June 12, 2007
The Honorable Lana C. Seivers
Commissioner of Education
Tennessee Department of Education
Sixth Floor, Andrew Johnson Tower
710 James Robertson Parkway
Nashville, Tennessee 37243-0375
Dear Commissioner Seivers:
I am writing in response to Tennessee'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). Following our discussions with your staff, the approved changes are now included in an amended State accountability plan that Tennessee submitted to the Department on June 7, 2007, which we will post on the Department's website. A summary of the amendments submitted for the 2006-07 school year is enclosed with this letter. As you know, any further requests to amend the Tennessee accountability plan must be submitted to the Department for review and approval as required by section 1111(f)(2) of Title I.
Please also be aware that approval of Tennessee's accountability plan for Title I, including the amendments approved above, 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 Tennessee 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 NCLB, please do not hesitate to contact Patrick Rooney (Patrick.Rooney@ed.gov) or Zollie Stevenson (Zollie.Stevenson@ed.gov) of my staff.
Kerri L. Briggs, Ph.D.
Acting Assistant Secretary
cc: Governor Phil Bredesen
Amendments to the Tennessee Accountability Plan
The following is a summary of the State's amendment requests. Please refer to the Department's website (www.ed.gov/admins/lead/account/stateplans03/index.html) for the complete Tennessee accountability plan.
The following amendments are aligned with the statute and regulations.
Including all schools in adequate yearly progress (AYP) determinations (Element 1.2)
Revision: For schools with fewer than 10 tested students, Tennessee will sum student assessment results over 2 to 3 years until there are at least 10 students in the tested population.
Including alternative schools in AYP determinations (Element 1.2)
Revision: Tennessee will use the event dropout rate as the additional indicator for alternative schools with secondary grades. For some alternative high schools that serve students with disciplinary problems, the school is unable to graduate students according to State law. As a result, alternative schools do not have graduation rates. Therefore, Tennessee will calculate the event dropout rate for these schools as the Other Academic Indicator. Any school with an event dropout rate of 5 percent or less will have made AYP.
Growth model calculations (Element 3.2)
Revision: Tennessee will calculate separate accountability determinations for reading/language arts and mathematics when using its growth model to calculate AYP. All subgroups will be required to meet the growth model annual measurable objective in reading/language arts in order for the school to make growth for reading/language arts. The same will be true for mathematics.
Elimination of Katrina subgroup (Element 5.1)
Revision: Tennessee will remove the separate subgroup for students displaced by Hurricanes Katrina and Rita for reporting and accountability purposes.
Including students with disabilities in AYP (Element 5.3)
Revision: Tennessee will use the "proxy method" (option 1 in our guidance dated December 2005) to take advantage of the interim flexibility regarding calculating adequate yearly progress (AYP) for the students with disabilities subgroup (refer to: www.ed.gov/policy/elsec/guid/secletter/070207.html). Tennessee will calculate a proxy to determine the percentage of students with disabilities that is equivalent to 2.0 percent of all students assessed. For this year only, this proxy will then be added to the percentage of students with disabilities who are proficient. For any school or district that did not make AYP solely due to its students with disabilities subgroup, Tennessee will use this adjusted percentage proficient to re-examine if the school or district made AYP for the 2006-07 school year.
Graduation rate (Element 7.1)
Revision: For four early college/middle college high schools in Tennessee, the State will define the "standard number of years" for calculating the graduation rate as 5 years and one summer. These four schools, Middle College High School at Nashville State Community College, Chattanooga State Middle College High School, Memphis City Middle College High School, and Williamson County Middle College High School, are student self-selected schools with an integrated high school and postsecondary curriculum. Students follow a 5-year trajectory leading to an associate's degree or acceleration toward a 4-year college degree in addition to receiving a regular high school diploma.
The following amendment is not aligned with the statute and regulations and is therefore not approved.
Confidence interval on growth model calculations (Element 3.2)
The Department cannot approve Tennessee's proposal to apply a 68 percent confidence interval to the percentages of students either scoring proficient or on track to proficiency as part of Tennessee's growth model. The Department has brought together two panels of outside experts to review State growth model proposals and to make recommendations to the Secretary regarding the growth model pilot. As noted by the first peer review panel in its "cross cutting issues" document (refer to: /www.ed.gov/admins/lead/account/growthmodel/cc.doc), "the justification for employing confidence intervals around the AYP status target is based largely on reducing the impact of score volatility due to changes in the cohorts being assessed from one year to another, and thus reducing the potential for inappropriately concluding that the effectiveness of the school is improving or declining. Under the growth model the issue of successive cohorts is no longer in play since we are measuring the gains over time that are attained by individual students." Based on the peers' logic, the Department declines to approve Tennessee's application of a confidence interval on its growth model calculations.