possibility is to use a separate room in the building and test the students separately. Each school would have to determine what location would be suitable and who would be available to administer the test. Some possible locations would include the lunchroom, the library, or an office that is either vacant or available for a set time period each day. This option can pose difficulties itself since most schools do not have an abundance of space that is not being used.

        A third option which could be implemented is to pre-record the material that can be read to the students who are entitled to the accommodation. Several copies of the tape can be made if necessary. This would allow them to be used by multiple students at the same time and in separate classrooms. This option would allow students to remain in their own classrooms with their own teachers. Another benefit to a tape recording is that the tape can be used again each school year until the test manufacturer changes the test.

        Another challenge to this systems change that inevitably will come up is that of other students complaining that it is unfair for some students to be permitted to have additional time, additional breaks, a reader, or permission to write on their test booklets. While there is no easy answer to this, it will help if the others learn throughout the school year that each student is different and has different needs. If the other students can better understand the need, they will be more tolerant of individual differences.

Follow-up Plan:

         A simple follow-up plan would be to use the same master list that was used to determine what accommodations each child was entitled to. An additional column could be completed to show what accommodations each child received and a teacher signature on the bottom. That list could then be turned in to the principal, guidance counselor, or other individual who is responsible for ensuring that these accommodations are provided.

        Another option would be to have a separate follow-up form for each student. While this involves more paperwork, it also allows for this form to be added to the student's file. This can greatly simplify the process of determining what accommodations are needed for each student the following year since the student's new teacher along with the others on the IEP team could refer to what was done the previous year.

Evaluation Plan:

        One possibility for evaluating the success of the plan would be to plot student test scores on a graph or chart. The scores from previous years when accommodations were not provided could provide a base point with the current results added on to show the results. Students normally would have an increase in grade equivalent each year simply due to the fact that they are older and learning more. It would be important to note the average amount of increase a student had shown in previous years compared to the amount of increase shown during the current school year when accommodations were provided.

Legal Implications:
 

PL 94-142 Education of All Handicapped Children Act (1975).  This law mandated that children with disabilities be educated in the least restricted environment.

Section 504 of the Rehabilitation Act of 1973.  This act provides rights for students with a disability and includes those students who need assistance but are not otherwise eligible for special education services.

The Americans with Disabilities Act of 1990.  This act prohibits discrimination against any persons with disabilities.

The State Board of Education Rule 6A.6.0312, FAC, Course Modifications, and Rule A-10943,FAC, Modifications of State Student Assessment Test Instruments and Procedures for Exceptional Students and Other Eligible Handicapped Students.  Both Rules specify allowable accommodations and modifications for students with disabilities (See Appendix A).

        In addition, the following case studies and research reports relate to providing students with disabilities appropriate accommodations.  These cases appear to indicate that the courts do not expect a state to provide a substantial accommodation on a statewide test, which would alter the testing intent.  It should be remembered that different opinions can come out of court cases depending on the jurisdiction.  Findings include the following:

Austin (Texas) Independent School District, 25 IDELR 253 (OCR, 1996). Neither Section 504 of the Rehabilitation Act nor the Americans with Disabilities Act (ADA) obligates a district to allow a student with a learning disability and attention deficit disorder (ADD) the use of a calculator when taking a standardized, statewide test when the student's EEP team did not include such a need in his list of necessary accommodations.

Alabama Department of Education, Case No. 04-90-1226 (OCR, 1990). The Office of Civil Rights upheld a state's refusal to permit a student with a learning disability to use a calculator on a math section of its statewide graduation exam. The test was designed to measure a student's ability to add, subtract, multiply, and divide. Use of a calculator would invalidate the purpose of the test. Section 504 does not require the modification of test content in order for the student to be included in testing.

Nevada State Department of Education, 25 IDELR 752 (OCR, 1996). OCR upheld the state's decision to refuse use of a calculator on the math section of its statewide proficiency exam with reasons similar to those applied in the Alabama case. Other accommodations (e.g., extended time, multiple chances to pass the exam) were made available.

Brookhart v. Illinois State Board of Education, 697 R2d 179, 184 {8 Ed. Law Rep. [608]} (7th Cir 1983). "Denial of diplomas to handicapped children who have been receiving the special education and related services required by the Act, but are unable to achieve the educational level necessary to pass the [test] is not a denial of a 'free appropriate public education.'" Since the graduation test was not the sole criterion for graduation, the student's rights were not violated.

Hawaii State Department of Education, 17 EHLR 360,361 (October, 1990). OCR ruled in favor of a parent of a student with learning disabilities who had requested a reader for non-reading portions of the state- mandated graduation test. State policy indicated that readers were provided for certified blind students and only on the non-reading portions of the test. OCR's finding indicates the importance of making modification decisions for students on a case-by-case basis and supports the use of a reader for non-readingof a test.

        These opinions indicate that courts support the notion that students cannot be denied accommodations based on a disability, but that states may deny a diploma to students who cannot demonstrate the educational level necessary to pass a state assessment. The Standards for Educational and Psychological Testing recommend caution in interpreting test scores when a test is given under nonstandard testing conditions. These legal cases are a reminder that any testing situation must begin with the investigation of the purpose of the test and the appropriateness of the test format and process for each individual student.