UDL+Task+Force

> To Whom It May Concern: > > The National UDL Task Force is a Washington, DC-based coalition comprised of  [|more than 40 organizations] . The UDL Task Force advocates support for Universal Design for Learning (UDL) in federal, state and district education policy. (For more information about the UDL Task Force, please go to  [] .) > > The Task Force thanks you for this opportunity to comment on the Draft Policies on Reading Access Accommodations & Calculator Accommodations for Students with Disabilities  that your Consortium recently put out for public feedback. > The members of our Task Force have been optimistic that the development of the Common Core assessments held the promise of incorporating the principles of UDL into the assessments from the beginning so that there would be no need to ‘retrofit’ the assessments using these principles, or worse, ignoring them completely. > > When the Race to the Top (RTTT) Assessment applications were announced, all applicants were asked to describe how they would use the principles of universal design for learning (UDL). In the application that won them the grant, PARCC made a commitment to universally design its assessment at every stage. The primary focus of UDL, as it applies to assessments, is to eliminate all construct irrelevant barriers to access so students can demonstrate skills and knowledge. PARCC’s RTTT Assessment application included examples for building multiple, flexible supports into each item and task, provided the construct validity is maintained. > > The National UDL Task Force therefore recommends that PARRC be clear and concise as to how it is embedding the principles of UDL in its assessments so that ALL students will be able to demonstrate their knowledge. > > Second, the bottom line is that, as an assessment developer, it is NOT PARCC’s responsibility, nor it is your area of expertise, to restrict who is eligible to use an accommodation. Rather, it is PARCC’s responsibility to individually review each test item and to show with undisputed evidence <span class="s5" style="background-color: rgba(255,255,255,0);"> that use of a particular accommodation(s) will fundamentally alter the test construct. Under the Individuals with Disabilities Education Act (IDEA), the responsibility to articulate which students might be eligible for a specific accommodation is delegated to the Individualized Education Program (IEP)team. Decisions by the IEP team on assessment accommodations are typically based on the type of accommodations that a student is receiving for instruction, as long as they will not invalidate the assessment score. These decisions, again by law, are based on the <span class="s11" style="background-color: rgba(255,255,255,0);">specific needs of the individual student <span class="s5" style="background-color: rgba(255,255,255,0);">. Having no knowledge of an individual student, It is not possible for PARRC to second-guess the decision of the IEP team, even if it werepermissible under the IDEA. The National <span style="background-color: rgba(255,255,255,0);"> <span class="s5" style="background-color: rgba(255,255,255,0);">UDL Task Force therefore recommends that PARCC strike the entire Proposed Eligibility Requirements for both the reading access and calculator accommodations and revise its accommodations policy to adhere to Section 504 and IDEA > > <span class="s5" style="background-color: rgba(255,255,255,0);">Finally, the PARRC draft policy does not address the needs of students on Section 504 plans. Like an IEP, a 504 plan is based on the individual needs of a student with a disability and the plan may articulate specific accommodations for both classroom instruction and assessment. Because the principles of UDL apply to all students, we hope that the PARRC’s policies would make specific mention of these students and would acknowledge that some students on 504 plans may need the type of read-aloud and calculator accommodations that the PARRC is considering > > <span class="s5" style="background-color: rgba(255,255,255,0);">The UDL Task Force Co-Chairs