In the name of flexibility and innovation, ESSA allows the use of interim assessments, the results of which would be aggregated for purposes of ESSA accountability. However, there are good arguments for why both general achievement measures used multiple times during the school year and benchmark tests covering recently taught material would be poor choices for ESSA-required testing. Retention and where students are at the end of a school year matter. A better alternative for ESSA could be a two-component model using curriculum-embedded performance assessments on an interim basis and an abbreviated, traditional end-of-year summative test. The interim component, then, is doing something that is different from what the summative end-of-year measure does best.