Tulsa, OK — The NorthStar Project has filed formal public comments on the Oklahoma State Department of Education’s request for a waiver from federal peer review of statewide assessments. While affirming the Department’s intent to modernize testing and reduce burdens on schools, the NorthStar Project warns that the proposal—if adopted as written—risks eroding accountability, transparency, and fairness across Oklahoma’s 500+ school districts.

“Oklahoma cannot afford to weaken accountability at the very moment when student outcomes are at historic lows,” said Dr. Mark Roberts, Chairman of the NorthStar Project. “Our students deserve both innovation and rigor. That requires statewide comparability, constitutional compliance, and clear transparency for parents.”

In its filing, the NorthStar Project outlined six areas of concern:

1. Accountability and Comparability — Without a uniform statewide end-of-year test (summative testing), comparisons across districts will collapse into a fragmented patchwork of local benchmarks.
2. Federal Compliance — Dismissing federal peer review risks hundreds of millions in Title I and IDEA funding.
3. Fairness Across Districts — Underperforming districts may adopt easier assessments, concealing failure rather than fixing it.
4. Validity of College-Readiness Exams — Alternative tests may lack validation as statewide accountability measures under Every Student Succeeds Act.
5. Implementation Timeline — Immediate replacement of statewide testing before alternatives are validated would destabilize accountability.
6. Transparency and Public Trust — Oklahoma must publish clear annual reports on assessment vendors, costs, and outcomes.
   The comments emphasize that Oklahoma has a constitutional obligation to provide a “uniform and adequate” education. Summative assessments are the primary tool the state uses to demonstrate that duty. Eliminating the statewide test in spring 2025 without a validated replacement would leave Oklahoma unable to prove constitutional compliance.
   The NorthStar Project therefore urges OSDE to:

• Maintain at least one uniform statewide summative assessment in math and reading as an anchor.
• Pilot local benchmarks under federal authority before full replacement.
• Narrow and support the vendor list to prevent inequity across districts.
• Conduct rigorous technical reviews of Scholastic Assessment Test, American College Testing, and Classical Learning Test.
• Continue the scheduled spring 2025 statewide assessment to avoid a dangerous accountability gap.

“Parents, taxpayers, and policymakers need clear, comparable data to hold schools accountable,” Dr. Roberts said. “Innovation is important—but without accountability, innovation becomes a smokescreen. Oklahoma’s children deserve better.”

The NorthStar Project is an independent, Oklahoma-based initiative dedicated to dramatically improving K-12 education through bold policy ideas, rigorous analysis, and actionable reform strategies. We bring together parents, educators, and community leaders to design governance, funding, and instructional models that put students first. Our work provides practical blueprints for lasting change so every child in Oklahoma can thrive. More information is available at NorthStar’s website: https://oknorthstar.org.

NorthStar Project Comments on the Oklahoma State Department of Education ESSA Peer Review Waiver Request follow: