STAR Testing - The Ever Elusive Reimbursable Mandate
STAR Testing, once a $38 million annual reimbursable program, has now been reduced to nothing. Fortunately, proactive steps taken three years ago provide hope for this program's successful return.
1997: STAR Program Legislation
In 1997, the legislature enacted the STAR program, comprised of an achievement test at grades 2-11. The Stanford 9 test was chosen by the State Board as the nationally norm referenced test for this purpose. When the STAR test claim was filed with the Commission on State Mandates (CSM), the decision recognized the specific tests within the STAR program as individual reimbursable items instead of the STAR umbrella as a whole. This approach, where each test within the STAR program is assessed separately as a possible mandate, is the root cause of the STAR reimbursement problems faced today.
2000: The Original Approved Program
The first CSM decision issued on the STAR program recognized the Stanford 9 nationally norm referenced achievement test and the SABE/2 Spanish Language Exam as reimbursable tests within the STAR testing program. The Standards Based Achievement Test known as the California Standards Tests (CST) and the California Alternative Performance Assessment (CAPA) were not part of the original approved program as they were never amended into this test claim.
2005: The Reconsidered Program
In the name of "Mandate Reform", the CSM was directed by the legislature to determine if federal No Child Left Behind laws mandated the various STAR program tests. The SABE/2 test was eliminated because it was deemed a federal mandate. However, the nationally norm referenced achievement test (now called the California Achievement Test, Sixth Edition Survey or CAT/6) remained a reimbursable state mandated cost. The CST & CAPA tests were not included in this reconsideration as they had not yet been pursued as reimbursable items. At the end of the day, only one of four STAR program tests, administered in just 2 grades, remained reimbursable. The $38 million dollar question of whether the other tests within the STAR program are state or federal mandates would be left until another day.
2008: The Death of the One Reimbursable STAR Test
Assembly Bill 519 (effective September 30, 2008) eliminated the Nationally Norm Referenced Achievement Test (CAT/6) at grades 3 & 7 from the STAR Testing Program. This change means none of the tests in today's STAR testing program remain reimbursable state mandated programs. Fortunately, this is not the end of the story.
The Light at the End of the Tunnel
Recognizing each test within the STAR program requires a separate test claim, San Diego USD and Grant Joint HSD (represented by David Scribner of Scribner & Smith) filed test claims in 2005. The purpose of these actions was to obtain reimbursement for the balance of the STAR testing program. These actions are pending and have yet to be set for hearing. The key point, which went undecided during the reconsideration, is whether the CSM will deem the individual tests within the STAR program as State or Federal mandated tests.
Scribner & Smith Recommends
We believe the STAR II test claims will be successful and recommend tracking your costs for the entire STAR program. This ensures State Controller's Office (SCO) required contemporaneous documents exist and positions your agency for full reimbursement regardless of whether some or all tests within the STAR program are approved. Recent SCO audits have permitted the use of cost allocations based on a per pupil tested method. Proactive time accounting of promising test claims is an integral part of our MAX8550 Time accounting system.
When it comes to mandates, it is better to be proactive rather than to react and recreate costs. |
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