June 25, 2001
Honorable Ted Stilwill
Director of Education
Iowa Department of Education
Grimes State Office Building
East 14th & Grand Streets
Des Moines, Iowa 50319-0146
Dear Director Stilwill:
It was a pleasure speaking with you about the outcome of the Department’s review of Iowa's final assessment system under the requirements of Title I of the Elementary and Secondary Education Act. We were pleased to learn that Iowa is moving forward in providing guidance and professional development to districts on evidence that the districts must submit regarding their final assessment systems and content and performance standards. We appreciate the effort Iowa made to prepare for our review and hope that the process provides useful feedback that will support your State’s efforts to monitor student progress toward challenging standards.
Since Iowa is a "local educational control" State, the Iowa Department of Education (IDE) and its designees should interact with local school districts in a fashion that is similar to the manner in which our Department interacts with States. Iowa must wear three "hats" as efforts are undertaken to meet the requirements of Title I. Your agency should:
- Provide guidance and direction to school districts regarding steps that they must take to meet Title I requirements,
- Monitor and approve final assessment system evidence submitted by school districts, including taking corrective action for districts not in compliance with Title I requirements , and
- Provide evidence to this Department that all Iowa districts receiving Title I funds meet or are undertaking corrective action to meet the requirements of Title I.
Iowa has begun implementation of a process for reviewing and monitoring school district evidence of compliance with the final assessment system requirements of Title I.
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Currently, however, Iowa does not meet the requirements of the Title I statute on any of the five final assessment review criteria because the evidence on full assessment system, inclusion, alignment, technical quality, and reporting is not due from Iowa school districts until September 2001. In addition, Iowa does not meet the requirements for content or performance standards approval. Based on the evaluation conducted by external peer reviewers and U.S. Department of Education staff, in order to meet the requirements of Title I, Iowa must:
Content and Performance Standards
- Provide the Department with the results of the State’s content standards review for all Iowa districts. The Department previously approved the process that your agency intended to use to review district content standards, but we have not received evidence that every district has approved content standards that meet the Title I requirements.
- Provide evidence on the involvement of special educators, persons with expertise in educating limited English proficient students, and other audiences in the development and review of content standards.
- Provide us with the results of your performance standards review for all Iowa districts. Iowa needs to document that each school district is assessing students in reading and mathematics, that student performance evaluation has three levels (with one of the levels being advanced), and that the performance standards are developed with broad-based involvement, are challenging, and are applied to all students.
Full Assessment System
- Provide evidence for all districts receiving Title I funds that assessments include multiple measures of student achievement and measure higher-order thinking.
- Provide information to the Department regarding the number of districts that have approved full assessment systems, including what is being used by each as the multiple measures assessment.
- Report participation/exclusion rates for students with disabilities (SWD) and limited English proficient (LEP) students compared to their total presence at the school, district and statewide levels. Please include information on the number of students in these categories for whom the results are both reported and included in determining school progress.
- Ensure that participation rates reported by districts to the State are accurate.
- Provide evidence to the Department that the IDE has provided guidance and is monitoring how school districts address issues related to offering appropriate accommodations or native language assessments for LEP students.
- Provide documentation of the specific process used by your agency for monitoring the implementation of district policies for the inclusion of SWD and LEP students.
- Provide information on the guidance and training that the IDE has provided for districts to build their capacity to implement inclusion policies successfully.
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- Provide a sample of completed “Standards Coverage Matrixes” when they become available.
- Provide documentation of the processes your agency uses to assist districts in using the Matrix and the process for State review of the matrices.
- Provide evidence that each school district has conducted an alignment study that verifies the extent to which the full range of district content standards are being covered, that the assessments are sufficiently demanding cognitively, and that district assessments provide scales that reflect the meaning of the performance standards.
- Provide information regarding steps each district will take to address gaps between its content and performance standards and its assessment system.
- Submit evidence to the Department regarding: (1) the number of districts that have met the alignment requirements; and (2) corrective actions your agency is taking to bring districts that do not meet those requirements into compliance.
- Provide documentation to the Department that each district's
- Provide evidence that each district's assessment system provides comparable results for different schools and years for all content standards.
- Establish criteria and guidelines, for dissemination to districts, regarding what constitutes sufficient validity and reliability for final assessment systems.
- Provide evidence that training is taking place to build the capacity of districts to address technical quality issues in their final assessment systems.
- Submit evidence to the Department regarding the number of districts that have met the technical quality requirements and what is being done to address those districts not in compliance with those requirements.
The IDE should establish policy that requires districts to include the following information in the student performance reports they provide to parents, students, and others in the community:
- Information about all components of the local assessment system used to identify schools in need of improvement, not just ITBS/ITED results.
- Information on student performance on all measured district standards.
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You should submit to us samples of materials used by your agency and Iowa's Area Education Agencies to assist districts in interpretation of assessment results. In addition, please provide the following to the Department:
- Samples of LEA and school reports showing disaggregated data for all required subgroups.
- A plan for monitoring the dissemination of reports by LEAs to the public.
- Evidence that your agency has reviewed inadequacies that were discovered by peer reviewers (in the sample Annual Progress Report provided to our peer reviewers) to ensure that 1) building report data are disaggregated, 2) all schools in an LEA are reported on, 3) district-level disaggregation includes LEP and migrant students, 4) performance data for low-income students are disaggregated, 5) demographic data on enrollment are provided, 6) data for multiple measures and ITBS/ITED are included in the report, and 7) an indicator or note regarding measurement error is included in the reports.
- Evidence regarding the number of districts that have met the disaggregated reporting and other reporting requirements (including a sample of district and school level reports).
- A plan to address those districts not in compliance with the reporting requirements of Title I.
We understand that Iowa 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 Iowa’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 criteria and guidelines your agency will provide to districts regarding what constitutes sufficient validity and reliability for final assessment systems. The timeline should also include such details as timeframes for developing sufficiency criteria, training State, area education agencies, and district staff on the application of the criteria, the format for submitting evidence of validity and reliability, when reviews of validity and reliability will take place, the number of districts that provide acceptable evidence of reliability and validity, and corrective actions taken by the SEA for districts not in compliance with the technical quality requirements.
The plan and timeline should provide opportunities for this Department to review, on a periodic basis, specific steps taken by Iowa to meet the requirements of the Title I statute.
The Department’s Title I staff will monitor progress against the timeline. Failure of Iowa 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 Iowa 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.
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We will confer full approval of Iowa’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 Iowa 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 Iowa 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