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

January 19, 2001


TO: Chief State School Officers

FROM: Michael Cohen
Assistant Secretary for Elementary and Secondary Education

SUBJECT: Review of State Assessment Systems for Title I

On this final day of the Clinton Administration, I would like to update you on our review of State final assessment systems under Title I. As you know, ensuring that States meet these requirements has been a top priority of mine, as well as of Secretary Riley. These requirements provide the foundation for the largest Federal elementary and secondary education program, and are a critical element in the framework for education reform in virtually every State and local school system. Their effective implementation is crucial to the effectiveness of Title I and to efforts nationwide to improve academic achievement for all students.

I want to thank each of you and your staffs for the tremendous effort, cooperation and patience you have demonstrated during this review process. Every State met the deadline for submitting descriptions of its assessment system. The review of these materials involved significant amounts of staff time in each State as well as in our office, and a good deal of communication and cooperation between State and Education Department staff. This effort was important so that we could be sure we fully understood, in some detail, each State's assessment system, the progress it had made, and the obstacles and challenges it faced.

In making final decisions, I have tried to make sure that we (1) remained focused on our primary objective of helping each State fully meet the Title I requirements; (2) took an evenhanded and consistent approach among the States even while recognizing significant differences among them; and (3) tried, whenever possible, to help each State meet the requirements in a fashion that was most consistent with its own needs, framework and approach to standards, assessments and accountability.

As of today, I have made decisions on 34 States. The remainder are still under review and that process will continue without interruption during the change in Administration. For a number of the remaining States, our staff is working with State staff to ensure we have complete information on the State assessment system. I expect that decisions on a number of additional States will be made in the next several weeks, and that the entire process will be completed by early Spring.

The chart below summarizes the decisions that have been made.


Number of States


Full Approval

11 States

Delaware, Indiana, Kansas, Louisiana, Maryland, Massachusetts, Pennsylvania, Rhode Island, Vermont, Virginia, Wyoming

Conditional Approval

(Full Approval expected by Spring 2001)

6 States

Kentucky, Missouri, North Carolina, Oregon, , Texas, Washington

Timeline Waiver

14 States

Colorado, Connecticut, Georgia, Hawaii, Maine, Mississippi, Nebraska, Nevada, New Hampshire, New York, North Dakota, Ohio, South Carolina, South Dakota

Compliance Agreement

3 States

California, West Virginia, Wisconsin

Still Under Review

18 States

Alabama, Alaska, Arizona, Arkansas, District of Columbia, Florida, Idaho, Illinois, Iowa, Michigan, Minnesota, Montana, New Jersey, New Mexico, Oklahoma, Puerto Rico, Tennessee, Utah,

Issues Facing States

Over the course of the reviews, we have identified a number of significant issues and challenges that States frequently faced in meeting the Title I requirements. In many cases, we had to request changes in State policy or practice, or had to allow states additional time by waiving the Spring 2001 implementation deadline, in order for States to meet the requirements.


Number of States


Inclusion of limited English proficient students

22 States

California, Connecticut, Delaware, Georgia, Kansas, Kentucky, Louisiana, Massachusetts, Maryland, Maine, Mississippi, North Carolina, North Dakota, Nebraska, New Hampshire, Nevada, Pennsylvania, Rhode Island, South Dakota, Virginia, Wisconsin, West Virginia

Inclusion of students with disabilities

14 States

California, Connecticut, Indiana, Kansas, Missouri, New Hampshire, New York, Oregon, South Carolina, South Dakota, Texas, Vermont, Wisconsin, West Virginia

Disaggregated Reporting

30 States

California, Colorado, Connecticut, Delaware, Georgia, Hawaii, Indiana, Kansas, Kentucky, Louisiana, Massachusetts, Maryland, Maine, Mississippi, Missouri, New York, North Carolina, North Dakota, Nebraska, New Hampshire, Nevada, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Vermont, Virginia, Wisconsin, West Virginia

Finish Standards-based System

11 States

California, Colorado, Georgia, Hawaii, Mississippi, North Dakota, Nebraska, Nevada, South Carolina, South Dakota, West Virginia

Nearly all of the States were required to take some additional steps in order to include all students, especially limited English proficient and students with disabilities, in the State's assessment and accountability system. When these reviews began, I knew that this would be a challenge for most States but also that it was not beyond their capacity to achieve. Further, compliance with this requirement was important because this is the vehicle for ensuring that schools, school districts, and States assume responsibility for educating every child to high standards.

For limited English proficient students, 22 States have needed to change their time based exclusion policy, monitor the local implementation of State policies, or include the results of limited English proficient students in the accountability system. There are other States that must develop policies for their new standards based systems to include limited English proficient students.

State policies and practices for students with disabilities have generally met the Title I requirements with the exception of reporting and including the results for the alternate assessments in the accountability system. There are, however, a few States that exclude too many students with disabilities from the State assessment system. My office has been working the Office of Special Education and Rehabilitative Services in the Department to ensure that Title I and IDEA requirements are being met. 14 States have needed to make changes to meet these requirements.

We have asked every State to monitor and report annually the exclusion rates for limited English proficient students and students with disabilities, so that we ensure sustained attention to including all students in the assessment and accountability system.

More than half the States had additional steps to take in order to meet the Title I requirements for disaggregating and reporting achievement data by all the specific categories required by the Title I statute. Almost every State was already producing school, district and State reports with some disaggregated data and meeting the Title I requirements typically meant adding information on additional population groups to State, district, and school reports. Parents, teachers, students and the community need to see how all students are achieving and disaggregated reports are one of the best ways to provide that information. 30 States are making changes to their reporting practices to conform to the Title I requirements.

There are a handful of States that have yet to complete their standards-based system. The high school component is the most common component that will not be finished for the 2000-2001 test administration. In most of these cases, especially where it was clear that the State had already implemented a standard-based assessment system in some grades, had a firm commitment to completing the work, and simply needed additional time, we waived the implementation deadline to permit the State to stay on its own schedule. States that were asked to enter a compliance agreement with us were more likely to be at the very early stages of shifting from the exclusive use of norm-referenced tests, and often lacked clear evidence that all parts of the State education governance structure were committed to meeting the Title I requirements. 7 States have a timeline waiver to finish their systems, 3 are entering into a compliance agreement. As the reviews are completed for the remaining States, there will probably be additional compliance agreements and timeline waivers to fully implement standards-based systems.

As you can imagine, there are some State specific issues that have emerged during the review. These range from the completion of technical manuals necessary for determining the validity and reliability of the assessment and, more seriously, a documented lack of alignment between a State's standards and its current assessment system.

One final area related to the Title I assessment requirements is approval of requests for Ed-Flex authority. As of today, 13 States have applied for Ed-Flex and 6 have been granted Ed-Flex authority. You may recall that to be eligible for Ed-Flex, a State must meet the Title I standards and assessment requirements, have implemented an accountability system that includes technical assistance and corrective actions in low-performing schools consistent with Title I, and have the authority to waive certain education requirements. Although I recognize that developing and implementing strong assessment and accountability systems has required significant effort, it is critical that strong accountability accompany the flexibility Ed-Flex affords.

In closing, I want to express my thanks for the opportunity to work so closely with you, your staff and your colleagues on so many issues during this past year, and for the past eight years that I have served in the Clinton Administration. I believe the federal/State partnership to improve education is stronger now than it was when we began, and that together we have made significant progress in improving American education. I hope that there will be many more opportunities to work with you in the future.

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This page last modified February 9, 2001 (sbw)