Washington DC Assessment Letter

June 29, 2006

TThe Honorable Clifford B. Janey
Superintendent of Public Schools
District of Columbia Public Schools
825 North Capitol Street, N.E.
Suite 900
Washington, DC 20002

Dear Superintendent Janey:

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). For the District of Columbia Public Schools (DCPS), this review examined evidence of DCPS’ standards and assessment system under the Title I requirements in both the Improving America’s Schools Act of 1994 (IASA) and 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.

The peer review of DCPS’ standards and assessment system occurred May 10-12, 2006. The results of this peer review indicate that additional evidence is necessary for DCPS to meet the statutory and regulatory requirements of Section 1111(b)(1) and (3) of the ESEA under both the IASA and NCLB.

With respect to the Title I standards and assessment requirements under NCLB, as you will recall, the Department laid out new approval categories in a 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 DCPS’ standards and assessment system is Approval Pending. This status indicates that DCPS’ standards and assessment system administered in the 2005–06 school year has 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 DCPS can address the outstanding issues by the next administration of its assessment system, that is, by the end of the 2006–07 school year.

DCPS’ system has two fundamental components that warrant the designation of Approval Pending. Specifically, the Department cannot approve DCPS’ standards and assessment system due to outstanding concerns with the alignment of the alternate assessment based on alternate achievement standards (the District of Columbia Alternate Assessment, or DC CAS-Alt) to grade-level content standards and the technical quality of all assessments, particularly the reliability and the appropriateness of accommodations. Please refer to the enclosure for a detailed list of the evidence DCPS must submit to meet the requirements for an approved standards and assessment system.

Accordingly, DCPS is placed under Mandatory Oversight, pursuant to 34 C.F.R. §80.12. As you know, DCPS has already been designated a “high-risk grantee” under 34 C.F.R. §80.12, and special conditions addressing other matters have been placed on DCPS’ grant awards. Based on the Mandatory Oversight status, there will be additional specific conditions placed on DCPS’ fiscal year 2006 Title I, Part A grant award. DCPS must provide, not later than 25 business days from receipt of this letter, a plan and detailed timeline for how the District will meet the remaining requirements to come into full compliance by the end of the 2006–07 school year. Beginning in September 2006, the District of Columbia must also provide bi-monthly reports on its progress implementing the plan. If, at any time, the District of Columbia 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 the District of Columbia’s fiscal year 2006 Title I, Part A administrative funds, which will then revert to local educational agencies (schools in DCPS and eligible charter schools) in the District of Columbia.

As you know, DCPS has not yet received approval of its standards and assessment system under IASA. Based on the recommendations of the peer reviewers and the evidence you have provided, we believe that DCPS administered an assessment system in grades 3–8 and high school in 2005–06 that the evidence to date suggests is fully compliant with the statutory and regulatory requirements under IASA, which are more limited than those under NCLB. We recognize, however, that there are certain elements that cannot be completed by July 1, 2006, due to the nature of assessment development, such as setting academic achievement standards. The enclosure lists the evidence that is needed to establish compliance with the IASA requirements. In the plan and timeline requested above, DCPS should ensure that this evidence is submitted by December 1, 2006. Please know that, if DCPS does not meet the timeline for submitting this evidence, the Department will withhold, as required by section 1111(g)(1) of the ESEA, 25 percent of DCPS’ Title I, Part A State administrative funds for fiscal year 2006.

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 request reconsideration of the conditions, please do not hesitate to contact Catherine Freeman (catherine.freeman@ed.gov) or Sue Rigney (sue.rigney@ed.gov) of my staff.

Sincerely,

Henry L. Johnson

Enclosure

cc: Mayor Anthony Williams
Dr. Robert C. Rice

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

1.0 ACADEMIC CONTENT STANDARDS

  1. Confirmation that the DCPS content standards development process involved special educators and educators who work with students with limited English proficiency.

2.0 ACADEMIC ACHIEVEMENT STANDARDS

  1. Draft performance level descriptors for science.
  2. Formal adoption of cut scores and achievement level descriptors associated with each academic level for the DC CAS in English language arts and mathematics for all grades assessed.
  3. 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.
  4. Current data indicating (1) the number of students with disabilities statewide and, of these, (2) the number who participated in the general assessment and (3) the number who participated in the alternate assessment.
  5. Detailed description of the standard setting procedures, including evidence that special educators and educators who work with LEP students were included in the standard-setting panels.

4.0 TECHNICAL QUALITY

  1. A completed technical report that includes:
    1. Definitions of the purposes the DC CAS is designed to serve and evidence of how it ascertains that decisions based on DC CAS results are appropriate and consistent with the intended purposes.
    2. Evidence that it has evaluated the relationships between DC CAS performance and other relevant, external variables.
    3. Evidence that its assessments yield reliable scores that are consistent with the structures inherent to the state’s academic content standards.
    4. Evidence of how it is employing judgmental and empirical methods to evaluate potential bias of items that appear on current DC CAS test forms. This evidence must include a description of the process, the participants, and the outcomes of these reviews.
    5. A design or results from studies that address the consequences of implementation of its assessment system.
  2. Data showing that the accommodations permitted do not fundamentally alter the construct being assessed. Evidence that its allowable accommodations, and especially those accommodations that result in non-standard conditions, yield meaningful results that can be meaningfully aggregated with those from non-accommodated tests.
  3. Quality control requirements for scoring and analyzing results for the DC CAS.
  4. Description of a system for monitoring and improving the on-going quality of its assessment system (e.g., use of results from the DCPS test administration monitoring protocol; the role of its TAC in suggesting annual improvements, etc.).

5.0 ALIGNMENT

  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 encourages the teaching of advanced skills, confirmation that the assessments reflect the same degree and patterns of emphasis as the state’s 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.
  4. Confirmation that DCPS is field-testing an adequate number of items to support the development of aligned forms over time.

6.0 INCLUSION

  1. Clarification of assessment procedures for Homebound students.
  2. Revised guidelines for participation in the DC CAS-Alt that clearly state that this assessment is restricted to students with the most significant cognitive disabilities.

7.0 REPORTS

  1. Sample summary reports that include performance data for Economically Disadvantaged and Migrant, if applicable.
  2. An interpretive guide for parents and educators to accompany DC CAS reports.
  3. 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.
  4. A sample item analysis report.
  5. A description of how DCPS ensures the confidentiality of student records in its student information management system and how it ensures that its testing vendor also protects the confidentiality of student records.

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

2.0 ACADEMIC ACHIEVEMENT STANDARDS

  1. Formal adoption of cut scores and achievement level descriptors associated with each academic level for the DC CAS in English language arts and mathematics for all grades assessed.
  2. Detailed description of the standard setting procedures, including evidence that special educators and educators who work with LEP students were included in the standard-setting panels.

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