Illinois Assessment Letter

June 23, 2006

The Honorable Randy J. Dunn
Superintendent of Education
Illinois Board of Education
100 North First Street
Springfield, Illinois 62777

Dear Superintendent Dunn:

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), as amended by 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 peer review of Illinois’ standards and assessments, which occurred in May 2006. The results of this peer review process indicated that additional evidence was necessary for Illinois to meet the statutory and regulatory requirements of Section 1111(b)(1) and (3) of the ESEA.

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 Illinois standards and assessment system is Approval Pending. This status indicates that Illinois’ standards and assessment system administered in the 2005-06 school year has three or more 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 Illinois can address the outstanding issues by the next administration of its assessment system, that is, by the end of the 2006-07 school year.

Illinois’ system has a number of fundamental components that warrant the designation of Approval Pending. Specifically, the Department cannot approve Illinois’ standards and assessment system due to outstanding concerns with the Illinois Measures of Annual Growth in English (IMAGE) assessment that is given to limited English proficient students; the technical quality of the Prairie State Achievement Examination (PSAE) and the Illinois Alternate Assessment (IAA); and the alignment of the PSAE and the linkage of the IAA to grade-level content standards. Please refer to the enclosure for a detailed list of the evidence Illinois must submit to meet the requirements for an approved standards and assessment system.

Accordingly, Illinois is placed under Mandatory Oversight, pursuant to 34 C.F.R. §80.12. Under this status, there will be specific conditions placed on Illinois’ fiscal year 2006 Title I, Part A grant award. Illinois 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, Illinois must also provide bi-monthly reports on its progress implementing the plan.

Due to the number of outstanding items that Illinois needs to complete to come into compliance with NCLB, the Department intends to withhold 10 percent of the State’s fiscal year 2006 Title I, Part A administrative funds, totaling $540,228, pursuant to Section 1111(g)(2) of the ESEA. Illinois has the opportunity, within 20 business days of receipt of this letter, to show cause in writing why we should not withhold these funds. If Illinois cannot show cause, the Department will withhold 10 percent of Illinois’ fiscal year 2006 Title I, Part A administrative funds, which will then revert to local educational agencies in Illinois. Moreover, if, at any time, Illinois does not meet the timeline set forth in its plan, the Department will initiate proceedings to withhold an additional 10 percent of the State’s fiscal year 2006 Title I, Part A administrative funds.

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 (Patrick.Rooney@ed.gov) or Grace Ross (Grace.Ross@ed.gov) of my staff.

Sincerely,

Henry L. Johnson

Enclosure

cc: Governor Rod R. Blagojevich
Becky McCabe

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

1.0 – ACADEMIC CONTENT STANDARDS

1. Documentation of formal Board approval of the 2005-06 Assessment Frameworks, which contain the State’s grade-level content standards for reading and mathematics.
2. Documentation regarding the degree of challenging content, rigor, and coherence of the grade-level standards contained in the 2005-06 Assessment Frameworks for reading and mathematics.
3. Documentation of the involvement of diverse groups of stakeholders (e.g., grade level and content expertise, students with disabilities, and English language learners) in the development of the 2005-06 Assessment Frameworks for reading and mathematics.

2.0 – ACADEMIC ACHIEVEMENT STANDARDS

1. Documentation of grade-level or grade-span descriptors associated with alternate achievement standards for reading, mathematics, and science.
2. Formal approval of the State’s alternate achievement standards.
3. Documentation that the State’s alternate achievement standards are limited to students with significant cognitive disabilities.
4. Clear guidelines to assist Individualized Education Program (IEP) teams in deciding when a student should be assessed against alternate achievement standards.
5. Evidence of clear procedures for informing parents when a child’s achievement will be based on alternate achievement standards and any possible consequences imposed by the LEA or State.
6. Evidence of the number and percentage of students with disabilities taking the alternate assessment and the regular assessment (with or without accommodations).
7. Grade-level descriptions of the competencies associated with achievement standards in math and reading for grades 3-8 related to the content standards in the Assessment Frameworks.
8. Documentation of the involvement of diverse groups (e.g., expertise in educating students with disabilities, and English language learners) in developing academic achievement standards and alternate achievement standards (including cut scores).

3.0 – FULL ASSESSMENT SYSTEM

1. Documentation showing the design of the entire assessment system and how the assessments fit into a coherent system that describes student achievement relative to Illinois’ academic content standards.
2. Evidence regarding how the State uses assessment results in determining adequate yearly progress, including the relative contribution of the ACT and WorkKeys scores for reading and mathematics.
3. Documentation showing the relative contribution of the ACT, WorkKeys, and State Board-developed science assessment to the overall Prairie State Achievement Examination (PSAE) content area scores in reading, mathematics, and science and evidence of how those contributions affect the alignment of overall scores to the Assessment Frameworks.
4. Documentation that the Illinois Measures of Annual Growth in English (IMAGE) math and reading tests are comparable to the Illinois Standards Achievement Test (ISAT) and the PSAE

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5. Documentation that the assessments measure higher-order thinking skills and student understanding of challenging content for the ISAT reading and mathematics.

4.0 – TECHNICAL QUALITY

1. Plans and a timeline for determining whether the assessments are producing intended and unintended consequences.
2. Documentation of the technical adequacy of the current ISAT:
   • Evidence of validity;
   • Evidence of the use of procedures for sensitivity and bias reviews, DIF analyses, and how results are used;
   • Documentation that the cut scores on the 2005-06 ISAT in each content area and grade level relate to student performance on the Illinois Learning Standards, as delineated in the 2005-06 Assessment Frameworks;
   • Documentation of the reliability, conditional standard errors of measurement, and generalizability of the ISAT assessments for all grades and content areas;
   • Documentation of procedures for ensuring consistency of scores over time, including equating procedures, and the consistency of score meaning over time; and
   • Documentation of quality control procedures for scoring, analysis, and reporting.
3. Documentation of the technical adequacy of the PSAE:
   • Evidence of validity;
   • Evidence of the use of procedures for sensitivity and bias reviews, DIF analyses, and evidence of how results are used;
   • Evidence of a review of the PSAE cut scores and follow-up activities to correct flaws in the standard-setting procedures, if any are found;
   • Documentation of the reliability, conditional standard errors of measurement, and generalizability of the PSAE for all content areas;
   • Documentation of procedures for ensuring consistency of scores over time, including equating procedures, and the consistency of score meaning over time; and
   • Documentation of quality control procedures for scoring, analysis, and reporting.
4. Documentation of the technical adequacy of the IMAGE:
   • Evidence of validity;
   • The use of procedures for sensitivity and bias reviews, DIF analyses, and evidence of how results are used;
   • Evidence that the IMAGE cut scores in mathematics are comparable in meaning to those on the ISAT and the PSAE mathematics assessments; and
   • Evidence of a content-based rationale for the IMAGE reading cut scores and evidence that the cut scores are comparable in meaning (i.e., represent the same degree of knowledge and skills in Illinois grade-level content standards) to those on the ISAT and the PSAE reading assessments.
5. Documentation of the technical adequacy of the Illinois Alternate Assessment (IAA):
   • The use of procedures for sensitivity and bias reviews and evidence of how results are used; and
   • Clear documentation of the standard-setting process.
6. Documentation that the state monitors the provision and use of accommodations to ensure that appropriate types of accommodations are provided for students with disabilities.
7. Documentation of the provision of linguistic accommodations for limited English proficient students.
8. Documentation that the use of accommodations yields meaningful scores.

5.0 – ALIGNMENT

1. A plan for the alignment study planned for the ISAT in reading and mathematics.
2. The final report of the science alignment study.
3. A plan for addressing the weaknesses and deficiencies found in the PSAE alignment studies, especially in the reading assessment.
4. A plan and a timeline for addressing the weaknesses and deficiencies found in the alignment of the IMAGE reading assessment.
5. Details of the alignment study planned for the IAA. This evidence should include the assurance that tasks used are appropriately aligned/linked to the academic performance indicators.

6.0 – INCLUSION

1. Documentation showing the number of students enrolled and number of students tested for each subgroup within grade levels and content areas; this report should include students with medical exemptions and students who are receiving services in other locations but whose education is the responsibility of the sending school.
2. Documentation that schools are encouraged, through policy and training, to include students with the most significant cognitive disabilities in assessments based upon grade-level standards, when appropriate.
3. Documentation of policies and practices the State has in place to ensure the identification and inclusion of migrant and other mobile students in the tested grades in the assessment system.

7.0 – REPORTS

1. 2005-06 ISAT score reports at the individual, school, district, and State levels.
2. 2005-06 IAA score reports at the individual, school, district, and State levels showing interpretive material for parents.
3. Documentation that enrollment data collected at time of testing reflect actual school enrollment, verified to ensure that numbers of students are being reported accurately.
4. Documentation that individual student reports are delivered so that instructional decisions and parental notification can be made in a timely manner.
5. Documentation that the PSAE scores are reported relative to academic content standards in reading and mathematics.

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