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As states continue to debate their participation in the two large testing consortia associated with the common-core standards, those with are getting a reminder from the U.S. Department of Education that dropping out requires an official Plan B.

So far, federal officials are reviewing the testing plans of four waiver states that have announced they are not participating in either the Smarter Balanced Assessment Consortium or the Partnership for Assessment of Readiness for College and Career (PARCC) tests: Kansas, Georgia, Utah, and Oklahoma.

Alabama and Pennsylvania have also announced they won鈥檛 be using the common tests, but their approved waiver applications already included alternative-assessment plans.

To be sure, participating in a testing consortium is not a requirement for a waiver, and neither is adopting the common standards in the first place. For example, Virginia hasn鈥檛 adopted the common core (and by extension the tests either), yet the state has a waiver. But doing both is the most direct, and perhaps easiest, way to satisfy federal requirements that standards be college- and career-ready, and that tests be aligned with them.

Starting in September, Education Department officials began sending letters to the four states asking them to submit alternative plans since each of them had said they would use the common tests. Among other things, states are being asked their timeline for developing test questions, how they plan to make sure the questions are valid and aligned with a state鈥檚 standards, and what the state鈥檚 plans are for communicating the results to parents.

鈥淯nder [waiver] flexibility, states committed to develop and administer high-quality assessments aligned with college-and career-ready standards by 2014-15,鈥� said Dorie Nolt, a spokeswoman for the U.S. Department of Education. 鈥淭he department reviews state plans for developing and implementing high-quality assessments, but does not review the assessments themselves.鈥�

Fallback Plans

Utah is a common-core state, but dropped out of Smarter Balanced in 2012, in part to try to assuage critics who were railing against the state鈥檚 adoption of the common standards. Utah then signed a $39 million contract with the Washington-based American Institutes for Research to develop its own test. (AIR is also working with Smarter Balanced.)

Mark Peterson, a spokesman for the Utah Department of Education, said that, even as his state awaits official approval from federal officials, students will take the new, computer-adaptive tests starting this spring in grades 3-12.

For now, states only have to satisfy Education Department officials with their testing plans. But that鈥檚 changing.

Federal officials are revamping the longstanding peer-review process for state assessment systems, and, as soon as that work is complete, outside reviewers will be judging state testing systems, whether they are individual systems or multistate consortia tests.

The goal, federal officials say, is not to approve the tests themselves, but to make sure they align with promises made in waiver applications, and with a state鈥檚 standards. What鈥檚 more, peer review of assessment systems is not new to NCLB waivers, but has been a requirement for nearly two decades under the Elementary and Secondary Education Act.

In other words, all states鈥攁nd not just waiver states鈥攚ill eventually have to have their testing systems peer reviewed again.

Tight Timetable

For Georgia and Oklahoma, which dropped out of PARCC in mid-2013, and Kansas, which dropped out of Smarter Balanced in December, the timetable to get new tests ready for 2014-15 is a tight one.

Last week, Kansas was planning to submit its plan to federal officials,which includes a new contract with the University of Kansas Center for Educational Testing and Evaluation to develop the state鈥檚 new assessment. It will debut in 2014-15 and be tweaked each subsequent year to make sure it鈥檚 aligned with the common core.

In December, Oklahoma submitted its revised plan for testing after dropping out of PARCC five months earlier. At the time, state officials were greatly concerned that the computer-only PARCC tests, which were also longer than Oklahoma鈥檚 current state tests, would be too technologically advanced for many of the state鈥檚 districts.

State education department spokeswoman Tricia Pemberton said Oklahoma is still waiting on word from federal officials, but is forging ahead with its plans to adapt end-of-course tests in high school to the common core. The state in December signed a new, $35 million contract with Measured Progress, a New Hampshire-based test developer, to create common-core-aligned tests for grades 3-8. Those will be piloted this spring, and will officially debut next school year.

Georgia dropped out of PARCC in July, with Gov. Nathan Deal and state schools鈥� chief John D. Barge saying they wanted more autonomy over tests. In addition, Mr. Barge was concerned that not all schools would have the technology to administer PARCC鈥檚 computer-adaptive tests. The state鈥檚 new test will be available in both paper-and-pencil and computer formats, and will debut no later than 2014-15. It will be a completely new test, with more open-ended questions, and require a significant increase in funding, state officials say.

The tests will contain 鈥渘orm-referenced鈥� items that allow the performance of students in Georgia to be compared with students around the country. Spokesman Matt Cardoza said the only feedback the state has gotten so far from federal officials is that its plan is 鈥渦nder review.鈥�