The Every Student Succeeds Act may have kept annual testing as a federal requirement. But it also aims to help states cut down on the number of assessments their students must take by giving districts the chance to use a nationally-recognized college entrance exam, instead of the regular state test, for accountability purposes.

When the law passed back in 2015, some superintendents hailed the change, saying it would mean one less test for many 11th graders, who would already be preparing for the SAT or ACT. Assessment experts, on the other hand, worried the change would make student progress a lot harder to track.

Now, more than two years after the law passed, it appears that only two states—North Dakota and Oklahoma—have immediate plans to offer their districts a choice of tests. Policymakers in at least two other states—Georgia and Florida—are thinking through the issue. Arizona and Oregon could also be in the mix.

That’s not exactly a mad dash to take advantage of the flexibility.

Offering a choice of tests can be a tall order for state education officials, said Julie Woods, a senior policy analyst at the Education Commission of the States. They have to figure out how to pay for the college entrance exams, design a process for districts to apply for the flexibility, and find a way to compare student scores on the state test to scores on the SAT, ACT, or another test.

That’s “potentially a lot more work than states are currently doing,” Woods said. “States have to decide what the payoff is for them.”

What’s more, the prospect of allowing districts to pick between multiple tests—and potentially change them from year-to-year—drives assessment experts “batty,” said Scott Marion, the executive director of the Center for Assessment, which works with states to design and implement tests.

“You’re just lost, you’re just grasping at straws for any kind of comparability” among school districts that take different tests, he said. “You’re supposedly giving districts free choice and all that nice stuff.” But states must decide, “do they care about flexibility or do they care about a comparable accountability system? It’s hard to have both.”

Marion argued that districts might not make technical quality their top criteria for choosing a test. Instead, the pick may be subject to the whims of the local school board or superintendent—positions that tend to have high turnover.

For now, Woods said, most states that want to use college entrance exams for accountability are using those tests as their primary state-wide high school assessment. In fact, a dozen states use either the SAT or the ACT for accountability, according to an Education Week survey published last year.

Potential State Takers

But some states think the potential upside outweighs any concerns.

North Dakota, for instance, wants to offer its districts the chance to take the ACT instead of the state exam, said Kay Mayer, a spokeswoman for the state education department. The state will need approval from the feds for technical reasons, dealing with the federal peer review process. (More on page 2 of this memo from the state to its districts.)

And Oklahoma plans to give districts a choice between two most popular college entrance exams—the ACT and the SAT. The move is very popular with districts, according to Oklahoma’s ESSA plan, which was submitted to the feds in September.

“Oklahoma’s decision to use a commercial, off-the-shelf college-readiness assessment (e.g. SAT, ACT) as the high school assessment enjoys broad support from stakeholders all over the state [and] responds to local district needs, and has been codified in state law,” the Sooner State said in its plan. (Check out the language for yourself on page 27 of the plan.)

Importantly, Oklahoma doesn’t currently designate either the ACT or SAT as its main assessment for high school accountability. Instead, the state plans to offer its districts a choice of either test without stating a preference. It’s unclear if that that will fly with the feds. The department told the state it needs to pick one test or the other as its primary high school exam, in its feedback letter to Oklahoma.

Georgia finds the option enticing, too. In fact, the state legislature passed a bill last year calling on state board to examine this and other testing flexibility offered under ESSA. The state has started on that work now, said Allison Timberlake, the interim deputy superintendent for assessment and accountability.

“It’s a slow methodical process to make sure that everything is in place and well aligned,” Timberlake said. Among the considerations: whether the college entrance tests offer appropriate accommodations for English-language learners and students in special education and whether they mesh with the state’s content standards.

State lawmakers in Florida have also expressed interest in offering their districts a choice of the ACT, SAT, or state exam. So far, though, bills that would make this possible have died in the legislature. State law prohibits the education department from making the change on its own, a spokeswoman said. Lawmakers required the state to study the issue. A report released last week concluded that it wasn’t a good idea, according to the Orlando Sentinel.

Oregon’s ESSA plan, which has gotten the green light from the U.S. Department of Education, includes a line saying the state will “pursue flexibility under ESSA to allow districts to use a nationally recognized assessment in place of the state exam.” The state said it will consider a host of factors, including educator feedback, in making the change. (For more, check out page 27 of Oregon’s plan).

And Arizona has also passed a law that would give its districts a choice of tests, not just in high school, but in K-8 schools, too. Offering middle and elementary schools a choice of tests would be a violation of ESSA, Rep. John Kline, R-Minn., an ESSA architect, has argued. Arizona didn’t include any mention of its testing law in its ESSA plan, which has already been approved by the feds, so it’s an open question whether the state will move forward on this.