April 18, 2001
Honorable Shirley J. Holloway
Commissioner of Education
Alaska Department of Education
801 West 10th Street, Suite 200
Juneau, Alaska 99801-1894
Dear Commissioner Holloway:
It was a pleasure speaking with you about the outcome of the Department's review of Alaska's final assessment system under the Title I requirements of the Elementary and Secondary Education Act. We appreciate the effort Alaska made to prepare for the review and hope that the process provides useful feedback that will support your State's efforts to monitor student progress toward challenging standards.
Alaska has made significant progress in moving towards a standards-based assessment system. We were pleased to learn that your standards-based assessments and high school graduation qualifying examinations are being administered in reading, mathematics, and writing on an annual basis. Alaska meets the requirements of the Title I statute on one of the five final assessment review criteria, the establishment of a full assessment system.
However, the evaluation conducted by external peer reviewers and U.S. Department of Education (ED) staff found that, in order to fully meet the requirements of Title I, Alaska must:
- Submit evidence that performance standards have been developed and implemented and are aligned with Alaska content standards and the State's standards-based assessment program. Cut scores associated with performance levels are also needed.
- Develop native language assessments and/or linguistically appropriate assessment accommodations that allow for the most valid and reliable measures of student performance, to the extent practicable. Alaska provides some instruction to Yup'ik and Inupiaq students at third grade in their native Alaskan languages but does not assess students in their language or in a manner that is likely to yield the most valid and reliable results on the standards-based assessments for those students.
- Change the policy that permits limited English proficient (LEP) students to be excluded from the Alaska final assessment system for two years to a policy that allows for a maximum one year-exclusion. Documentation should be provided of the revised policy showing when it was approved and by whom.
- Provide ED with accurate participation rate data for all students including the rates for students with disabilities (SWD) and LEP students. For each of the grades 3, 6, 8, and 10, the data must include the number of students enrolled in each of the aforementioned categories, the number who took the standard version of the tests in each grade, the number who took the standard test with accommodations, the number who took the alternate assessment, and the number who did not take the tests. The primary reasons that students did not take the tests should be described, and the number of students falling under each explanation provided.
- Provide evidence that all Title I high school students are being included in administrations of their high school qualifying exams and that the results for those students are being reported and used for school, local educational agency (LEA), and State accountability.
- Provide to ED evidence of the alignment of Alaska standards with the State's benchmark assessments. Test specifications for the benchmark tests, which show the match between test items and Alaska standards, need to be provided. An external alignment study can help to establish the alignment of Alaska standards with the State's assessment system.
- Provide additional information on the reliability of the benchmark assessments at the school and district levels and on the construct, consequential, and predictive validity of the benchmark assessments. Alaska's alternate assessments and accommodations used with SWD also need to be examined in terms of their technical quality.
- Disaggregate and report student performance data in the categories required by the Title I statute (gender, race/ethnicity, English proficiency status, economic status, migrant status, and disability status). Alaska should submit to ED its plan to report disaggregated student performance to the public.
- Indicate how Alaska will evaluate the accountability of small schools.
- Provide to ED information on the weight that their final assessment system will contribute to the determination of "adequate yearly progress."
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We understand that Alaska will need additional time to meet the remaining Title I requirements. Therefore, you may request, within 45 days, a waiver of the timeline for completion of Alaska's final assessment system to ensure the State's continued eligibility for receiving Title I funds. In your request, please include an action plan that includes quarterly milestones. For example, you will need to specify in the plan such things as the steps or timeframes for developing procedures to ensure that elementary-level native Alaskans have the opportunity to take the standards-based assessments in a form that is most likely to yield the most valid and reliable results. The timeline should also include
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such details as timeframes for ED review, on a periodic basis, of specific steps taken by Alaska to meet the requirements of the Title I statute. Projected dates for Board action on the LEP exemption policy revision should also be included.
The Department's Title I staff will monitor progress against the timeline. Failure of the State to complete activities or products as scheduled may make it necessary for this office to consider the other courses of action available to the Department. Potential actions include requiring Alaska to enter into a compliance agreement in order to remain eligible to receive Title I funds or initiating proceedings to withhold Title I funds from the State.
We will confer full approval of Alaska's assessment system upon completion of the actions described in your plan. Enclosed with this letter are detailed comments from the peer review team that evaluated the Alaska assessment documents. I hope you will find the reviewers' comments and suggestions helpful. Our Title I staff will be pleased to work with you and your staff to achieve consistency between the Title I requirements and the Alaska assessment system. We wish you well in your efforts to improve school and student performance in your State.
Thomas M. Corwin
Acting Deputy Assistant Secretary