PACE — When is an Assessment Not a Test? Answer: NEVER

The New Hampshire Department of Education boasts about the new, experimental assessment program they are developing. It is called the Performance Assessment of Competency Education (PACE). On the surface, PACE sounds good. It attempts to replace a single high-stakes assessment (the Common-Core aligned Smarter Balanced Assessment); claims to reduce testing; and gives the perception that it is locally controlled. Unfortunately, upon closer examination, the promises do not hold true.

More Testing

The NH Department of Education describes PACE as an “integrated program,” meaning that the statewide assessment is part of the regular classroom experience including projects, tests, and day-to-day homework. How is this less testing? While it may not be bubble-sheets or a single ‘this is a majority of your grade” test, the PACE program has incremental tests occurring throughout each school term. Instead of several days dedicated to testing, students are evaluated at least weekly with some kind of assessment or test, all counting toward the statewide accountability program.

According to parents in the original PACE pilot districts, the experimental program includes weekly assessments/tests which means approximately 30 tests every academic year in K-12, not just grades 3-8 and 11. Students are given multiple opportunities to retake the assessments/tests until they pass while proficient students do “busy work.”  For example, the following Facebook post was made on March 23, 2015 by a parent whose child is in one of the PACE programs. The parent’s last name below is removed to protect her identity. This is consistent with what other PACE district parents are sharing about their children’s experiences.

PACE assessment NH parent 032415

Additionally, PACE functionally removes the ability for parents to refuse their child’s participation in the latest statewide assessment/test because it is interwoven in the “classroom experience”. The fact is this: a parent cannot refuse the unit capstone project or exam without risking his or her child’s scores. To do so would seriously jeopardize the student’s academic performance and advancement. The NH Department of Education knows this and uses it like a club that it holds over the child’s head.

Single Statewide Assessment/Test

Standardized tests are often criticized as providing a single “snapshot” of student performance, an artificial one that is not tied to their classroom learning. That is a reasonable argument against high-stakes testing and one reason New Hampshire is attempting to move away from the Smarter Balanced Assessment. However, existing state statute, RSA 193-C:6, requires a single statewide assessment/test at each grade level that is tested. The tests currently in use are the Smarter Balanced Assessment for grades 3 through 8, with the option to use the SAT in grade 11 (per HB 323, effective September 11, 2015). The law requires the use of the same assessment/test statewide and is the reason the NH Department of Education cites to deny districts the option to use other standardized exams.

So why is it that the NH DOE is allowing districts to use PACE instead? Why are they encouraging districts to break state law? PACE districts are not following the requirements of RSA 193-C:6.

This is hypocritical and potentially illegal. The NH DOE is allowing eight districts (as of the 2015-2016 school year) to bypass the state required assessments/tests in favor of their alternative, yet they refuse to allow other districts to select one independently even if it is one that has been in use for decades and is nationally standardized achievement test.

PACE is an experimental program currently in its second year. In 2014-2015 school year it was piloted in four districts — Epping, Rochester, Sanborn Regional, and Souhegan.  It will be expanded to eight districts this school year. For now the use of PACE is optional for school districts; however, the NH DOE intends to make PACE mandatory in all districts across the state. The NH DOE’s goal to require PACE in all grades Kindergarten through grade 12 is specifically mentioned in the March 5, 2015 letter from the US DOE.

The four LEAs will administer the NHDOE State assessments in reading/language arts and mathematics once each in elementary, middle, and high school and will administer PACE in every grade (K-12). NHDOE may increase the number of pilot LEAs to eight in year 2 of the pilot, subject to the relevant conditions below.”

The letter also states, “Finally, this waiver is also granted based on NHDOE’s intent to move to a single Statewide system in which all local educational agencies (LEAs) are administering the same assessment system to all students in each grade…”

Lack of Local Control

The NH Department of Education claims that PACE is “locally designed” with input from “stakeholders” including teachers, superintendents, and parents. At best, this is an exaggeration; at worst, it is an outright falsehood. School boards did not vote to participate in the PACE program. In Rochester, for example, the SAU superintendent alone made the determination that the district would apply to the experimental program; it was never brought to the school board as a body or the public for comment or a vote. The switch to PACE was simply steamrolled into the district without any approval process.

Also, the NH DOE only allowed public input for four short days via an online survey service. There was no widespread notice about the survey; it appears to have been buried on the state DOE’s accountability website. Consequently it is no surprise that the broader public had no knowledge of this survey. Roughly 55 people completed the survey with the vast majority being NH DOE staff, administrators, and classroom teachers. That does not represent a reasonable sample of “stakeholders.”

This is not local control; it is authoritarianism.

Requires Common Core Standards

Because PACE is an integrated program built around College and Career Readiness Standards (aka Common Core), is also engrains these controversial standards into the classroom even more. The DOE has always claimed that the statewide assessment/test was the only Common Core requirement for NH public schools. PACE changes that; it makes Common Core central to the very nature of the classroom experience and it further embeds Common Core into our schools.

Accountability Turned Upside-down

Meaningful and relevant tests are a critical component in learning. They are a key feedback tool to determine how effectively students are absorbing the educational material and objectives. However, PACE makes students’ regular classroom work and evaluations the accountability mechanism to the state and federal governments. Think about that. This completely turns accountability on its head and puts it squarely on the child. It is inappropriate for unit projects and exams to be reported to state or federal agencies.

What does PACE look like in the classroom? In Governor Hassan’s announcement dated March 5, 2015, she provided the following: “For example, in English, middle school students might submit research papers showing that they know how to analyze and present information from many sources. In math, fourth-graders might design and cost out a new park and write a letter to their board of selectmen arguing their perspective based on their calculations and other evidence.

While these might be dynamic cross-curricular team projects, how do they show an individual student’s mastery of specific academic knowledge? To use the playground example above, would that project show that Ashley knows multi-digit multiplication and the relationship between fractions and decimals? Is Ashley’s math competency score based on her mathematics skill or her ability to write about it? What if Dillon has to do a small skit in front of the whole class, but is a little bashful. Will Dillon’s competency in English reflect his mastery of the subject or his ability to perform? Now Taylor’s grade on a team project becomes the tool the district uses to report to the state and federal Departments of Education.

Effect on Chartered Public Schools

This shift to “competency-based” education (CBE) will undoubtedly impact charter schools, too. Because CBE and PACE are integrated into the classroom instruction, charters will no longer be able to use other standards or educational approaches in their schools. This effectively reduces educational options for students who do not fit the cookie-cutter mold of Common Core or have the financial means to afford private school tuition.


Currently PACE is the only alternative to the Smarter Balanced Assessment that the state DOE is accepting or developing for the statewide assessment/test in grades three through eight. This is why several concerned citizens, parents, and advocates worked so hard in the negotiations on House Bill 323 (2015). This bill was centered on the NCLB/ESEA waiver that the state wanted in order to be released from some federal requirements. Every amendment offered by our opponents provided either direct or indirect references to PACE as the only alternative to the Smarter Balanced Assessment. Our efforts to allow locally-adopted standards and other academic assessments/tests were not accepted in the negotiations.

While we encourage ending the use of the Smarter Balanced Assessment as the statewide assessment/test, we believe districts should not be forced to implement another experimental program, especially one that is integrated into the everyday classroom experience. There are many proven academic standards that districts could consider and well-established standardized exams that could serve as alternatives. Districts should be given more flexibility, not limitations, to determine how to best meet the needs of and be accountable to their residents. Common Core should not be further forced into all our schools against the wishes of local districts. Children are not accountable to the state or federal government nor should their class work be used for that purpose. Additionally, the NH Department of Education is not above the law and as an agency of the executive branch, must also follow state statutes.

For  more information about PACE, read Things Come Apart So Easily and PACE: the Next Educational Reform from the NH DOE.

For information about how to refuse the statewide assessment, read Starting the Year Right.