A r c h i v e d  I n f o r m a t i o n

June 8, 2000


TO: Chief State School Officers

FROM: Michael Cohen, Assistant Secretary

SUBJECT: Review of State Assessment Systems for Title I

I would like to update you on our review of State final assessment systems under Title I. There have been a number of significant developments since I last wrote to you on this topic in April.

I am pleased to report that two of the States that participated in the February pilot review have now successfully completed the review process. Both Wyoming and Kentucky deserve congratulations and thanks for their leadership in developing and implementing high quality assessment systems aligned with their State standards. I have approved Wyoming's final assessment system as meeting all of the relevant requirements of Title I, without condition or qualification. I have also approved Kentucky's assessment system, subject to the condition that it make two changes by its 2000-2001 test administration to bring its practice in line with key Title I requirements.

I am also pleased to report that in May eleven additional States submitted evidence necessary for us to evaluate their assessment systems. The States are: California, Connecticut, Delaware, Kansas, Louisiana, Missouri, New Hampshire, Oregon, Pennsylvania, Tennessee, and Washington. Final decisions on these systems will be made prior to June 30, 2000.

Based on the evidence we have seen to date, it is becomingly increasingly clear that few State policies or practices for including limited English proficient (LEP) students in assessments meet the Title I requirements. As you are aware, Title I requires that LEP students be included in the State assessment and accountability systems and that achievement results be disaggregated for those students. I recognize the challenges these requirements may present, but firmly believe that full inclusion is not beyond the capacity of State assessment and accountability systems. Enclosed is another copy of the summary of the inclusion requirements for your information.

At this point in the review process, it is now possible to give you a clear idea of the range of possible outcomes a State can anticipate as a result of our review of your submission of evidence of a final assessment system under Title I.

Determining whether a waiver or a compliance agreement is most appropriate for a State will, of necessity, be a judgment call. In general, a waiver will be granted if the State has a track record of success in implementing its system to date; has a clear plan with a definite timeline for completing the development and implementation of its assessment system and for complying with Title I requirements; and has the capacity, resources, and support to carry out the plan and thus meet the requirements.

A compliance agreement will be necessary in cases where it is determined, upon review of the evidence, that the State assessment system will not be completed in a timely manner; that significant requirements have not been met; that the State does not have a clear and feasible plan underway for meeting the requirements; and that the State has not demonstrated a track record of progress or successful implementation. The track record of States with previously granted timeline waivers, including their record of meeting timelines and reporting requirements, will be taken into consideration.

In making these decisions on final assessments, our primary concern will be to select the course of action that will best help the State complete the development and implementation of a high quality assessment system that meets each State's needs and that complies with the Title I requirements.

The next deadline for submitting evidence of final State assessment systems is July 1. Approximately ten States have informed us of their intent to submit materials by July 1, and I encourage any State that can meet this deadline to do so. Let me remind you that the deadline for submitting documentation of your State's final assessment system is October 1. Each State must submit its evidence by that date, even if its system and corresponding evidence are not complete. Failure to meet this deadline is likely to result in our withholding a portion of your State's Title I administrative funds starting October 1 and continuing until the documentation is received.

If you would like to discuss this further, please do not hesitate to contact me. I will be attending the Milken Family Foundation National Education Conference in Los Angeles on June 27-28 and am available to discuss this issue and others with you if you are participating in that meeting. I also plan to be at the Council of Chief State School Officers' Summer Institute in Wilmington, Delaware on July 23-24 and would be pleased to discuss the issues with you there as well.

Please be assured that it is my intent to work closely with each State as these decisions are made to ensure that the best interests of the students and schools served by Title I are taken into account, and to support States' progress in continuing to implement standards-based reforms for all students.


This memorandum is being sent to you via Chiefline and through the regular mail. It will also be sent electronically to State Assessment and Title I Directors.

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This page last modified July 20, 2000 (edg)