May 25, 2007
Dr. Mark K. McQuillan
Connecticut State Department of Education
165 Capitol Avenue
Hartford, CT 06145
Dear Commissioner McQuillan:
I am writing in response to Connecticut's request to amend its State accountability plan 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). The changes proposed are not aligned with NCLB and cannot be included in the State's accountability plan.
If you have any questions or need additional assistance to implement the standards, assessments, and accountability provisions of NCLB, please do not hesitate to contact Catherine Freeman (firstname.lastname@example.org) or Valeria Ford (email@example.com) of my staff.
Kerri L. Briggs, Ph.D.
Acting Assistant Secretary
cc: Governor M. Jodi Rell
Amendments to Connecticut's Accountability Plan
The following is a summary of the State's amendment requests. None of the requests is aligned with the statute and regulations and therefore cannot be approved.
Including Limited English Proficient (LEP) Students (Element 5.4)
The Department cannot approve Connecticut's request to alter its treatment of limited English proficient (LEP) students. The State proposed the following three alternatives in order of its preference:
- Alternative 1: Allow for LEP students in their first academic year in a U.S. school to be exempted from the State's mathematics assessment.
- Alternative 2: Exempt LEP students from the State assessments if they have been enrolled in a U.S. school for more than 10 school months and less than 20 school months and receive a score of 1 or 2 (the equivalent of Below Basic and Basic, respectively) on the English language proficiency test.
- Alternative 3: Exempt all LEP students from the reading/language arts and mathematics assessments until they have been in a U.S. school for three years.
Each of Connecticut's proposals seeks to extend this flexibility in ways that are not permitted under NCLB and go beyond the regulation that was released in September of 2006.
Provision of Supplemental Educational Services (SES) by LEAs in Improvement (Element 1.6)
At this time, the Department declines to approve Connecticut's proposal to allow 15 LEAs that are in need of improvement to be eligible to apply to provide supplemental educational services (SES) to eligible students in Title I schools under Section 1116(e) of Title I. The districts would apply to become providers through Connecticut's usual approval process. Under the Title I regulations, LEAs that are in need of improvement are not eligible to be SES providers. However, in the 2004-05 school year, the Secretary began a pilot program that allowed certain LEAs to be SES providers despite being in need of improvement. In her May 15, 2006, letter, the Secretary explained that she is currently reviewing the results of this pilot program and will be making a decision about the continuation or expansion of the program in the first part of June 2007.
Determination of adequate yearly progress (AYP) (Element 3.2)
Connecticut requested permission to submit a growth model proposal in the fall of 2007 to be applied to its AYP determinations beginning in the 2007-08 school year. The Department cannot approve Connecticut's request at this time. In the 2005-06 school year, the Secretary began a pilot program to allow up to 10 States to use a growth model in their AYP determinations. To date, the Department has conducted three peer reviews of growth model proposals and is currently evaluating the results of the last of those reviews. Consequently, the Department has not made a decision as to whether there will be any additional opportunities for States that did not take advantage of the first three opportunities to apply. If this does occur, Connecticut will be notified and will have the opportunity to submit a proposal for approval.
Implementation of consequences for schools and districts identified as "in need of improvement" (Element 3.2)
The Department cannot approve Connecticut's proposal of how consequences are implemented for schools identified as "in need of improvement" because it is inconsistent with the statute.