Mississippi Assessment Letter dated August 6, 2007

August 6, 2007

The Honorable Hank M. Bounds
Superintendent
Mississippi Department of Education
P. O. Box 771
Jackson, Mississippi 39205-0771

Dear Superintendent Bounds:

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 am writing to provide feedback from the most recent peer review on May 21-25, 2007. The results of this review indicate that, based on the evidence received, Mississippi’s standards and assessment system still does not meet all of the statutory and regulatory requirements of Section 1111(b)(1) and (3) of the ESEA. I want to thank you for taking the time to meet with my staff and me during my visit to Jackson on July 18 to discuss the results of this review.

I want to take this opportunity to enumerate the evidence that Mississippi must provide in order to have a fully compliant system. Specifically, the Department cannot approve Mississippi’s standards and assessment system due to outstanding concerns with achievement standards, technical quality, alignment with grade-level content standards, and inclusion for the Mississippi Curriculum Test (MCT), the Mississippi Alternate Assessment of Extended Curriculum Frameworks (MAAECF), the Mississippi Subject Area Testing Program (MSATP), and the new high school assessment based on alternate academic achievement standards. The enclosure provides a detailed list (discussed with you in mid-July) of the evidence Mississippi must still submit to meet the requirements for a fully approved standards and assessment system. In addition, I know that Mississippi is in the process of developing a new general assessment (the Mississippi Curriculum Test 2, or MCT2, for grades 3-8) and is revising the MSATP for high school for the 2007-08 school year. These new assessments must meet each element of the Department’s peer review guidance, which is available on the Department’s website (refer to: http://www.ed.govhttps://www2.ed.gov/policy/elsec/guid/saaprguidance.doc). The evidence list is based on our understanding that Mississippi will fully implement the new general assessments, the MCT2 and MSATP, for the 2007-08 school year. Should those plans change, please contact us immediately to discuss the impact on the Mississippi standards and assessment and accountability systems.

I know that Mississippi will be submitting additional evidence regarding the MAAECF, the high school alternate assessment, and the field test of the MCT2 for peer review within the next month. Therefore, we are not assigning an approval status to Mississippi’s system at this time. Please note that all evidence regarding the MAAECF and the high school alternate assessment must be submitted no later than August 31, 2007. That evidence will be peer reviewed during the week of September 17-21, 2007. Because Mississippi’s system is not fully approved, a condition was placed on your fiscal year 2007 Title I, Part A grant award.

Based upon the results of the September peer review, we will take appropriate enforcement actions as outlined in the Department’s May 10, 2007, fact sheet, including the possibility of a Compliance Agreement under Section 457 of the General Education Provisions Act. 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).

I would like to acknowledge the tremendous work done by your staff to implement the new high school alternate assessment and the MCT2 field test. The hardship imposed upon Mississippi by Hurricane Katrina in 2005-06 diverted Mississippi’s time, energy, and resources at a critical time. Due to these problems and because of the progress Mississippi has made revising its standards and assessment system, the Department will not withhold any portion of Mississippi’s fiscal year 2007 Title I, Part A administrative funds.

I appreciate the steps Mississippi 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. As you move forward in meeting the remaining requirements of the ESEA, please let us know what additional assistance we can provide. 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 Patrick Rooney (Patrick.Rooney@ed.gov) of my staff.

Sincerely,

Kerri L. Briggs, Ph.D.

Enclosures

cc: Governor Haley Barbour
Kris Kaase

SUMMARY OF ADDITIONAL EVIDENCE THAT MISSISSIPPI MUST SUBMIT TO MEET ESEA REQUIREMENTS FOR THE MISSISSIPPI ASSESSMENT SYSTEM

NOTE: Because no evidence was submitted for the new Mississippi Curriculum Test (MCT2) for reading/language arts and mathematics in grades 3-8 and because Mississippi is revising its Mississippi Subject Area Testing Program (MSATP) for high school, both of which will be operational in 2007-08, Mississippi must submit all evidence for elements 2, 3, 4, 5, 6, and 7 as listed in the Department’s April 2004 Peer Review Guidance (refer to: http://www.ed.govhttps://www2.ed.gov/policy/elsec/guid/saaprguidance.doc) for both of these assessments.

1.0 – ACADEMIC CONTENT STANDARDS

1. Documentation showing that the Language Arts, Mathematics, and Science Frameworks are challenging.
2. Document showing stakeholder diversity, especially expertise in students with disabilities and limited English proficiency, in the panels that developed frameworks in language arts, mathematics and science.

2.0 – ACADEMIC ACHIEVEMENT STANDARDS

High School Alternate Assessment:

1. Evidence of approved/adopted alternate academic achievement standards for students with the most significant cognitive disabilities in reading/language arts and mathematics for high school.
2. Evidence that the alternate academic achievement standards include for each content area:
   1. At least three levels of achievement, including two levels of high achievement (proficient and advanced) that determine how well students are mastering a State’s academic content standards and a third level of achievement (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. Documentation that the State has reported separately the number and percentage of students with disabilities assessed on an alternate assessment based on alternate academic achievement standards, an alternate assessment based on grade-level academic achievement standards, and the regular assessment (with and without accommodations) for the 2007 administration of the assessments.
4. Evidence of diverse stakeholders representation in the development of the alternate academic achievement standards.

3.0 – FULL ASSESSMENT SYSTEM

1. Evidence that the assessments, including the MCT2 and the MSATP, assess higher-order thinking skills and understanding of challenging content.

4.0 – TECHNICAL QUALITY

MAAECF:

1. For the alternate assessment(s), evidence that the State has considered the issue of reliability, as described in the Standards for Educational and Psychological Testing (AERA/APA/NCME, 1999).
2. When different test forms or formats are used for the alternate assessment, evidence that the State has ensured that the meaning and interpretation of results are consistent.
3. Evidence that the State has established:
   1. Clear criteria for the administration, scoring, analysis, and reporting components of its alternate assessment(s); and
   2. A system for monitoring and improving the on-going quality of its alternate assessment.

High School Alternate Assessment:

1. Evidence that the State has documented the issue of validity (in addition to the alignment of the assessment with the content standards), as described in the Standards for Educational and Psychological Testing (AERA/APA/NCME, 1999).
2. Evidence that the State has provided documentation of the standards-setting process including a description of the selection of judges, methodology employed, and final results.
3. 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 assessment system is 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 assessments.
6. When different test forms or formats are used for the alternate assessment, 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(s); and
   2. A system for monitoring and improving the on-going quality of its alternate assessment.

5.0 – ALIGNMENT

MAAECF:

1. Documentation of how the alignment of IEP goals/objectives with the MAAECF items affects the alignment of student work on the alternate assessment.

High School Alternate Assessment:

1. Evidence that the State has taken steps to ensure alignment between its alternate assessments 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(s) and standards over time, particularly if gaps have been noted.

6.0 – INCLUSION

1. Documentation of the State’s total and subgroup enrollments in each of the required grade levels and subjects or grade clusters for all the assessments (MCT2, MAAECF, MSATP, and High School Alternate) and calculations of its participation rates as a proportion of students assessed to students enrolled during the test administration period.
2. Documentation of guidelines and procedures that the State has in place to ensure that all students are tested with an appropriate assessment aligned with grade-level content standards.

7.0 – REPORTING

MAAECF:

1. Documentation of the timeline regarding when the various audiences will receive the information from the State.

High School Alternate Assessment:

1. Evidence that the State’s reporting system facilitates appropriate, credible, and defensible interpretation and use of its alternate assessment data.
2. 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 is administered.

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