June 20, 2001
Honorable Paul L. Vance
Superintendent of Public Schools
District of Columbia Public Schools
825 North Capitol Street, NE
Washington, DC 20002
Dear Superintendent Vance:
It was a pleasure speaking with you and your staff regarding the Department's review of the District of Columbia's final assessment system under the requirements of Title I of the Elementary and Secondary Education Act. We appreciate the District of Columbia Public Schools' (DCPS) efforts to prepare for the final review and hope that the process provides useful feedback that will support the District's monitoring of student progress toward challenging standards.
Enclosed with this letter are detailed comments from the peer review team that evaluated DCPS assessment documents. We hope this information will be useful as DCPS considers improvements to the District's assessment system.
Title I requires the full implementation of an aligned system of standards and assessments that includes all students. Results from the assessment system must be used to determine adequate yearly progress and to identify schools that are in need of improvement. As we discussed, several aspects of the District of Columbia’s assessment system do not meet the requirements of Section 1111(b)(3) and 1116(a) of Title I. The DCPS must, therefore, do the following in order to remain eligible to receive Title I funds.
- Develop or select an assessment that represents the full range of the DCPS content standards in at least reading/language arts and mathematics at the benchmark grades. Materials previously submitted as evidence of DCPS performance standards consistently suggested a substantial lack of alignment between the standards and the test. Also, DCPS' sole reliance on the Stanford Achievement Test (9th edition) does not satisfy the requirement for use of multiple measures of student performance, including measures that assess higher-order thinking and understanding. In addition, DCPS must document the alignment of the assessment(s) with DCPS content and performance standards. If alignment gaps are identified, DCPS must submit a timeline for completing the steps needed to achieve alignment.
- Complete the creation of DCPS performance standards by identifying the scores on the assessment(s) that define each of the DCPS performance levels. DCPS teachers or other persons who are thoroughly familiar with the DCPS standards must be included in this activity.
- Provide data showing that all assessments used for Title I accountability meet commonly accepted professional standards for technical quality consistent with the District's uses of the results. Reliability of both student and school classifications should be reported.
- Establish assessment procedures and reports that include all students with disabilities (as required by the Individuals with Disabilities Education Act (IDEA) and Title I) in the DCPS assessment system, and include the test results for these students in DCPS' school accountability measures. This requirement includes completion of the work now under way to develop and implement an alternate assessment for students with disabilities. Results from the alternate assessment must be publicly reported (in a manner consistent with protection of student privacy) and included in DCPS' accountability system.
- Establish assessment procedures to maximize participation of limited English proficient (LEP) students in the assessment and include test results for these students in the school accountability measures. The current DCPS time-based exemption policy for LEP students is not consistent with Title I requirements and must be modified. Every student who has been in the District for more than one year must be included in the assessment system. If DCPS permits individual exemptions based on language proficiency, then you must establish clear criteria for exemption and communicate those criteria to all schools. Any students exempted from the regular assessment on the basis of language proficiency must be included in the accountability system in some manner. DCPS is also responsible for determining the practicability of administering a native language version of the DCPS assessment(s), and including the results in the accountability system.
- Monitor school-level decisions regarding participation in the alternate assessment or exemption based on limited English proficiency to ensure consistency across schools and over time.
- Provide to the Department accurate enrollment, participation, and exclusion data; report school-level results for all students tested; and base school accountability measures on all students.
- Develop and disseminate annual school reports that display results for all students, disaggregated by gender, major racial/ethnic groups, LEP status, migrant status, students with disabilities as compared to non-disabled, and economically disadvantaged students compared to non-disadvantaged. These school profiles must be shared with teachers and other educators, parents, and the community.
- Modify individual student reports to reflect the DCPS performance standards when they are completed. In addition to test scores and their meaning, reports should include an explanation of the meaning of the DCPS performance levels.
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In order to maintain eligibility for Title I funding, it will be necessary for DCPS to enter into a compliance agreement with the Department of Education. A compliance agreement is a statutory remedy authorized by §457 of the General Education Provisions Act for situations in which a State or local agency cannot meet statutory requirements within the timeframe specified by law. Its purpose is to enable a grantee to remain eligible to receive funding while coming into full compliance with applicable requirements as soon as feasible but in no longer than three years.
We are ready to work with the DCPS to reach agreement on the terms of the compliance agreement as quickly as possible. After we have agreed to tentative terms, the Department must hold a hearing to explore why full compliance with the Title I final assessment requirements is not feasible until a future date. The District, affected students and their parents, and other interested parties may participate. If, after the hearing, it is still evident that full compliance is genuinely not feasible until a future date, this office will make written findings to that effect and will publish those findings, along with the substance of the compliance agreement, in the Federal Register.
Please be aware that the review of DCPS’ assessment system for Title I is not a determination that the system complies with Federal civil rights requirements, including Title VI of the Civil Rights Act of 1964, Title VI 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 Act.
If you would like to talk further about this, please do not hesitate to call me.
Thomas M. Corwin
Acting Deputy Assistant Secretary