Idaho Assessment Letter

June 28, 2006

The Honorable Dwight Johnson
Executive Director
Idaho State Board of Education
P.O. Box 83720
Boise, ID 83720-0037

The Honorable Marilyn Howard
Superintendent of Public Instruction
Idaho Department of Education
650 West State Street
PO Box 83720
Boise, Idaho 83720-0027

Dear Superintendent Howard:

Thank you for your participation in the U.S. Department of Education’s (Department) standards and assessment peer review process under Title I of the Elementary and Secondary Education Act of 1965 (ESEA). For Idaho, this review examined evidence of Idaho’s standards and assessment system under the Title I requirements in both the Improving America’s Schools Act of 1994 (IASA) and the No Child Left Behind Act of 2001 (NCLB). I appreciate the efforts required to prepare for the peer review. As you know, with the implementation of NCLB’s accountability provisions, each school, district, and State is held accountable for making adequate yearly progress (AYP) towards having all students proficient by 2013–14. An assessment system that produces valid and reliable results is fundamental to a State’s accountability system.

I am writing to follow up on the letter that was sent to you on December 9, 2005. In that letter we presented the results of the peer review of the Idaho standards and assessment system and detailed the additional evidence necessary for Idaho to meet the statutory and regulatory requirements of Section 1111(b)(1) and (3) of the ESEA under both the IASA and NCLB. The information Idaho provided in follow-up discussions with the State were not sufficient to address each item of evidence requested. The need for that evidence remains.

With respect to the Title I standards and assessment requirements under NCLB, as you will recall, the Department laid out new approval categories in the letter to the Chief State School Officers on April 24, 2006. These categories better reflect where States collectively are in the process of meeting the statutory standards and assessment requirements and where each State individually stands. Based on these new categories, the current status of the Idaho standards and assessment system is Approval Pending. This status indicates that Idaho’s standards and assessment system administered in the 2005–06 school year has at least two fundamental components that are missing or that do not meet the statutory and regulatory requirements, in addition to other outstanding issues that can be addressed more immediately. These deficiencies must be resolved in a timely manner so that the standards and assessment system administered next year meets all requirements. The Department believes that Idaho can address the outstanding issues by the next administration of its assessment system, that is, by the end of the 2006–07 school year.

Idaho’s system has a number of fundamental components that warrant the designation of Approval Pending. Specifically, the Department cannot approve Idaho’s standards and assessment system due to outstanding concerns with the academic achievement standards in mathematics and reading/language arts in grades 3-8 and high school and the technical quality, particularly the comparability of the Idaho Standards Achievement Tests (ISAT) from year to year. Please refer to the enclosure for a detailed list of the evidence Idaho must submit to meet the requirements for an approved standards and assessment system.

Accordingly, Idaho is placed under Mandatory Oversight, pursuant to 34 C.F.R. §80.12. Under this status, there will be specific conditions placed on Idaho’s fiscal year 2006 Title I, Part A grant award. In addition, Idaho must provide, not later than 25 business days from receipt of this letter, a plan and detailed timeline for how it will meet the remaining requirements to come into full compliance by the end of the 2006–07 school year. Beginning in September 2006, Idaho must also provide bi-monthly reports on its progress implementing the plan. If, at any time, Idaho does not meet the timeline set forth in its plan, the Department will initiate proceedings, pursuant to Section 1111(g)(2) of the ESEA, to withhold 15 percent of Idaho’s fiscal year 2006 Title I, Part A administrative funds, which will then revert to local educational agencies in Idaho.

As you know, Idaho has not yet received approval of its standards and assessment system under IASA. Based on the recommendations of the peer reviewers and the evidence you have provided, we believe that Idaho administered an assessment system in grades 3–8 and high school in 2005–06 that the evidence to date suggests is fully compliant with the statutory and regulatory requirements under IASA, which are more limited than those under NCLB. We recognize, however, that there are certain elements that cannot be completed by July 1, 2006, due to the nature of assessment development, such as setting academic achievement standards. The enclosure lists the evidence that is needed to establish compliance with the IASA requirements. In the plan and timeline requested above, Idaho should ensure that this evidence is submitted by October 1, 2006. Please know that, if Idaho does not meet the timeline for submitting this evidence, the Department will withhold, as required by section 1111(g)(1) of the ESEA, 25 percent of Idahos’ Title I, Part A State administrative funds for fiscal year 2006.

I know you are anxious to receive full approval of your standards and assessment system and we are committed to helping you get there. Toward that end, let me reiterate my earlier offer of technical assistance. We remain available to assist you however necessary to ensure you administer a fully approved standards and assessment system. We will schedule an additional peer review when you have evidence available to further evaluate your system. If you have any questions or would like to request reconsideration of the conditions, please do not hesitate to contact Patrick Rooney ( or David Harmon ( of my staff.


Henry L. Johnson


cc: Governor James E. Risch
Saundra K. DeKlotz

Summary of Additional Evidence that Idaho Must Submit to Meet ESEA Requirements for the Idaho Assessment System


  1. Additional evidence is required that sets forth a recognized standard-setting procedure and timeline for implementation and that includes substantial evidence (test blueprints, item specifications, and descriptions of competencies associated with each achievement level) that the achievement standards are aligned to the State’s grade-level content standards.
  2. Documentation is required including re-established academic achievement standards that are approved by the Idaho State Board of Education and that show alignment to the State’s grade-level content standards. This documentation must provide technical details and evidence of broad-based stakeholder participation in the process, including a high proportion of participants with specific content-area expertise.


  1. Documentation to support the comparability of the Idaho Standards Achievement Test (ISAT) forms from year to year.
  2. Evidence supporting the reliabilities of the ISAT with subpopulations.
  3. Related technical information resulting from the revision of academic achievement standards; the methodology designed to set the original achievement standards was not technically acceptable.


  1. Evidence that demonstrates adequate alignment of the ISAT with Idaho’s academic content and achievement standards in reading/language arts and mathematics.


  1. Documentation that includes the enrollment or total tested/not tested on the student report.
  2. Evidence that the ISAT results on individual student reports are expressed in terms of Idaho’s academic achievement standards with descriptions of what students know and can do at different achievement levels.
  3. Information regarding how individual student ISAT results are delivered to parents.

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