Missouri Assessment Letter

June 20, 2006

The Honorable D. Kent King
Commissioner of Education
Missouri Department of Elementary and Secondary Education
P. O. Box 480
Jefferson City, MO 65102-0480

Dear Commissioner King:

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 Missouri’s standards and assessments, which occurred February 13-15, 2006. The results of this peer review process indicated that additional evidence was necessary for Missouri to meet the statutory and regulatory requirements of Section 1111(b)(1) and (3) of the ESEA. At this time, the need for that evidence remains.

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 Missouri standards and assessment system is Approval Pending. This status indicates that Missouri’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 Missouri can address the outstanding issues by the next administration of its assessment system, that is, by the end of the 2006-07 school year.

Missouri’s system has a number of fundamental components that warrant the designation of Approval Pending. Specifically, the Department cannot approve Missouri’s standards and assessment system due to outstanding concerns with the alignment of the assessments with the State’s academic content and achievement standards for grades 3-8 and high school and the technical quality, including the validity of all assessments and the reliability of the new assessments added in the 2005-06 school year. Please refer to the enclosure for a detailed list of the evidence Missouri must submit to meet the requirements for an approved standards and assessment system.

Accordingly, Missouri is placed under Mandatory Oversight, as authorized under 34 C.F.R. §80.12. Under this status, there will be specific conditions placed on Missouri’s fiscal year 2006 Title I, Part A grant award. In addition, Missouri 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, Missouri must also provide bi-monthly reports on its progress implementing the plan. If, at any time, Missouri 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 Missouri’s fiscal year 2006 Title I, Part A administrative funds, which will then revert to local educational agencies in Missouri.

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 discuss this further, please do not hesitate to contact Abigail Potts (Abigail.potts@ed.gov) or Grace Ross (grace.ross@ed.gov) of my staff.

Sincerely,

Henry L. Johnson

Enclosure

cc: cc: Governor Matt Blunt
Dee Beck

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

1.0 – ACADEMIC CONTENT STANDARDS

1. Documentation that the grade level expectations (GLEs) in communication arts, math and science were formally approved.
2. Documentation showing that the GLEs in communication arts, math and science are challenging.
3. Documentation showing stakeholder diversity in the panels that developed the GLEs in communication arts, math and science.

2.0 – ACADEMIC ACHIEVEMENT STANDARDS

1. Documentation showing that the academic achievement standards for the regular assessments in communication arts and math were approved.
2. Documentation showing that labels, descriptors, and cut scores have been developed and approved for the alternate achievement standards.
3. Documentation showing stakeholder diversity in the panels that developed the academic achievement standards in communication arts and math.
4. Documentation showing the number and percent of those students with disabilities assessed against alternate achievement standards and those included in the regular assessment (including those administered with appropriate accommodations) for the spring 2006 assessments.
5. Plan and timeline for the development of an alternate assessment for science including descriptors.

3.0- FULL ASSESSMENT SYSTEM

1. Documentation that the assessments measure higher order thinking skills and student understanding of challenging content.

4.0 – TECHNICAL QUALITY

1. Plans to investigate the intended and unintended consequences of MAP and MAP-A.
2. A complete 2006 technical report for MAP (except for standard setting) containing information on the assessments in the areas of validity, reliability, fairness, bias, and the impact of accommodations.
3. Impact data for all required subgroups for all grades tested in 2006.
4. With regard to the State’s alternate assessments, evidence:
   1. That results from State’s alternate assessments are reported in a manner consistent with the alternate achievement standards.
   2. Of how the State will address overall test reliability and consistency for all achievement levels for the alternate assessments.
   3. Of inter-rater agreement for scoring the alternate assessments.
   4. Of clear criteria for the administration, scoring, analysis, and reporting components of the alternate assessment.
5. Documentation that scores for students with disabilities based on accommodated administration conditions allow for valid inferences about students’ with disabilities knowledge and skills.
6. Documentation that the State has a system for monitoring accommodations for ELL students during test administration.
7. A sample of the results of the State’s process for monitoring the implementation of accommodations during testing (4.6.e).

5.0 – ALIGNMENT

1. Document the level (content standards or GLEs) at which the 2006 Webb alignment study will be conducted.
2. Results of the 2006 Webb alignment study, when available.
3. Documentation of an alignment/linking study conducted for MAP-A.
4. A timeline and plan for addressing any identified alignment gaps for the MAP and the MAP-A.
5. Evidence that the findings of the 2006 alignment study informed the development of the fall 2006 RFP for ongoing MAP assessment development, if necessary.
6. Evidence that the 2006 MAP and the grade level expectations are aligned comprehensively, meaning that the assessments reflect the full range of the State’s GLEs.
7. Evidence of the cognitive complexity and challenge of the GLEs.
8. Evidence that the assessments are as cognitively challenging as the content standards and GLEs (beyond released items).
9. Evidence that the assessments and standards are aligned to measure the depth of the GLEs.
10. Evidence that the assessment reflects the degree of cognitive complexity and level of difficulty of the concepts and processes intended by the standards.

6.0 – INCLUSION

1. Participation data (data that show that all students in the grades tested are included in the assessment system) for the 2006 MAP and MAP-A administrations.
2. Clarification of the following discrepancy so that that the participation data presented can be understood: In the 2005 MAP summary reports for schools and for districts [7.5], the footnote describing “reportable” and “accountable” does not match the descriptions for those terms in the “MAP Guide to Interpreting Results.”

7.0 – REPORTING

1. Documentation of the 2006 individual student reports for both MAP and MAP-A.

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