July 30, 2009
The Honorable Judy Jeffrey
Director of Education
Iowa Department of Education
Grimes State Office Building
East 14th & Grand Streets
Des Moines, Iowa 50319-0146
Dear Director Jeffrey:
On behalf of Secretary Duncan, I want to thank you for your hard work in implementing the Elementary and Secondary Education Act of 1965 (ESEA). As you may know, the Secretary is traveling the country and listening to representatives of states and districts, as well as other stakeholders, talk about the ways in which the ESEA can be improved. These conversations will inform the next reauthorization of the statute. In the meantime, we will push towards our reform goals under the authority of, and in accordance with, the existing statute and regulations.
Specifically, I am writing in response to Iowa’s request to amend its state accountability plan under Title I of the ESEA. Following discussions between the U.S. Department of Education (the Department) and your staff, you made changes to Iowa’s accountability plan, which are now included in the amended state accountability plan that Iowa submitted to the Department on July 16, 2009. I am pleased to approve Iowa’s amended plan, which we will post on the Department’s website. A summary of Iowa’s requested amendments is enclosed with this letter. As you know, any further requests to amend Iowa’s accountability plan must be submitted to the Department for review and approval as required by section 1111(f)(2) of Title I of the ESEA.
Please also be aware that approval of Iowa’s accountability plan for Title I, including the amendments approved herein, does not indicate that the plan complies with Federal civil rights requirements, including Title VI of the Civil Rights Act of 1964, Title IX of the Education Amendments of 1972, Section 504 of the Rehabilitation Act of 1973, Title II of the Americans with Disabilities Act, and requirements under the Individuals with Disabilities Education Act.
I am confident that Iowa will continue to advance its efforts to hold schools and school districts accountable for the achievement of all students. If you need any additional assistance to implement the standards, assessment, and accountability provisions of the ESEA, please do not hesitate to contact Patrick.Rooney@ed.gov or David.Harmon@ed.gov of my staff.
Joseph C. Conaty
cc: Governor Chet Culver
Amendment to Iowa’s Accountability Plan
The following is a summary of Iowa’s amendment requests. Please refer to the Department’s website www.ed.gov/admins/lead/account/stateplans03/index.html for Iowa’s complete accountability plan.
The following amendments are aligned with the statute and regulations.
Including students with disabilities in adequate yearly progress (AYP) determinations (Element 5.3)
Revision: Iowa will use the “proxy method” (option 1 in the Department’s guidance dated December 2005) to take advantage of the transition flexibility offered by the Department pursuant to its authority under 34 C.F.R. § 200.20(g) (see http://www.ed.gov/policy/speced/guid/modachieve-summary.html) for calculating AYP for the students with disabilities subgroup for the 2008–09 school year. If a school or district misses AYP solely on the basis of the students with disabilities subgroup, a proxy of students with disabilities equivalent to 2.0 percent of all students assessed will be added to the actual percentage of students with disabilities in the school or district that was proficient or advanced. Iowa will then use this adjusted percent proficient to re-examine whether the school or district made AYP for the 2008–09 school year. The actual percentage proficient will be reported to parents and the public.
Graduation rate (Element 7.1)
Revision: Iowa revised its graduation rate calculation from a three-year to a four-year adjusted-cohort measure. The rate is calculated by dividing the number of on-time graduates in 2008 by the 9th-grade enrollment in fall 2004 minus the number of students who transferred out plus the number of students who transferred into a school or district. The formula allows an adjustment for special education students who take longer to graduate and early graduates. The graduation rate target will remain the same as in previous years: 91.3 percent. In order to make AYP, a school or district must have a graduation rate of 91.3 percent or show improvement in the three-year rate in 2008 compared to the three-year rate in 2007.
Please note that the Department is approving the graduation rate goal and targets for calculating AYP for the 2008–09 school year only. Iowa must submit information about its goal and targets for future years to the Department for peer review, as required by 34 C.F.R. § 200.19(b)(6). In addition, although the graduation rate is acceptable as Iowa’s transitional graduation rate under 34 C.F.R. § 200.19(b)(2), Iowa will be required to revise its graduation rate that it will use for reporting purposes along with results of assessments administered in 2010–11 and for AYP determinations based on assessments administered in 2011–12 so that it is consistent with 34 C.F.R. § 200.19(b)(1).