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Testing in Place

Leigh Anne Shaw makes the case for retaining ESL placement tools in California community colleges

In 2017, California Assembly Bill (AB) 705, by Assemblymember Jacqui Irwin, was drafted to eliminate placement bias and grant greater access for students in California’s community college system. The bill, which mandates that colleges maximize students’ probability of completing transfer-level English and math in a one-year timeline, aimed to address the needs of native-English-speaking high school students who were languishing from historic underplacement into remedial classes. The initial draft made no mention of the nearly 60,000 English language learners (ELLs) who enroll in college English as a second language (ESL) classes in order to become proficient in English for college; this omission of ELLs risked sweeping all ELLs directly into transfer-level composition (TLC) regardless of their ability to comprehend and produce academic English. A team of ESL faculty advocates worked directly with Assemblymember Irwin’s office to insert provisions into the bill to protect ELLs’ rights to English language instruction and avoid inconsistent and inequitable application of AB 705 throughout the 114 colleges statewide.

The AB 705 ESL Subcommittee was convened in 2018 by the California Community College Chancellor’s Office (CCCCO) and the Academic Senate for California Community Colleges (ASCCC) to provide guidance for ESL departments and their colleges in meeting the fall 2020 compliance deadline for credit ESL. However, to meet the earlier English and math compliance date of fall 2019, many colleges moved quickly to eliminate all assessment for placement services, despite the law’s provision (and CCCCO/ASCCC guidance) to retain ESL assessment services. Conflicting interpretations of the law have stymied ESL faculty efforts to maintain language-assessment services at the colleges, despite two clarification memos issued from the CCCCO via the ESL Subcommittee.

The zeal to remove assessment for placement from California community colleges can hinder the capacity of English language programs to serve students who require language proficiency to be successful in college. Failure to advise students of their rights to access credit ESL violates state law, and failure to assess ELLs accurately limits ESL departments’ options to equitably and effectively serve their students.

ESL Departments Are Language Programs

To serve California’s diverse population, ESL is provided at nearly all 114 community colleges throughout the state, in the form of credit, noncredit, or not-for-credit (community education, corporate education, or programs for international students) or a combination of these. Credit ESL programs in particular are effective in imparting language skills in tandem with preparation for academic work. AB 705 enshrines ESL in law, specifically calling out ESL students as foreign language learners “who require additional language training in English, require support to successfully complete degree and transfer requirements in English, or require both of the above.” The CCCCO tracks ELLs’ completion via the California Basic Skills Progress Tracker, thus marking ESL departments as language programs whose purpose is preparing students to be successful in college. AB 705 further states that “English as a second language (ESL) is distinct from remediation in English.” Defining ELLs as foreign language learners aligns ESL more with world (foreign) language instruction than with the instruction of college English. The unique preparation required to teach either ESL or English in the California community colleges supports this distinction, as does each field’s differing professional development. Unlike English, ESL shares with world languages a theory-based structure of second-language acquisition (SLA) involving a multitiered sequence leading to linguistic proficiency.

The Role of Assessment and Placement

Assessment, whether in English or any world language, obtains vital linguistic information to match a student to the best level of instruction for language growth and proficiency. Intensive English programs (IEPs), as a means to provide ESL to the nation’s international students prior to admission to colleges, are accredited by oversight bodies that all designate assessment and placement as critical elements of ensuring a quality program:

Commission on English Language Program Accreditation (CEA)

  • Student Achievement Standard 1: “The program or language institution has a placement system that is consistent with its admission requirements and allows valid and reliable placement of students into levels.” 
  • “In addition to having valid measurement tools, good practice includes having a set of reliable placement procedures. Programs and institutions may use published placement materials, valid and reliable in-house materials, or a combination of the two.”

American Association of Intensive English Programs (EnglishUSA)

  • Curriculum and Instruction Standard: “The program has appropriate assessment tools and procedures for initial placement of students into courses and to measure student progress toward course learning goals and attainment of English language proficiency.”

Other anglophone nations share this focus for their IEP accreditation:

Languages Canada

  • Orientation Standard D.1b: “Academic orientation includes testing and placement.”
  • Testing and Placement Standard F.5: “Diagnostic and test placement procedures are employed to ensure that each student is placed in an effective teaching–learning environment.”

British Council Accreditation Standards

  • Learner Management Standard T17(h): “There will be efficient procedures for the correct placement of students, appropriate to their level and age,and assessment of starting level so that progress can be evaluated.”
  • Learner Management Standard T19: “Students will be guided to select the examinations and examination training best suited to their needs and interests.”
    Placement Standard HT6: “There will be efficient procedures for assessing students’ level and needs, either at head office or on arrival locally (T17).”

Additionally, leading world language programs at U.S. universities, often in alignment with the American Council on Teaching Foreign Languages (ACTFL), focus on initial assessment and sequence placement as a means of quality assurance:

Middlebury College Language Schools

  • “All the Middlebury College Language Schools require their students to take placement tests after they have enrolled and before they begin taking classes. These placement tests help determine what level of study to place students in.”
  • “Most of the language schools require students to take multiple tests. The formats of these tests vary across schools. Some schools use paper-and-pencil tests, others use computer-based testing. Most schools augment written testing with oral testing, usually following oral proficiency guidelines as presented by the American Council on Teaching Foreign Languages (ACTFL).”

Stanford University Language Programs

  • “The Language Center administers placement tests to all students who intend to continue studying a foreign language at Stanford. The purpose of testing is diagnostic: it assesses students’ current language abilities in order to match them to the course most suitable for that level. Accurate initial placement is a key factor in successfully learning a foreign language. Placement exams in each language consist of both text and oral components.”

Georgetown University Language Programs

  • Placement into language programs is controlled through the university’s Canvas shell. All students with no previous experience in the target language are advised to enroll in Level 1, while students with previous experience are required to take a placement exam.”

As the primary recipients of transfers from California community colleges, the University of California (UC) and California State University (CSU) systems recognize the importance of language proficiency prior to admission. The CSU system requires a language-proficiency exam for any student who has not “completed at least three years of high school academic coursework taught in English, either in the U.S. or in a country where English is the native language.”

Similarly, the UC system has this message for university applicants:

  • If all of your high school/secondary school education was completed in English, you are considered proficient and do not need to satisfy this requirement.
  • However, if you’ve completed some high school or secondary school in a country where English was not the language of instruction, you will be required to demonstrate English proficiency if you have had less than three years of instruction in English.

The UC system also states that, in addition to taking a language-proficiency exam, students whose education has not been entirely in English may be subject to “an interview to determine English skills during the application review process.”

ACTFL, as a worldwide standard for language program alignment, uses globally validated rubrics that ESL text publishers use to clarify language instruction levels. So critical is assessment to ACTFL that they have created the ACTFL Center for Assessment Research and Development, whose missions include “[developing and maintaining] high-quality language-proficiency assessments.”

Placement Testing for ESL in a Community College

The omission of ESL from the early draft of the AB 705 bill illustrates how the bill was intended to address discrimination against native English speakers, not ELLs. The bill was meant to address high school students, particularly students of color, who have historically been underplaced into remedial coursework by assessment tests as the sole means of placement. California law now requires colleges to use multiple measures, primarily high school information, to place students into transfer-level English and math classes.

The issue of assessment and placement into a sequence of credit ESL courses, however, is far more nuanced than for transfer-level composition or math. ESL students must undergo two different steps of placement:

  1. Placement into the college pathways of English, ESL, and math (termed “initial placement” here), and
  2. Assessment and placement into the sequence of ESL (termed “sequence placement” here).

These two types of placement must not be conflated, as they are wholly separate, with differing functions and outcomes.

Initial Placement into Transfer-Level English or Credit ESL

Historically, students coming to a placement center for testing were directed through various processes to take either the ESL or English assessment. Under AB 1805 (partner bill to AB 705), students now must be informed of the right to access transfer-level composition or credit ESL. ESL is currently impacted in this stage of initial placement because in the move to implement AB 705, many colleges eliminated placement centers entirely. Additionally, sources of information about AB 705 such as and the video located on the Chancellor’s Office AB 705 page completely omit any reference to ESL.

Sequence Placement within a Credit ESL Program

Separate from initial placement, credit ESL programs require sequence placement into the levels of ESL. Levels of ESL vary from college to college according to service-area providers and demographics. Alignment between adult schools and community colleges through the California Adult Education Program (CAEP) legislation has resulted in placement agreements and articulations unique to each of the 72 districts, further complicating sequence placement.

Sequence placement is necessary as ELLs hail from a boundless array of language backgrounds. Their daily lives may reinforce language learning or not; they may have studied English formally, or they may have absorbed the language solely through “ear learning.” With so many variables in learner background, accurate placement into a level of credit ESL instruction maximizes success. Inappropriate placements can result in delays of student goals and missed opportunities to identify unique student needs. With the elimination of placement centers, ESL departments lack ways to accurately assess and place students into sequences. The absence of assessment takes placement out of the supervision of ESL discipline experts, and counselors, deans, support staff, and even students take on the burden of guiding ELLs into the most appropriate courses for their language needs.

The Academic Senate for California Community Colleges recognized ESL’s need to be able to assess language learners for accurate placement. Through Resolution 07.07 (spring 2018, Shaw) entitled “Maintain Language Placement Tests as a Multiple Measure Option for English as a Second Language (ESL),” the body adopted the following:

  • Resolved, that the Academic Senate for California Community Colleges will work with the California Community Colleges Chancellor’s Office and the Board of Governors as the approving body of all placement instruments to refrain from disallowing all placement instruments as a multiple measure; and
  • Resolved, that the Academic Senate for California Community Colleges will work with the California Community Colleges Chancellor’s Office and the Board of Governors to ensure that credit ESL departments are afforded the opportunity to provide language-proficiency assessment via multiple measures that may include quality standardized assessment tests for the purpose of aligning college language-learning curriculum with the needs of the English language learners who seek English proficiency at the advanced post-secondary level.

ESL Placement Is Not Discriminatory

Some California community colleges have feared that a portion of the California Code of Regulations, subsection 55522, declares assessment as discriminatory. This inaccurate interpretation was nullified by the AB 705 ESL Subcommittee in a memo dated April 18, 2019. In addition, the text of the AB 705 law states the following:

  • Assessment means the process of gathering information about a student regarding the student’s study skills, English language proficiency, computational skills, aptitudes, goals, learning skills, career aspirations, academic performance, and need for special services. Assessment methods may include, but are not necessarily limited to, interviews, standardized tests, attitude surveys, vocational or career aptitude and interest inventories, high school or post-secondary transcripts, specialized certificates or licenses, educational histories, and other measures of performance. (Section 2.(e))

The text of the law is very clear on assessment for ESL, specifically mentioning standardized tests as one acceptable measure. So long as assessment tests are not used as the sole measure for placement, they are allowable under the law.

Finally, it is important to look at the course-taking patterns that ELLs demonstrate; a cursory view at any college will show ELLs taking classes in a variety of subjects prior to completion of the ESL sequence and prior to entering transfer-level composition. Any ELL who wishes to take a course without a language prerequisite can do so; Wada, Rice, and Shaw (2016) documented several students who successfully completed several transfer-level courses despite not having completed the ESL sequence. Furthermore, in accordance with AB 1805, all students entering the community college should be informed of their rights to access transfer-level English as well as transfer-level or academic-credit ESL. Therefore, the retention of assessment and placement within an ESL sequence is neither discriminatory nor against the law.

Assessment Tools and Equity for ELLs

A lack of understanding of ESL’s nuanced needs for placement has created an equity issue for ELLs in the AB 705 landscape. While AB 705 does not restrict placement assessment for world language programs at the California community colleges, credit ESL departments are now potentially stripped of access to quality assessment instruments for their own language programs. Faculty from ESL departments statewide have requested the retention of placement tests and have been gravely concerned at the potential for the Board of Governors to cease approving further assessments for use.

ESL placement issues in California pre-date AB 705; in 2012, the CCCCO launched the Common Assessment Initiative (CAI), whose two-year promise of field-tested rubrics and a branching “smart” test covering English, ESL, and math caused top test publishers to exit the California market. ESL faculty began creating a comprehensive language-assessment battery to serve the entire college system; yet in 2014, work on the CAI was discontinued in the midst of field-testing ESL assessment items. Scores of faculty hours in the development of a comprehensive test of grammar, writing, reading, and listening were lost, and the state put no effort toward filling the sudden placement-test void. Colleges were forced to shift to the only remaining tests that still had Board of Governors approval, despite their age and looming expiry dates.

Meanwhile, compelling evidence shows placement tests as part of multiple measures can result in high throughput for credit ESL. Cypress College, for example, has a notably high three-year throughput rate for their ESL sequence, according to research conducted by Public Policy Institute of California (PPIC) and the RP Group. The college’s placement process includes the CELSA standardized test as one of multiple measures. Faculty assert the combination of multiple measures, including the use of a standardized test, enables students to place into high levels within the sequence, resulting in a strong transition from credit ESL to transfer-level composition. While the use of standardized placement tests as the sole measure of assessing for placement is not supported by law, the use of such tests as part of a battery of multiple measures should not be disallowed or deemed noncompliant.


ESL as a discipline is engaged in the teaching of English to foreign language learners and as such requires the same support that world languages enjoy in assessing students for placement within a program. The fall 2019 AB 705 compliance deadline for English and math has had the unfortunate effect of decimating initial and sequence placement for ESL despite ESL’s extended compliance deadline. Thus, ESL departments statewide now struggle to serve their students by placing them appropriately. The now-defunct Common Assessment Initiative caused an exodus of test publishers, and the Board of Governors has not approved any new assessments to offset those that will soon expire.

While AB 705 was intended to advance equity for all students, compliance that ignores the nuances of language learning jeopardizes equity for ELLs in California’s community colleges. ELLs need to know their rights to access credit ESL, and ESL departments need options for a reliable, high-quality assessment instrument to assess language proficiency and place students into the levels of their respective ESL sequences. The Board of Governors needs to approve new, quality assessment measures and, in the interim, extend past approvals so that ESL programs may continue to assess and place students into sequences. The CCCCO needs to convene a task force to seek out new assessments so that ESL departments may assess language learners via multiple measures. Finally, California community colleges that have eliminated initial assessment for English and math must be made to ensure that sequence assessment is still available for ESL.

Leigh Anne Shaw is an ESL professor at Skyline College, San Bruno, CA, and a member of the Assembly Bill (AB) 705 ESL Subcommittee at the Chancellor’s Office for California Community Colleges.

References available at

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