This paper was submitted to the United States Department of Education (ED) in September 2016 as comments on the proposed ESSA federal regulations (§200.77) for the section 1204 Innovative Assessment Demonstration Authority. This document focuses on the federal requirements for establishing comparability between the statewide assessment system and the innovative assessment system. We provide a conceptualization of comparability and a framework for designing options to evaluate comparability that considers the types of measures (items) and student samples used. Additionally, we offer more than a dozen potential approaches for evaluating comparability beyond the three proposed by ED in §200.77.
