January 19, 2001
Honorable Douglas Christensen
Commissioner of Education
Nebraska Department of Education
301 Centennial Mall, South, 6th Floor
Lincoln, Nebraska 68509-4987
Dear Commissioner Christensen:
I want to follow up our recent conversations regarding the U. S. Department of Education's review of Nebraska's Title I assessment system. Both the conference call with our respective staffs and the meeting you and I had were extremely productive. I greatly appreciate the cooperative spirit you and your staff have taken during these discussions. The purpose of this letter is to share with you the findings of the peer and staff review process that incorporates the new information we have received
As we have discussed, the Title I assessment requirements were adopted as part of the major overhaul of Title I undertaken by Congress and the Administration in 1994. The statute requires each State to implement a system of challenging content and performance standards, aligned assessments and school and district accountability for all students for the 2000-01 school year. Given that Nebraska has locally determined content and performance standards as well as assessments, the review of the Title I final assessment system focused on how Nebraska will meet the Title I requirements for standards and assessments within a locally determined system.
Based on the timeline contained in the School-based Teacher-led Assessment and Reporting System (STARS), the locally developed standards and assessments will not be completed and reviewed until at least Summer 2001, beyond the deadline for meeting the Title I requirements. To stay in compliance, therefore, you must submit a request to waive the timeline. Your request must include Nebraska's plan to complete the review and documentation of the locally developed performance standards and assessments as described in the following sections as well as a detailed timeline. The plan must also include when the Department of Education will receive the specific criteria Nebraska will use for reviewing and approving performance standards, and local assessments including their alignment and technical quality. This waiver request should be sent to the Assistant Secretary for Elementary and Secondary Education within 45 days of receipt of this letter.
Title I requires States to have adopted performance standards that include at least three performance levels (e.g., partially proficient, proficient and advanced). Guidance previously issued by the U.S. Department of Education indicates that good performance standards may also include performance descriptors (narrative descriptions of the performance levels), exemplars of student work, and cut scores.
Nebraska must submit the process that it will use to review and approve LEA content standards if different from State content standards. In regard to performance standards, Nebraska must submit the specific criteria it will use for reviewing and approving its LEAs' performance standards to verify that for each LEA the 1) performance standards have at least three levels of proficiency, 2) a broad base of stakeholders was involved in their development, 3) the performance standards are challenging for all students, and 4) the performance standards include, as appropriate, performance descriptors, cut scores, and exemplars of student work.
Final Assessment System
Title I requires that each State have final assessments in place by the 2000-2001 school year. These assessments must be aligned to the State's content and student performance standards, and be administered annually in at least reading and mathematics to students in at least one grade in each of three grade ranges-grades 3 through 5, grades 6 through 9, and grades 10 through 12.
Based on our conversation and the conference call with Department staff, we understand that Nebraska will require districts and schools receiving Title I funds to assess students each year in reading and mathematics and report the performance of those students annually at grades 4, 7 and 11. Please provide documentation that this interpretation is accurate.
Alignment and Technical Quality
Title I requires that final assessments be aligned with content and performance standards in at least math and reading/language arts, as well as any other subject area in which a State has adopted standards.
Nebraska provided evidence on the alignment and technical quality between the State standards and the five norm-referenced assessments that LEAs may choose from in implementing their final assessment systems. The evidence indicated that alignment between Nebraska's content standards and the norm-referenced tests was at most 33%. Moreover, no information was provided on the technical quality of the norm-referenced tests that LEAs may use for assessment purposes.
Based on the subsequent conference call and the STARS manual, we understand that Nebraska will conduct alignment studies of the criterion-referenced assessments submitted by districts along with their assessment plans during 2001. Thus, in addition to the SEA receiving an assessment plan and checklist from each district indicating that assessments have been aligned with their content and performance standards, Nebraska will provide an independent review and evaluation of the degree of alignment between LEA developed standards and LEA selected norm-referenced and criterion-referenced assessment instruments. Nebraska's contractor for this activity, the Buros Center for Testing, will also provide feedback on the alignment of criterion referenced test's similar to the feedback that they provided on the alignment between the norm-referenced tests and the optional state content standards. This information will be used to select the four to six suggested criterion referenced tests that LEAs should adopt to complete their assessment systems. The Department of Education's Title I office must also receive copies of those reports and the criteria used to select the four to six criterion referenced tests referenced above.
We did not receive information regarding how LEA criterion referenced assessments would be evaluated in terms of their technical quality. From our conversation we understand that the plan for evaluating technical quality is being developed and that the Buros Center for Testing will also conduct the technical quality studies.
According to the State's plan, the process of review and analysis conducted by the Buros Center for Testing will exceed the 2001 timeline for completion of final assessment systems. Nebraska should address when these studies will be completed in its plan and timeline accompanying its waiver request and when the Department will receive these studies.
Inclusion of All Students
Title I requires that final assessments must provide for the participation of all students in the grades being assessed. Title I specifically requires the inclusion of students with limited English proficiency in final assessments and makes clear that States must assess those students, to the extent practicable, in the language and form most likely to yield accurate and reliable information on what they know and can do in subjects other than English. Furthermore, Title I requires States to provide reasonable adaptations and accommodations for students with diverse learning needs.
Given Nebraska's submission, external reviewers were unable to determine: 1) statewide participation rates for limited English proficient students and students with disabilities; 2) how alternative assessments will be implemented for students with disabilities in 585 school districts; and 3) how the State will monitor the application of inclusion policies at the local level.
Information provided by Nebraska suggested to external reviewers and ED staff that guidelines for assessing limited English proficient students are lacking in specificity and that limited English proficient students may be excluded from the State's accountability system. In our conversation, Nebraska indicated the SEA's expectations that all students be included in assessments and that their results be included in accountability. However, a plan and timeline for reviewing the extent to which all students in an LEA are being assessed needs to be provided.
Title I requires that States provide individual student interpretive and descriptive reports on the attainment of student performance standards set by the State. Assessment results are also required to be disaggregated within each State, district, and school. The Title I statute spells out the categories for reporting results, including by gender, major racial and ethnic groups, English proficiency status, and migrant status. It also requires that students with disabilities be compared to nondisabled students, and economically disadvantaged students be compared to students who are not economically disadvantaged.
Though Nebraska does not have performance standards, student results appear to be standards based. However, the method used to collect individual student data does not readily accommodate the aggregation of student data from the school level to the state and district level and disaggregation of student performance information by the six categories required in the Title I statute. Nebraska must describe the process that will be used to disaggregate student performance.
Enclosed with this letter are detailed comments from the peer review team that evaluated the Nebraska assessment documents. We hope this information will be useful to the Nebraska Department of Education, providing suggestions that support continued high quality in the assessment system.
We will work with you and your staff to support and monitor the implementation of your plan. If you have any further questions, please do not hesitate to call the Title I staff in the Department of Education.