September 29, 2003
The Honorable Raymond J. Simon
General Education Division
Arkansas Department of Education
Four State Capitol Mall, Room 304 A
Little Rock, Arkansas 72201 -1071
Dear Director Simon:
I am writing to follow up on your letter of August 5th in which you submitted two amendments to the Arkansas accountability plan. As we discussed, Arkansas may apply confidence interval to the determination of adequate yearly progress. With this amendment, Arkansas may apply a confidence interval of 0.5 of a standard deviation to its starting points and annual measurable objectives. Please update your accountability plan, including the actual starting points, annual measurable objectives, and intermediate goals, and submit it to your state contact (Grace Ross) so that the most up-to-date plan is available and on the Department's website.
With respect to the other amendment request, Arkansas wishes to compare the current year assessment results with an average of the most recent three years' results (including the current year) and use the most favorable results to make school AYP determinations. While Arkansas may use this application of uniform averaging this year, it must provide the Department information on the impact and implications of this approach.
In providing this information, there are at least two critical questions that should guide your collection and analysis of the data with respect to this issue: 1) How many schools and districts made AYP because this procedure was applied? 2) Our understanding of this approach is that the same procedure will be applied to each subgroup within a particular school.
We received your preliminary analysis showing the effect of the uniform averaging procedure in this manner. We want to. continue monitoring this process. Please provide the final analysis by November 1, 2003, following the data analysis for the 2002-03 school year. Specifically, we want to know how many schools and districts made AYP because this procedure was applied? We would like to know how many schools would have made AYP if only the three-year data rule was applied; and how many more made AYP by virtue of using the current year's data alone. Please note that we may find it necessary to collect this information for two school years; we will notify you about this possibility, if needed, during the 2003-04 school year. If you have any questions about this issue, please contact Kerri Briggs at 202-205-2540 or Grace Ross at 202-260-0967.
The Secretary has stated repeatedly that States should be granted maximum flexibility in the implementation of NCLB provided this flexibility does not undermine the goals of NCLB. I appreciate your efforts to ensure that this balance is appropriately achieved in Arkansas.
Ronald J. Tomalis
Chief of Staff to the Under Secretary