November 6, 2001
Honorable Elizabeth Burmaster
Superintendent of Public Instruction
Wisconsin Department of Public Instruction
P.O. Box 7841
125 South Webster Street
Madison, Wisconsin 53702
Dear Superintendent Burmaster:
I am writing to discuss the action plan entitled “Enhancing the Wisconsin Student Assessment System” that you submitted to my office on October 30. Because the plan addresses all of the changes needed to comply with the Title I assessment requirements, I agree to grant a two-year waiver of the timeline for completion of Wisconsin’s final assessment system. We understand that it will take some time to complete the revision of assessments to improve alignment with Wisconsin standards, and to complete the changes in policy and procedures needed to ensure an assessment and accountability system that includes all students; however, the revised assessment system must be fully implemented in the 2002-03 school year. I appreciate your cooperation in this endeavor.
The evaluation conducted by external peer reviewers and U.S. Department of Education staff found that, in order to fully meet the requirements of Section 1111(b)(3) and 1116(a) of the Elementary and Secondary Education Act, Wisconsin must address the following tasks:
- To support full inclusion of students with limited English proficiency and to ensure equity across schools and districts within the State, Wisconsin must adopt a policy that includes in State assessment all students who have been enrolled in a district for a full academic year, with clear criteria for exemption of individual students. Wisconsin needs a uniform standard for exempting individual students. The existing proficiency levels as defined in PI 13.03(3)(a-e) are not tied to performance on any standardized language assessment, and are interpreted inconsistently across the State. The State can either provide operational definitions, such as a score of 1 or 2 on the Language Assessment Scales, or monitor local decisions under the existing guidelines to ensure consistency. You might accomplish this objective through a standard setting activity that identifies cut scores on the most commonly used English proficiency tests for each of the levels of proficiency identified in PI 13.03(3).
- Title I requires a school accountability system that accounts for all students, including students who take alternate assessments and those not tested. School, district, and State profiles must include the performance of all students tested; profiles must also include the number of students exempted; and the performance of all students tested and the number of students exempted must be disaggregated insofar as statistically defensible.
- Wisconsin must improve the alignment of assessment(s) with State standards to ensure that assessment results provide a valid representation of school performance relative to State standards. Wisconsin’s decision to add items to the existing test and to incorporate local assessments as an indicator of school quality is an appropriate response to this requirement. The use of local assessments will require procedures to ensure and document technical quality sufficient for measures of school accountability.
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Our Title I office will monitor progress against the timeline you provided. Failure of Wisconsin to complete activities or products as scheduled in the first twelve months will make it necessary for this office to consider the other courses of action available to the Department. These actions include requiring Wisconsin to enter into a compliance agreement in order to remain eligible to receive Title I funds or initiating proceedings to withhold Title I funds from Wisconsin.
Our Title I office will be happy to work with you and your staff to achieve consistency between the Title I requirements and the Wisconsin assessment system. We wish you well in your efforts to improve school and student performance in your State.
Susan B. Neuman, Ed.D.