June 29, 2007 – Louisiana Assessment Letter

June 29, 2007

The Honorable Paul G. Pastorek
Superintendent of Education
Louisiana Department of Education
PO Box 94064
1201 North 3rd Street, 5th Floor
Baton Rouge, Louisiana 70804-9064

Dear Superintendent Pastorek:

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).

In a letter to you on April 18, 2007, the Department enumerated one fundamental component as well as a number of technical issues regarding Louisiana’s standards and assessment system that did not meet all the requirements of Section 1111(b)(1) and (3) of the ESEA. Specifically, the Department did not approve Louisiana’s standards and assessment system due to concerns with Louisiana’s alternate assessment based on alternate academic achievement standards for students with the most significant cognitive disabilities. In response, Louisiana submitted additional evidence to the Department in June 2007, which demonstrates that Louisiana’s regular assessment meets all ESEA standards and assessment requirements. However, we still have concerns regarding the technical quality and alignment to grade-level content standards of the Louisiana Alternate Assessment, Level I (LAA 1). The complete list of evidence needed to address these concerns is on the last pages of this letter.

We are pleased that Louisiana is already taking steps to remedy the deficiencies in the LAA 1. As indicated in the correspondence Louisiana submitted to the Department on June 22, 2007, Louisiana has already begun to develop a new alternate assessment based on alternate academic achievement standards that will be used to assess students with the most significant cognitive disabilities in the 2007-08 school year. We will schedule a peer review of Louisiana’s new alternate assessment when the necessary evidence is available.

Because Louisiana was not able to address the deficiencies for the LAA1 in time for its administration in the 2006-07 school year, Louisiana cannot demonstrate that the full standards and assessment system it administered in 2006-07 meets ESEA requirements. As a result, Louisiana’s system remains Approval Pending and Louisiana remains in Mandatory Oversight, as authorized under 34 C.F.R. §80.12. Under this status, we will place a condition on Louisiana’s fiscal year 2007 Title I, Part A grant award.

In addition, Louisiana must enter into an agreement with the Department demonstrating its commitment and investment of resources to be able to administer a fully approved standards and assessment system in the 2007-08 school year. Specifically, Louisiana must submit a mutually acceptable timeline for how and when the remaining work will be completed and evidence submitted for peer review. Further, Louisiana must submit quarterly reports of its progress along this timeline. If, at any point, Louisiana does not submit the evidence required or does not administer an approved standards and assessment system in 2007-08 that meets all ESEA requirements, the Department will initiate proceedings, pursuant to Section 1111(g)(2) of the ESEA, to withhold all or a portion of Louisiana’s Title I, Part A administrative funds, which will then revert to local educational agencies in Louisiana.

I appreciate the steps Louisiana has taken toward meeting the requirements of the ESEA, and I know you are anxious to receive full approval of your standards and assessment system. We are committed to helping you get there and remain available to provide technical assistance. 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 discuss this further, please do not hesitate to contact Grace Ross (grace.ross@ed.gov) or Martha Snyder (martha.snyder@ed.gov) of my staff.

Sincerely,

Kerri L. Briggs, Ph.D.

Enclosure

cc: Governor Kathleen Babineaux Blanco
Scott Norton

SUMMARY OF ADDITIONAL EVIDENCE THAT LOUISIANA MUST SUBMIT TO MEET ESEA REQUIREMENTS FOR THE LOUISIANA STANDARDS AND ASSESSMENT SYSTEM

2.0 – ACADEMIC ACHIEVEMENT STANDARDS

1. Evidence of approved/adopted alternate academic achievement standards for students with the most significant cognitive disabilities in reading/language arts and mathematics for each of grades 3 through 8 and high school.
2. Evidence that the alternate academic achievement standards include for each content area:
   1. a. At least three levels of achievement, including two levels of high achievement (e.g., proficient and advanced) that determine how well students are mastering a State’s academic content standards and a third level of achievement (e.g., basic) to provide information about the progress of lower-achieving students toward mastering the proficient and advanced levels of achievement;
   2. Descriptions of the competencies associated with each achievement level; and
   3. Assessment scores (“cut scores”) that differentiate among the achievement levels.
3. Evidence that the Board or other authority has adopted all alternate academic achievement standards.
4. Documentation that the State has reported separately the number and percent of those students with disabilities assessed against alternate academic achievement standards, those assessed on an alternate assessment against grade-level standards and those included in the regular assessment (including those administered with appropriate accommodations).
5. Evidence that the State has documented the involvement of diverse stakeholders in the development of its alternate academic achievement standards.
6. Documentation that the alternate student academic achievement descriptors for science are based on grade-span content standards and that they are linked to grade-span measures of students’ subject-matter proficiency.

4.0 – TECHNICAL QUALITY

1. For the alternate assessments based on alternate academic achievement standards, evidence that the State has documented validity (in addition to the alignment of the alternate assessment with the content standards), as described in the Standards for Educational and Psychological Testing (AERA/APA/NCME, 1999).
2. For the alternate assessments based on alternate academic achievement standards, evidence that the State has provided documentation of the standard-setting process including a description of the selection of judges, methodology employed, and final results.
3. For the alternate assessments based on alternate academic achievement standards, evidence that the State has considered the issue of reliability, as described in the Standards for Educational and Psychological Testing (AERA/APA/NCME, 1999).
4. Evidence that the State has ensured that its alternate assessments based on alternate academic achievement standards are fair and accessible to all eligible students, including students with limited English proficiency.
5. Evidence that the State has taken steps, such as bias review of items, to ensure fairness in the development of the alternate assessment based on alternate academic achievement standards.
6. When different test forms or formats are used for the alternate assessments based on alternate academic achievement standards, evidence that the State has ensured that the meaning and interpretation of results are consistent.
7. Evidence that the State has established:
   1. Clear criteria for the administration, scoring, analysis, and reporting components of its alternate assessment based on alternate academic achievement standards; and
   2. That the State has a system for monitoring and improving the on-going quality of that assessment.

5.0 – ALIGNMENT

1. Evidence that the State has taken steps to ensure alignment between its alternate assessment based on alternate academic achievement standards and the State’s academic content and alternate academic achievement standards.
2. Evidence that the State has developed ongoing procedures to maintain and improve alignment between the alternate assessment and alternate academic achievement standards over time, particularly if gaps have been noted.

6.0 – INCLUSION

1. Evidence that the State has implemented alternate assessments for students whose disabilities do not permit them to participate in the regular assessment even with accommodations.
2. Evidence of guidelines and training that the State has in place to ensure that all students with disabilities taking the alternate assessment based on alternate academic achievement standards are included appropriately in the State assessment system.
3. Evidence that the State has developed clear guidelines for Individualized Educational Program (IEP) Teams to apply in determining which assessment is most appropriate for a student.
4. Regarding the alternate achievement standards:
   1. Evidence that the State has developed clear guidelines for IEP Teams to apply in determining when a child’s cognitive disability justifies assessment based on alternate academic achievement standards; and
   2. Evidence of the steps the State has taken to help regular and special education teachers and other appropriate staff know how to administer assessments, including making use of accommodations, for students with the most significant cognitive disabilities.

7.0 – REPORTS

1. Evidence that the State’s reporting system facilitates appropriate, credible, and defensible interpretation and use of data from its alternate assessment based on alternate academic achievement standards.
2. For the alternate assessment based on alternate academic achievement standards, evidence that the State has provided for the production of individual interpretive, descriptive, and [non-clinical] diagnostic reports that indicate relative strengths and instructional needs:
   1. Evidence that these individual student reports express results in terms of the State’s alternate academic achievement standards rather than numerical values such as scale scores or percentiles;
   2. Evidence that these individual student reports provide information for parents, teachers, and principals to help them understand and address a student’s specific academic needs. This information must be displayed in a format and language that is understandable to parents, teachers, and principals, for example through the use of descriptors that describe what students know and can do at different performance levels. The reports must be accompanied by interpretive guidance for these audiences; and
3. Evidence that the State ensures that these individual student reports will be delivered to parents, teachers, and principals as soon as possible after the alternate assessment based on alternate academic achievement standards is administered.

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