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CAST’s Response to U.S. Department of Education Guidance on Title I Peer Review Process

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CAST recommends ways to improve the draft of the US Department of Education’s guidance on Title I assessment peer review process.

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CAST (2013). CAST’s response to U.S. Department of Education guidance on assessment: Title I peer review. Policy Statement. Wakefield, MA: Author.

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September 23, 2013

U.S. Department of Education
ESEA Assessment
400 Maryland Avenue, SW
Washington, DC 20202

To Whom It May Concern:

CAST appreciates the opportunity to comment on ED’s Title I assessment peer review process. CAST is an organization that works to expand learning opportunities and outcomes for all individuals through Universal Design for Learning (UDL). CAST defined the principles and practices of UDL, which were incorporated into the Higher Education Opportunity Act (HEOA) of 2008. When applying the principles of UDL, we believe that instruction represents the entire episode of learning—i.e., the entire assessment-instructional cycle.

CAST is known for its development of innovative, technology-based educational resources and strategies based on the principles of UDL. For example, CAST created Bobby, the first software to check website accessibility; WiggleWorks (with Scholastic), the first universally designed literacy program; and CAST eReader, one of the first computer-based literacy tools. Additionally, CAST held an instrumental role in the development of the National Instructional Materials Accessibility Standard (NIMAS) and currently leads the National Accessible Instructional Materials (AIM) Center. CAST has also partnered with the University of Kansas and NASDSE in the Center on Online Learning and Students with Disabilities and serves as the lead partner (with Vanderbilt University) in the National Center on the Use of Emerging Technologies to Improve Literacy Achievement for Students with Disabilities in Middle School.

Through strategic collaborations, CAST continues to work on behalf of all learners by seeding the fields of education research, policy, professional development, and product development with UDL-based solutions. Based on CAST’s extensive experience, we offer the following comments to ED regarding the Title I assessment peer review process:

(1) ED should ensure that states are not focusing exclusively on summative assessment but also emphasize formative assessment as part of the entire assessment-instructional cycle.

(2) ED should ensure that monitoring activities consider the potential effects of assessment on classroom instruction.

(3) ED should closely monitor the impact of computer adaptive testing (CAT) on all subgroups, including students with disabilities and English Language Learners.

(4) ED should ensure that state assessment systems are valid, reliable, and fair for all students, including students with disabilities and English Language Learners.

(5) ED should ensure that states maintain high expectations, while allowing for the appropriate use of accommodations and supports, in order to provide optimal accessibility throughout the assessment.


Tracey E. Hall, PhD, Senior Research Scientist
Chuck Hitchcock, MEd, Chief of Policy and Technology
Richard Jackson, EdD, Senior Research Scientist
Joanne Karger, JD, EdD, Research Scientist/Policy Analyst
David H. Rose, EdD, Chief Education Officer and Founder
Skip Stahl, MS, Senior Policy Analyst
Joy Zabala, EdD, Director of Technical Assistance, CAST and AIM Center


Almond, P., Winter, P., Cameto, R., Russell, M., Sato, E., Clarke-Midura, J., ... Lazarus, S. (2010). Technology-enabled and universally designed assessment: Considering access in measuring the achievement of students with disabilities—A foundation for research. Journal of Technology, Learning, and Assessment,10(5). Retrieved from

Folk, V. G. & Smith, R. G., (2002) "Models for delivery of CBTs." Computer-based testing: Building the foundation for future assessments (pp. 41-66).

Kingsbury, G. G. & Houser, R. L. (2007). ICAT: An adaptive testing procedure to allow the identification of idiosyncratic knowledge patterns. In D. J. Weiss (Ed.). Proceedings of the 2007 GMAC Conference on Computerized Adaptive Testing. Retrieved from

Laitusis, C. C., Buzick, H. M., Cook, L., & Stone, E. (2011). Adaptive Testing Options for Accountability Assessments. In M. Russell & M. Kavanaugh (Eds.), Assessing Students in the Margins: Challenges, Strategies, and Techniques. Charlotte, NC: Information Age Publishing.

Papanastasiou, E. C. & Reckase, M. D. (2007). A "rearrangement procedure" for scoring adaptive tests with review options. International Journal of Testing, 7(4), 387-407.

Thurlow, M., Lazarus, S. S., Albus, D., & Hodgson, J. (2010). Computer-based testing: Practices and considerations (Synthesis Report 78). Minneapolis, MN: University of Minnesota, National Center on Educational Outcomes.

U.S. Department of Education. (2007). Standards and assessments peer review guidance: Information and examples for meeting requirements of the No Child Left Behind Act of 2001. Washington, DC: Author. Retrieved from

Way, W. D. (2006). Practical questions in introducing computerized adaptive testing for K–12 assessment. PEM Research Reports. Iowa City, IA: Pearson Educational Measurement. Retrieved from

Yen, Y. C., Ho, R. G., Liao, W. W., & Chen, L. J. (2012). Reducing the Impact of Inappropriate Items on Reviewable Computerized Adaptive Testing. Educational Technology & Society 15(2), 231-243.

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