Washington DC Assessment Letter

June 29, 2007

Michelle Rhee
Acting Chancellor of DC Public Schools
District of Columbia Public Schools
825 North Capitol Street NE
Suite 900
Washington, DC 20002

Dear Chancellor Rhee:

I am writing regarding our review of the District of Columbia’s standards and assessment system 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 the District of Columbia’s efforts to monitor student progress toward challenging standards.

External peer reviewers and Department staff evaluated the District of Columbia’s submission and found, based on the evidence received, that it did not meet all the statutory and regulatory requirements of section 1111(b)(1) and (3) of the ESEA. I know that my staff has discussed the results of this review with your staff. However, I want to take this opportunity to enumerate the evidence that the District of Columbia must provide in order to have a fully compliant system under NCLB.

Specifically, we still have concerns with technical quality and alignment of the District of Columbia Comprehensive Assessment System (DC CAS) to the District of Columbia’s grade-level academic content standards and academic achievement standards. Similarly, we have concerns with technical quality and alignment of the District of Columbia’s alternate assessment based on alternate academic achievement standards (the District of Columbia Comprehensive Assessment System Alternate, or DC CAS-Alt) to grade-level content standards. There are also issues related to the academic achievement standards for both the DC CAS and DC CAS-Alt, as well as documentation of inclusion on the DC CAS-Alt and verification that the District of Columbia has met reporting requirements. The complete list of evidence needed to address these concerns is on the last pages of this letter.

We know that the District of Columbia will complete work within the next few months that may result in a fully approved standards and assessment system under NCLB. Therefore, we are not assigning an approval status to the District of Columbia’s system at this time. Because that system is not fully approved, however, we will place a condition on your fiscal year 2007 Title I, Part A grant award.

To ensure that all remaining work occurs in a timely manner, I request that, within two weeks of the date of this letter, you provide my staff with a detailed timeline for how and when the District of Columbia will satisfy the remaining requirements. As part of that timeline, please indicate when you will submit evidence as it becomes available. We will review that evidence and schedule an additional peer review, if necessary.

If the District of Columbia is unable to resolve the remaining issues with its assessment system by the agreed upon timeline, 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 (www.ed.gov/admins/lead/account/stateplans03/).

Also enclosed with this letter are detailed comments from the peer review team that evaluated the District of Columbia’s assessment materials. I hope you will find the reviewers’ comments and suggestions helpful.

We look forward to working with the District of Columbia to support a high-quality standards and assessment system. If you would like to discuss this further, please do not hesitate to call Sue Rigney (202-260-0931) or Patrick Rooney (202-205-8831) of my staff.


Kerri L. Briggs, Ph.D.


cc: Mayor Adrian Fenty
Deborah Gist
Bill Caritj

Summary of Additional Evidence that DCPS Must Submit to Meet NCLB Requirements for the DCPS Standards and Assessment System


  1. Evidence of the formal adoption of cut scores and alternate achievement level descriptors for the DC CAS-Alt in English language arts and mathematics for all grades assessed.
  2. The final standard setting report for the DC CAS-Alt following the standard setting process scheduled for June 2007. This document must include a detailed description of the standard setting procedures, including the qualifications of the panelists.


  1. A completed technical manual for the DC CAS-Alt that confirms the validity and reliability of results.
  2. Additional evidence of validity and reliability for the DC CAS, including
    • Evidence that its assessments yield reliable scores that are consistent with the structures inherent to the state’s academic content standards. Specifically, validity and reliability evidence for the reporting of strands is inadequate.
    • Evidence that it has evaluated the relationships between DC CAS performance and other relevant, external variables. This is essential to show convergent and divergent validity.
  3. Evidence of its policy and of the implementation of its policy for allowing only those accommodations that do not fundamentally alter the construct being assessed. The state must provide evidence that students who are assessed under non-standard testing conditions (e.g., reading the reading test to students) are considered non-participants in the assessment system for AYP calculations.
  4. Evidence of an on-going system of quality review and improvement for the assessment system. For example using available data: evidence regarding data analyses to examine reliability of strands; investigation of convergent and divergent validity through inter-correlation of math and reading strand scores; surveys and focus groups to examine unintended consequences of the assessment system; a judgmental bias review of the items field tested in spring 2007 to eliminate any unsuitable items from the pool, and; factor analysis to examine the integrity of the strands.


  1. Results from a completed independent alignment study for the DC CAS that addresses: content and skill domains represented in the content standards, the inclusion of coherent and rigorous content that encourage the teaching of advanced skills, confirmation that the assessments reflect the same degree and patterns of emphasis as DCPS’ content standards.
  2. Clarification regarding the role of the “power standards,” including whether they have been adopted by the SEA, and their relation to the structure of the assessment.
  3. Results from a completed external alignment study for the DC CAS-Alt or other data confirming the alignment of the DC CAS-Alt with grade-level content standards.


  1. Revised participation policy that permits the exclusion of students from testing only on the basis of medical emergency and evidence that test administration instructions have been changed to reflect the revised policy.


  1. Sample assessment reports at the school and district level that include performance data for all required subgroups.
  2. An Individual Student Report for the DC CAS that includes the descriptor or other information explaining the meaning of the achievement level that corresponds to a student’s score.
  3. An Individual Student Report for the DC CAS-Alt that includes the descriptor or other information explaining the meaning of the achievement level that corresponds to a student’s score.

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