The Texas Higher Education Coordinating Board (Coordinating Board) adopts amendments to Title 19, Part 1, Chapter 4, Subchapter C, §§4.56, 4.57, and 4.62, concerning Texas Success Initiative, without changes to the proposed text as published in the September 4, 2020 issue of the Texas Register (45 TexReg 6208) and will not be republished.

These amendments provide college readiness benchmarks for the revised assessment approved by the Board under this title and provide the final phase for implementation of corequisite models supporting underprepared students.

The amendment to §4.56 replaces the TSI Assessment, which expires in January 2021, with the TSI Assessment, Version 2.0 (TSIA2), as the Board-approved assessment instrument under this title. The amendment to §4.57 adds the college readiness benchmarks, based on faculty-driven, psychometric standard setting processes, for the TSIA2 and clarifies that results from both assessment instruments remain valid for the purposes of this title for five (5) years from date of testing. The college readiness benchmarks added to §4.56 are based on the standard setting and psychometric processes conducted by the College Board, the TSIA/TSIA2 test vendor. One of the major changes to the TSIA2 is the reduction from three subject areas of reading, writing, and mathematics to two, with the reading and writing sections being integrated to an English Language Arts Reading (ELAR) section. This change is in alignment with other assessments, including the SAT and STAAR EOCs. The ELAR college readiness benchmark is based on a student's performance in both the College Readiness Classification test (CRC) comprising computer-adaptive multiple-choice items and the WritePlacer essay. The essay cannot be used as a sole indicator of readiness. Because the new ELAR section has fewer overall multiple-choice items, the determination was made to place greater weighting on the WritePlacer essay component in order to support a reliable and valid ELAR standard. The College Board is scheduled to conduct its study after one year of implementation to confirm the reliability and validity of the college-readiness benchmarks and will make recommended modifications, if needed, as indicated by the findings.

With regard to §4.62(8)(A)(iv), statewide developmental education (DE) outcomes data continue to demonstrate that underprepared students enrolled in corequisite models consistently and significantly outperform students in traditional stand-alone DE with regard to meeting college readiness and first college-level course completions. Corequisite models allow the student to co-enroll in the entry-level college course and an intervention designed to provide just-in-time, aligned support to help ensure students' successful completion of the college-level course. It is important to note that TSI statute is applicable only to those students who enroll in developmental education, not to the general developmental education population. Statute also provided exemptions from this requirement, including students enrolled in adult education and basic academic skills education (i.e., those assessed on the TSIA/TSIA2 at levels 1-4), and gave authority to enact rules for implementation (TEC, Subsection F-1, 51.336(d)). Based in data-informed decision-making, this proposal takes into account Texas outcomes data when comparing student performance pre-fall 2018 implementation and post-implementation, which confirm that students enrolled in corequisite models consistently and significantly outperform students who are enrolled in non-corequisite models (i.e., traditional, stand-alone developmental education courses). In the first year of implementation alone, over 11,500 more students successfully completed their entry-level college courses, including over 1,800 more Black students and 5,800 more Hispanic students, when compared to the previous pre-implementation year (Source: CBM002 and CBM00S). Providing equitable access and accelerating student success are key goals that are especially important in this COVID impacted environment.

The amendment to §4.62 provides the final phase of corequisite implementation for 2021 and thereafter, ensuring eligible underprepared students are afforded the best opportunity in building momentum towards important milestones leading to certificate/degree completions and transfers.

The following comments were received regarding the adoption of the amendments.

Comment: South Texas College raised concerns about the January 11, 2021 implementation date for the Texas Success Initiative Assessment, Version 2.0 (TSIA2) being during a peak enrollment period for this institution. A request was made to postpone the TSIA2 implementation date for three weeks to February 1, 2021 to enact a workable timeline or be provided a waiver due to a number of factors including testing restrictions, additional staff time, and fiscal implications that require Governing Board approval. Concerns about extended downtimes and negative impact on dual credit students were also raised.

THECB Response: The Coordinating Board appreciate this comment. Due to COVID-19 restrictions and resulting delays in the test development process for the TSIA2, the implementation date had been delayed two prior times. The final January implementation date was provided by the test vendor based on several factors, including postsecondary enrollment periods that vary by institution, as well as contractual considerations. We understand many local processes and practices have been, and continue to be, modified because of the pandemic and its impact. To this point, THECB has provided TSI COVID waivers applicable through AY2020-21 allowing institutions to use a number of indicators not involving TSIA/TSIA2 testing, such as GPA and course-taking patterns that can be used to place both undergraduate and dual credit students with unknown TSI status. Given these alternative placement options, we do not anticipate the test launch date to be a barrier for students. Unfortunately, test platform limitations do not provide for variations with regard to the implementation date. THECB staff is available to consult with institutions to explore various options for consideration to help ensure least impact on students and institutions.

Comment: Waco Independent School District raised concern about the proposed change in the WritePlacer essay score from a 4 to a 5 (on a 1-8 scale) and requested that it be kept at 4, the benchmark for the current TSIA.

THECB Response: The THECB appreciates this comment. The proposed college readiness benchmarks added to §4.56 are based on the standard setting and psychometric processes conducted by the College Board, the TSIA/TSIA2 test vendor. One of the major changes to the TSIA2 is the reduction from three subject areas of reading, writing, and mathematics to two, with the reading and writing sections being integrated to an English Language Arts Reading (ELAR) section. This change is in alignment with other assessments, including the SAT and STAAR EOCs. The ELAR college readiness benchmark is based on a student's performance in both the College Readiness Classification test (CRC) comprising computer-adaptive multiple-choice items and the WritePlacer essay. The essay cannot be used as a sole indicator of readiness. Because the new ELAR section has fewer overall multiple-choice items, the determination was made to place greater weighting on the WritePlacer essay component in order to support a reliable and valid ELAR standard. The College Board is scheduled to conduct its study after one year of implementation to confirm the reliability and validity of the college-readiness benchmarks and will make recommended modifications, if needed, as indicated by the findings. Furthermore, THECB has provided TSI COVID waivers applicable for both undergraduate and high school students through AY2020-21 allowing institutions to use a number of indicators that do not include, or can complement, TSIA testing that can be used to place students interested in qualifying for dual credit. It should also be noted that TSI applies only to those courses designated by the offering institution as ELAR- or math-intensive; non-designated core curriculum courses are not subject to TSI.

Comment: One comment received from the Texas Federation of Teachers/AFL-CIO, one comment from South Plains College, and one joint comment from Victoria College raised concerns about the proposal to increase from 75% to 100% "all developmental education students to be enrolled in a corequisite course" and that a "one-size-fits-all" approach will negatively impact students.

THECB Response: While the THECB appreciates this comment, the concern raised that all developmental education students be enrolled in a corequisite course is not accurately citing TSI statute. Effective fall 2018, TSI statute (Texas Education Code, Subsection F-1, 51.336(c)) requires that at least 75% of students not in adult education and basic academic skills education (i.e., those assessed on the TSIA at levels 5 and 6 on a scale of 1-6) and enrolled in developmental education be placed in corequisite models. Authority to implement rules to address this statutory requirement is provided in 51.344(b)(d).

Such models allow the student to co-enroll in the entry-level college course and an intervention designed to provide just-in-time, aligned support to help ensure students' successful completion of the college-level course. It is important to note that TSI statute is applicable only to those students who enroll in developmental education, not to the general developmental education population. Statute also provided exemptions from this requirement, including students enrolled in adult education and basic academic skills education (i.e., those assessed on the TSIA/TSIA2 at levels 1-4), and gave authority to enact rules for implementation (TEC, Subsection F-1, 51.336(d)). Based in data-informed decision-making, this proposal takes into account Texas outcomes data when comparing student performance pre-fall 2018 implementation and post-implementation, which confirm that students enrolled in corequisite models consistently and significantly outperform students who are enrolled in non-corequisite models (i.e., traditional, stand-alone developmental education courses). In the first year of implementation alone, over 11,500 more students successfully completed their entry-level college courses, including over 1,800 more Black students and 5,800 more Hispanic students, when compared to the previous pre-implementation year (Source: CBM002 and CBM00S). Providing equitable access and accelerating student success are key goals that are especially important in this COVID impacted environment.

The THECB clarified in 2018 that it does interpret the Education Code to require students who are not required to take college-level mathematics as part of their degree plan, to be TSI complete. THECB's understanding and application of the Code is that while non-exempt students are still required to be assessed in order to provide them with information regarding their knowledge and skills levels, they do not need to be TSI complete in order to enroll in or graduate from such programs.

The concern that placing students in corequisite models results in a "one-size-fits-all" approach may be reflective of a misunderstanding with how corequisite models are implemented in Texas. Each institution has autonomy to select from a wide range of instructional and delivery options to individualize each student's intervention and may include in this decision additional factors selected by the institution, such as student's high school GPA, course-taking patterns, and non-cognitive factors (e.g., career goals, job, childcare, transportation, etc.). Intervention options include a range from 4 to 96 hours; single or shared instruction; hybrid, online, or in-person delivery; modular/Emporium and/or computer labs; supplemental instruction; structured/open lab tutoring or course, among many others. Since 2011, THECB has provided comprehensive, statewide professional development and grant-funding opportunities to support institutions in research based and data-driven best practices related to the development, implementation, evaluation, enhancement, and scaling of their corequisite options.

Comment: In response to the proposed amendments to Texas Administrative Code (TAC), Title 19, Part 1, Chapter 4, Subchapter C, Sections 4.56, 4.57, and 4.62, the Texas Association of Community Colleges (TACC) commented that "advancing the proposed TSIA2 policy changes should only be done based on transparently shared information and evidence that the changes will improve equitable access and outcomes for students."

THECB Response: The proposed amendments provide the college readiness benchmarks based on Item Review and Standard Setting processes driven by faculty content-expert input, as outlined in the publicly-posted RFA for the Texas Success Initiative Assessment, version 2.0 (TSIA2) test vendor, and closely aligned with the Texas Success Initiative Assessment (TSIA) test development process described in the TSIA technical manual. Dr. Luz Bay, lead psychometrician at the College Board, will provide additional information on these processes at the THECB Committee on Academic and Workforce Success (CAWS) meeting on October 21, 2020. As with the implementation of the TSIA and in alignment with test implementation standard practices, the College Board will be conducting a study to verify validity and reliability of benchmarks based on authentic test data after one year of implementation and will proposed changes, if any, based on findings. Benchmarks related to TSIA are not changed and test results remain valid up to five years from date of testing, as do those for TSIA2.

The proposed amendments do include a policy change related to corequisite implementation. Data regarding the impact of corequisite implementation and how it has improved equitable access and outcomes for students has been shared in a number of meetings, presentations, and webinars hosted by the Texas Higher Education Coordinating Board (THECB) since 2019. Student placements into college-level courses with or without support that were informed through the TSIA and other multiple measures factors, including TSI waivers in place through AY 2020-21, coupled with the scaling of corequisite model course enrollments (HB2223), have yielded positive results for both African American and Hispanic students statewide. When comparing corequisite course outcomes in fall 2019 (phase II, HB2223 implementation) to fall 2017 (pre-HB2223 implementation), there were 19,560 more first college-level course completions statewide. This number is nearly double the number of first college-level course completions in fall 2018, the first year of HB2223 implementation, although the percentage of required corequisite enrollments increased by only 25%. Of those 19,560 completions, 14,115, or 72 percent, were completions by African American or Hispanic students who completed their first college-level reading and/or writing or mathematics course in one semester. Furthermore, the newly proposed TSIA2 second-chance benchmark for mathematics will provide students with an additional opportunity to demonstrate college readiness based on diagnostic test performance. When considering developmental education reform efforts underway in Texas since 2012, no impact has been greater in a shorter time period than that resulting from these targeted interventions.

Below is the THECB response to summary statements included in joint comments received from The Charles Dana Center, E3 Alliance, and TACC regarding the proposed amendments to TAC, Title 19, Part 1, Chapter 4, Subchapter C, Sections 4.56, 4.57, and 4.62. The complete comments are provided as an addendum to this document.

Comment: The Charles Dana Center, E3 Alliance, and the TACC submitted joint comments. Among other comments, the group asserted that the THECB should not adopt new rules until the THECB and the College Board provide evidence that the TSIA2 will result in more equitable outcomes for students than a multiple measures approach.

THECB Response: The THECB appreciates this comment; however, the THECB disagrees. The proposed rules provide the college readiness benchmarks for the revised TSIA2 and continue the support of co-requisite. The proposed rules have no impact on use of multiple measures (i.e., holistic placement), as provided in TAC, Rule 4.55(c), and use of such measures by institutions when making placement decisions is not impacted by the proposed amendments. Furthermore, Texas Success Initiative (TSI) waivers enabling use of multiple measures assessment (MMA) for determining placements for students whose TSI status is unknown remain effective through AY 2020-21. The THECB is open to extending these waivers through AY 2021-22.

Comment: The Charles Dana Center, E3 Alliance, and TACC submitted joint comments. Among other comments, the group asserted that the THECB should not adopt new rules until the THECB and the College Board demonstrate that the TSIA2 will result in more accurate and reliable course placement for students than a multiple measures approach.

THECB Response: The THECB appreciates this comment. As part of the TSIA2 RFA development process, THECB contracted with a third-party expert consultant group to help ensure the processes outlined in the RFA met or exceeded the industry standard for computer-adaptive test development and implementation. Spearheaded by the competitively-selected TSIA/TSIA2 test vendor, the College Board, and as outlined in its application in response to the RFA and the publicly-posted RFA (781-9-21432), the development of the TSIA2 includes alignment to the most updated and revised standards (CCRS, TEKS, Adult Education, NRS EFLDs). The Item Review process, described in the application and the RFA and conducted in February 2020, requires TSIA2 items to be in alignment with current standards and college readiness expectations of secondary and post-secondary faculty, a process also used for the establishment and revision of the College and Career Readiness Standards (Texas Education Code, Section 28.008). This development process makes the TSIA2 more likely than the current TSIA to provide the most appropriate information to institutions as they make their placement decisions. In addition, the Standard Setting process and psychometric and statistical modeling outlined in their application ensure that the TSIA2 results are reliable and valid. Furthermore, the proposed amendments also outline a new "second chance" opportunity for students to demonstrate college readiness in math via diagnostic testing, thus aligning with the second-chance opportunity available in ELAR and allowing more students with demonstrated knowledge and skills to place directly in entry-level college coursework. Finally, the College Board will conduct, after one year of implementation, a study using authentic test results to verify validity of its benchmarks and will recommend modifications as findings dictate. These processes were similar to those implemented during the development of the current TSIA, where its validity study findings resulted in only one adjustment to the writing standards. As required in TAC, Rule 4.55(c), assessment results, including diagnostic Cont'd...