April 2, 2001
Dr. Christine Jax
Minnesota Department of Children, Families & Learning
1500 Highway 36W
Roseville, MN 55113
Dear Commissioner Jax:
It was a pleasure speaking with you about the outcome of the review Minnesota's final assessment system under the Title I requirements of the Elementary and Secondary Education Act. We appreciate the effort required 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.
Minnesota has done an outstanding job of completing the grades 3 and 5 components of its final assessment system. We are particularly impressed with the manner in which the State is addressing inclusion at those grade levels. The evaluation conducted by external peer reviewers and U.S. Department of Education staff found that, in order to fully meet the requirements of Title I, Minnesota must still address the following tasks.
- Minnesota must complete its standards-based assessment system for students in grades 7 (reading and mathematics), 10 (reading), and 11 (mathematics). Based on the evidence that Minnesota provided, the seventh grade tests will be administered during March 2003, and the high school tests will be administered during March 2002. The Department will expect Minnesota to submit its grade 7 performance standards for approval as they are completed and to provide evidence of the alignment and technical quality of the grades 7, 10, and 11 tests.
- Minnesota must provide evidence that the grades 7, 10, and 11 tests satisfy the requirement for "multiple up-to-date measures of student performance, including measures that assess higher order thinking skills and understanding." Examples of appropriate evidence include item development procedures or results from a post hoc analysis conducted by educators familiar with State standards.
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- Minnesota must provide evidence that its policies and procedures for the grades 7, 10, and 11 assessments are inclusive and allow access to the assessments by students with disabilities and those with limited English proficiency. Those policies and procedures should be fairly similar to the policies and procedures that have been put into place at grades 3 and 5.
- English language learners must be assessed, to the extent practicable, in the language and form most likely to yield valid results and/or participation in the regular assessment with appropriate accommodations as needed. Title I requires that, except for limited English proficient (LEP) students who have attended Minnesota schools for less than one year, any exemptions from testing must be made on an individual basis, and must be based on clear criteria for language proficiency. When the new assessments are developed, Minnesota must communicate inclusion requirements to all schools with grades 7, 10, and 11, and must monitor implementation of the new inclusion procedures to assure consistency across districts and schools.
- Assessment results must be reported for all students with disabilities. Results for all students with disabilities (SWD), including those who take the Alternate Assessment, must also be included in measures of school progress. In addition, the results for LEP students tested or the number of exemptions must be reported and included in determinations of school progress.
- At all levels reports must include results expressed as performance levels and display results disaggregated by gender, racial/ethnic groups, English proficiency status, migrant status, students with disabilities as compared to non-disabled students, and economically disadvantaged students as compared to students who are not economically disadvantaged. Minnesota needs to add the migrant category to its reports at all levels.
- Minnesota must indicate how its final assessment system, when it is completed in 2003, will be used to determine Adequate Yearly Progress (AYP) and what percentage the final assessment system will contribute to the determination of AYP.
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We understand that it will take two additional years to implement the grade 7 tests, and a year to implement the grades 10 and 11 tests. Completion of alignment studies and technical quality reports will also require some additional time. Time is also needed to develop policies and procedures to ensure inclusion of all students in assessment and accountability and to make the necessary changes in reports. Therefore, you may request, within 45 days, a waiver of the timeline for completion of Minnesota's final assessment system to assure the State's continued eligibility for receiving Title I funds. In your request, please include an action plan that includes quarterly milestones. You will need to specify in the timeline such things as the steps/timeframes for developing policies regarding SWD/LEP participation in the assessments at grades 7, 10, and 11, and the steps to be employed to develop the grades 7, 10 and 11 assessments. The timeline should also include details such as review by this office of draft language for the policy statement. Projected dates for Board or legislative action should also be included when appropriate.
Our 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. These potential actions include requiring Minnesota 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 Minnesota.
We will extend full approval upon completion of the actions described in your timeline. Our Title I office will be happy to work with you and your staff to achieve consistency between the Title I requirements and the Minnesota 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