Length of the test is too long.
The test takes my students far too long if they take it seriously. When we were told about the test, we were told it should run about a single class period (high school periods are 51 minutes). It is taking our students three days or more, and some teachers report it taking a week for students to complete the test. Part of the issue is that the reading excerpts are far too long. If the test requires long excerpts, then have one long reading passage and more questions on a single passage. We test three times a year, and if students are taking 3-5 days to complete a test, that is 9-15 instructional days lost each year when we already don't have enough time to teach content. If we could truly make this a 45-60 minute test, that would be fantastic.