High - quality assessments generate rich data and can provide valuable information about student progress to teachers and parents, support accountability, promote high expectations, and
encourage equity for students of color and low - income students.
While we appreciate CDE's proposal to disaggregate
student subgroup data in achievement (not just growth, as was the case in previous frameworks), as well as the Department's commitment to ensuring transparency of subgroup performance data in reporting, we strongly
encourage CDE to reconsider the adoption of a combined subgroup
for accountability purposes, which would have significant implications
for educational
equity.