Wisconsin Assessment Letter

June 29, 2006

The Honorable Elizabeth Burmaster
Superintendent of Public Instruction
Wisconsin Department of Public Instruction
P. O. Box 7841
125 South Webster Street
Madison, WI 53707

Dear Superintendent Burmaster:

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 Wisconsin’s standards and assessments, which occurred February 15-16, 2006. The results of this peer review process indicated that additional evidence was necessary for Wisconsin 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 Wisconsin standards and assessment system is Approval Pending. This status indicates that Wisconsin’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 Wisconsin can address the outstanding issues by the next administration of its assessment system – that is, by the end of the 2006–07 school year.

Wisconsin’s system has a number of fundamental components that warrant the designation of Approval Pending. Specifically, the Department cannot approve Wisconsin’s standards and assessment system due to outstanding concerns with the alternate assessments including the alternate assessment for students with the most significant cognitive disabilities (the Wisconsin Alternate Assessment for Students with Disabilities, or WAA-SwD) and the Wisconsin Alternate Assessment for English Language Learners (WAA-ELL), and the technical quality, including validity and reliability. Please refer to the enclosure for a detailed list of the evidence Wisconsin must submit to meet the requirements for an approved standards and assessment system.

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

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 call Abigail Potts (abigail.potts@ed.gov) or Valeria Ford (valeria.ford@ed.gov)of my staff.


Henry L. Johnson


cc: Governor Jim Doyle
Mike Thompson
Margaret Planner
Lynette Russell
Maxine Hough

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


  1. Documentation of final adoption of science assessment framework once approved by the State superintendent.


  1. Final documentation that describes procedures used for the standard setting, the qualifications of the panelists and formal approval of the final performance level descriptors for the WKCE-CRT;
  2. Clarification that the cut scores and performance level descriptors were defined for each grade level (3-8, and 10) or grade clusters for the WAA-SwD;
  3. Clarification related to the WAA-SwD regarding what data were used to produce the bookmark booklets for the 2004 standard setting since fall 2005 was the first administration of assessments at all grades;
  4. Clarification as to what science assessment (NRT or CRT) was administered in fall 2005 and whether or not that assessment was based on a new scale;
  5. Formally approved academic achievement standards for the science general assessment once completed in spring 2006;
  6. Performance level descriptors for reading, mathematics and science for each academic achievement level for the WAA-SwD, not just for the proficient level; and
  7. Documentation of the process and approval of the academic achievement standards for the WAA-ELL.


  1. Documentation that the ELL-API’s are equivalent to the grade level achievement standards for the WKCE-CRT in order to demonstrate that the WAA-ELL is comparable to the WKCE-CRT;
  2. Description of how the WAA-SwD is administered and scored;
  3. Description of how the WAA-ELL is administered and scored to ensure standardization of the assessment and validity of the results; and
  4. Clarification of the use of Spanish or any other native language alternate assessment in Wisconsin’s assessment system.


  1. Appropriateness of the decisions based on the results of the WAA-ELL and evidence that the assessment system produces the intended consequences;
  2. Scoring and reporting structures of the WKCE-CRT consistent with the sub-domains in the WMAS;
  3. Report of validity evidence once it is completed;
  4. Results from standard setting once it is complete for the fall 2005 WKCE-CRT and WAA-SwD assessments;
  5. Documentation on the validity of the scores resulting from accommodated administrations of the WKCE-CRT;
  6. Documentation describing how Wisconsin uses DIF when reviewing items, how sensitivity reviewers were trained to review items, and what is done with their recommendations. Also, Wisconsin needs to provide evidence of ways it collects and uses information/data to improve validity of its assessments;
  7. Reliability information for the WKCE-CRT and the WAA-SwD;
  8. Updated Technical Manuals for the WKCE-CRT and WAA-SwD;
  9. Scoring guidelines for the WKCE-CRT if a student uses an accommodation that invalidates the score, how to handle multiple marks, and other scoring irregularities; and
  10. Statute or policy regarding local control that prevents State staff from monitoring test administrations.


  1. Documentation of alignment between WMAS and WKCE-CRT;
  2. Documentation that the grades 3-8 and 10 WAA-SwD assessments are aligned to the assessment framework. The new alignment study will also need to address all the critical elements in Section 5; and
  3. Documentation regarding the WAA-ELL’s alignment to grade-level content.


  1. Documentation, such as agendas and participation lists, to show that the accommodation workshops took place;
  2. Criteria used to determine if a translator is “qualified” and guidelines provided for translation;
  3. Documentation to demonstrate the State does not have a policy to allow assessment in a language other than English longer than the three years; and
  4. Policies related to the inclusion of migrant students.


  1. Final reports for the 2005/2006 assessments;
  2. Revised interpretation guide for the 2005-2006 WKCE-CRT;
  3. Inclusion of specific strands or domains of the API on student reports and an interpretive guide for these reports;
  4. Number of students tested in each achievement category for each subgroup and for each assessment; and
  5. Innstructions provided to districts as to when and how parent reports are to be disseminated.


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