June 29, 2007 – Kentucky Assessment Letter

June 29, 2007

Honorable Kevin Noland
Interim Commissioner of Education
Kentucky Department of Education
500 Mero Street
Frankfort, Kentucky 40601

Dear Commissioner Noland:

I am writing regarding our review of Kentucky’s standards and assessment system under the standards and assessment requirements of the Elementary and Secondary Education Act (ESEA), as amended by the No Child Left Behind Act of 2001 (NCLB). We appreciate the efforts required to prepare for the peer review and hope that the process provides useful feedback that will support Kentucky’s efforts to monitor student progress toward challenging standards.

External peer reviewers and Department staff evaluated Kentucky’s submission and found, based on the evidence received, that it did not meet all the statutory and regulatory requirements of section 1111(b)(1) and (3) of the ESEA. I know that my staff has discussed the results of this review with your staff. However, I want to take this opportunity to enumerate the evidence that Kentucky must provide in order to have a fully compliant system under NCLB.

The evidence Kentucky submitted for peer review on May 21-25, 2007, resolved several of the outstanding concerns regarding the regular assessment. However, there was not sufficient evidence provided to address all required elements regarding the new alternate assessment based on alternate achievement standards for students with the most significant cognitive. The complete list of evidence needed to address these concerns is on the last pages of this letter.

We know that the Kentucky will complete work within the next few months that may result in a fully approved standards and assessment system under NCLB. Therefore, we are not assigning an approval status to Kentucky’s system at this time. Because that system is not fully approved, however, we will place a condition on your fiscal year 2007 Title I, Part A grant award.

To ensure that all remaining work occurs in a timely manner, I request that, within two weeks of the date of this letter, you provide my staff with a detailed timeline for how and when Kentucky will satisfy the remaining requirements. As part of that timeline, please indicate when you will submit evidence as it becomes available. We will review that evidence and schedule an additional peer review, if necessary.

If Kentucky is unable to resolve the remaining issues with its assessment system by the agreed upon timeline, we will take appropriate enforcement actions as outlined in the Department’s May 10, 2007 fact sheet, including the possibility of continuing in Mandatory Oversight, pursuant to the 34 C.F.R. §80.12. For your convenience, I am enclosing a copy of that fact sheet, which is also available on the Department’s website (http://www.ed.govhttps://www2.ed.gov/admins/lead/account/statesystems.html).

Also enclosed with this letter are detailed comments from the peer review team that evaluated Kentucky’s assessment materials. I hope you will find the reviewers’ comments and suggestions helpful.

We look forward to working with Kentucky to support a high-quality standards and assessment system. If you would like to discuss this further, please do not hesitate to call David Harmon (202-205-2213) or Abigail Potts (202-260-0941) of my staff.


Kerri L. Briggs, Ph.D.


cc: Governor Ernie Fletcher
Pam Rodgers

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


  1. Approved academic achievement standards for the KCCT in reading and mathematics for each of grades 3 through 8 and for the 10-12 grade range with documented diverse stakeholder involvement.
  2. Approved alternate academic achievement standards for students with the most significant cognitive disabilities in reading and mathematics for each of the grades 3 through 8 and at least once in the 10-12 grade span with documented diverse stakeholder involvement.


  1. Comparability of multiple KCCT reading and mathematics test forms within content area and grade level.


  1. Validity with respect to the following categories:
    1. Intended and unintended consequences of the KCCT.
    2. Scoring and reporting structures for the KCCT and the KAP-R are consistent with the sub-domain structures of its academic content standards.
    3. KCCT and item scores are related to internal or external variables as intended.
  2. Standard setting process for the KCCT and KAP-R including the selection of judges, methodology employed, and final results.
  3. Reliability with respect to the following categories:
    1. a. Based on data for Kentucky’s student population and each reported subpopulation.
    2. Conditional standard error of measurement and student classification consistency at each cut score specified in Kentucky’s academic achievement standards.
    3. Generalizability for relevant sources, such as variability of groups, internal consistency of item responses, variability among schools, consistency from form to form of the test, and inter- rater consistency in scoring.


  1. External alignment study (2007) for reading and mathematics Kentucky Core Content Tests alignment to the Core Content for Assessment.
  2. Alignment study (2007) for Kentucky Alternate Portfolio-Revised alignment with the Core Content for Assessment.


  1. Data reports that show that all students in the grades tested are included in the assessment system (e.g., students with disabilities, students with limited English proficiency, economically disadvantaged students, race/ethnicity, and migrant students).


  1. Final copies of student, school and State 2007 reports.

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