Puerto Rico Assessment Letter

March 21, 2007

The Honorable Rafael Aragunde Torres
Secretary of Education
Puerto Rico Department of Education
P.O. Box 190759
San Juan, Puerto Rico 00919-0759

Dear Secretary Aragunde:

Thank you for submitting additional assessment materials for peer review 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 Puerto Rico’s efforts to monitor student progress toward challenging standards.

In the Department’s letter to you on June 29, 2006, Assistant Secretary Johnson enumerated the fundamental components as well as a number of additional technical issues that had not met the standards and assessment requirements of the ESEA after the first peer review in May 2006. Specifically, the Department could not approve Puerto Rico’s standards and assessment system due to outstanding concerns with the alignment of Las Pruebas de Aprovechamiento Académico (PPAA) to grade-level content standards and the performance level descriptors for the alternate assessment based on alternate achievement standards (Las Pruebas Puertorriqueñas de Evaluación Alterna, or PPEA). The peer reviewers and Department staff evaluated Puerto Rico’s additional evidence and found, based on the evidence received, that it still does not meet all the statutory and regulatory requirements of Section 1111(b)(1) and (3) of the ESEA. Specifically, the peer review of this evidence suggests that there remain concerns regarding the alignment of the PPAA to grade-level content standards and the performance level descriptors for the PPEA.

Because Puerto Rico’s additional submission of evidence did not resolve all outstanding issues, the status of its standards and assessment system remains Approval Pending. Please note that Puerto Rico must address all outstanding issues in order to have a fully compliant standards and assessment system under the ESEA by the end of the 2006-07 school year. Please refer to the enclosure for a detailed list of the evidence Puerto Rico must still submit to meet the requirements for an approved standards and assessment system.

Because the status of Puerto Rico’s standards and assessment system is still Approval Pending, Puerto Rico continues to be under Mandatory Oversight, as authorized under 34 C.F.R. §80.12. Under this status, we placed specific conditions on Puerto Rico’s fiscal year 2006 Title I, Part A grant award. If, at any time, Puerto Rico 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 Puerto Rico’s fiscal year 2006 Title I, Part A administrative funds, which will then revert to public schools in Puerto Rico.

I appreciate the steps Puerto Rico 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. We remain available to provide technical assistance regarding additional issues that you identify. We will schedule another 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 Valeria Ford (Valeria.Ford@ed.gov) or Patrick Rooney (Patrick.Rooney@ed.gov) of my staff.

Sincerely,

Kerri L. Briggs, Ph.D.
Acting Assistant Secretary

Enclosure

cc: Governor Aníbal Acevedo Vilá
Waldo Torres Vázquez

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

2.0 – ACADEMIC ACHIEVEMENT STANDARDS

1. Performance level descriptors for Science, grade 8.
2. Performance level descriptors for Spanish at grades 3-8 and 11.
3. Performance level descriptors for the English as a second language assessment aligned to grade-level content standards.
4. Description of content-based competencies associated with the Basic level for the alternate assessment and cut scores for that level.

4.0 – TECHNICAL QUALITY

1. Interpretation or analysis to accompany data summaries of the inter-correlations of subdomains.
2. An analysis of the efficacy and validity of accommodations for Las Pruebas de Aprovechamiento Académico (PPAA).
3. An analysis of consequential and concurrent validity for the PPAA.

5.0 – ALIGNMENT

1. A detailed plan to address gaps identified from the alignment study.
2. Administration of an assessment aligned to academic content standards by April 2007.
3. Evidence that the Depth of Knowledge (DOK) level of the items matches the DOK level of the academic content standards (rather than writing items at a range of DOK levels) and that the full range of knowledge, skills, and abilities described in the academic content standards is covered on the tests.
4. Documentation for the alignment of non-academic indicators as components of the score on Las Pruebas Puertorriqueñas de Evaluación Alterna (PPEA).
5. A plan to review and maintain alignment over time.

6.0 – INCLUSION

1. An expansion of linguistic accommodations for limited Spanish proficient (LSP) students, such as English versions and simplified Spanish versions of the mathematics and science assessments.
2. An explanation for the apparent exclusion of students eligible to take the PPEA.
3. Clarification of the eligibility criteria concerning age for participation in the PPEA.

7.0 – REPORTING

1. Description of the weighting procedure used to derive PPEA scores.
2. Reports should include definitions of the proficiency levels in the individual content areas.

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