Letter: SBAC would be bad for Iowa’s students

SBAC LogoBy Heather Stancil


The Iowa Dept. of Education is recommending, and the Senate and House Education Committees are considering, that Iowa move away from a locally developed Iowa assessment to one that was both federally funded and created, and will be based at UCLA: the Smarter Balanced Assessment Consortium. So instead of having the oversight of the Iowa Board of Regents, the legislators are considering ceding the oversight of Iowa students and Iowa school districts to the California Board of Regents. They are listening to the claims of a slick saleswoman from a company that was created solely from federal funding, which has only been in existence since 2011, and whose test is barely off the ground. And, by the way, this test is 500% more expensive than the current assessment & will double the current test time for our children – 7-9 hours (that is longer than both the MCATs & the LSATS)

Iowa and its ITBS used to be the gold-standard used by states nationwide. How will Iowa ever regain our top in the nation status if we do this?

I sent the following concerns & attachments below to every member of both the Senate and House education committees. Its not just a local control or cost thing either, as some of the remaining issues and unanswered questions are quite disturbing.


Honorable Representatives/Senators:

I know that you will be making a decision soon regarding whether or not to move forward with the Iowa Department of Education’s recommendation to use the Smarter Balanced Assessment from the Consortium based in California.

I am asking you to NOT choose this test for the following reasons:

Lack of Local Control:

  1. It removes oversight of our state test from the Iowa Board of Regents and replaces it with the California Board of Regents
  2. Iowa will not have the final say over the content of this test, membership rules and cost, or Consortium governance. We are merely one voice of many members
  3. The IADOE is recommending the full suite of services, which include professional development and curriculum, none of which Iowa or local districts had a hand in developing or will be able to control
  4. The full suite recommendation will force local school districts to either do away with locally controlled interim assessments or pay even more
  5. Iowa teachers and schools will be evaluated via a test over which Iowans had little influence

Known cost is high, unknown cost even higher:

  1. This test will increase annual assessment costs to districts by at least 500%
  2. Science is not included, so another test at additional cost will be required
  3. The SBAC does not assess those parts of Iowa Core that are not aligned with Common Core, so another test will be required to measure those
  4. Schools are not ready either from a bandwidth or technology perspective for this online test, so there will be additional millions in taxpayer money required to make the necessary upgrades
  5. Membership dues can increase, especially if more states pull out of the Consortium

Student Data mining cannot be controlled by Iowa:

  1. The test itself gathers student level data, to which both the SBAC and the state of Iowa have access. While the state of Iowa can control with whom they share their data, they cannot control with whom the SBAC shares theirs, as they are a private entity
  2. The terms of the USDOE grant required that student level data be held by the SBAC and be available to both the USDOE and others for research purposes. Iowa cannot override the terms agreed to under this federal grant.
  3. The SBAC has signed MOUs with both the USDOE and others regarding the sharing of student data. We do not yet know these terms, but if we decide to use this test, we then become a governing member and must abide by these third party terms
  4. Per the SBAC governance documents, the kind of student level data gathered is determined by its Technical Advisory Committee. Membership on this committee is appointed and there is no requirement that it be made up of just state membership – there is no guarantee that Iowa will have a voice other than a single vote on them later on

This test has never been validated for efficacy, content or Iowa Core alignment:

  1. The SBAC’s own Use of Scores document admits that this test should not be used as a measurement of student success without more research being done (p.1)
  2. Neither the test, nor its chosen cut scores, has been researched or validated using industry approved methods; it has only been piloted in order to set these arbitrary cut scores, which by the way, are expected to drastically increase the number of Iowa children marked as non-proficient

Other unanswered questions:

  1. Why is the Department of Defense a member of the Consortium and what level of influence or access do they have?
  2. Per the SBAC governance documents, why are psychometrics (psychological measurement) included as one of the student level data points on this test (p.13)? What kind of questions are these?
  3. To what extent will this test be used to evaluate teachers and schools, given both the SBAC grant (p.2) and SBAC governance documents (p. 3) state that was one of its specific design requirements?  
  4. What contracts/agreements/MOUs signed by the SBAC will Iowa have to abide by as a governing member? Can the public review these?
  5. What happens to the cost or comparative data for Iowa if more membership states pull out or more students refuse the test nationwide?
  6. Has an independent, non-Gates Foundation funded, technology and telecommunications expert from Iowa evaluated both the SBAC test technical requirements as well as Iowa school district readiness to validate the salesmen’s claims and avoid a conflict of interest?
  7. What level of public transparency will there be regarding meetings, documents, etc. for the SBAC, given this is a private entity based in California, and not subject to public FOIA requests or Iowa law?
  8. Who in Iowa will be able to review all the test questions for bias, content, age appropriateness, and standard alignment? How will we ensure that questions we do not like are deleted or changed on the test? How will this review be funded?
  9. Who in Iowa will be able to ensure that the test will not be adapted on the back end to either make it harder or easier in order to influence cut scores? How will this oversight be funded?
  10. How will this test fairly measure or compare students on IEPs? 
  11. What impact will a 7-9 hour test have on students and teachers, in terms of anxiety, test prep and instructional time? (Compare that to the test time of either the MCATs & LSATS, which is only 5 hours max)


The issues above only scratch the surface. It is my belief that there are still many more unanswered questions regarding the SBAC that need to be addressed before we can reasonably choose this test as the best one for Iowa. Considering the growing number of states that are considering pulling out, the number of students nationwide walking out, the number of parents nationwide opting out, as well as a court injunction against them in Missouri prohibiting that state’s membership, I think we need to take a step back and do a much more in depth review of this company before we commit either our money or our students to this assessment.

I am attaching copies of the SBAC governance document, the SBAC grant, and the SBAC Use of Cut Scores document for your further review.

Also, as a side note, on a SBAC commissioned white paper, even they don’t seem to entirely believe in the efficacy of their adaptive test to measure growth better than a fixed test like the Iowa Assessment (see here, p. 15, paragraph 3). I have tried to get answers from the SBAC too, and have followed up several times. Other than asking if I was a reporter (I am not) & what I will be using the info I requested for, I have had no response. It has been almost 3 weeks.