August 21, 2000
Elizabeth M. Twomey
Commissioner of Education
New Hampshire Department of Education
State Office Park South
1011 Pleasant Street
Concord, NH 03301
Dear Commissioner Twomey:
It was a pleasure speaking with you about the outcome of the review of New Hampshire's final assessment system under the Title I requirements of the Elementary and Secondary Education Act. We appreciate the efforts required to prepare for the final review and hope that the process provides useful feedback that will support your State's efforts to monitor student progress toward challenging standards. New Hampshire is to be commended for the breadth of its assessment system and for the quality of the information provided to parents regarding students' assessment results.
As we discussed, I am providing conditional approval for New Hampshire's final assessment system, based on the evaluation conducted by external peer reviewers and U.S. Department of Education staff. The review found that, except for the features noted below, New Hampshire's assessment system meets the requirements of Section 1111(b)(3) and 1116(a) of Title I.
To receive full approval as a final Title I assessment system, the following changes or clarifications in New Hampshire's assessment policy or procedures must be made prior to the 2000-2001 administration of your assessments:
- Revise the existing state inclusion policy to agree with the Title I requirements. Section 1111(b)(3)(G) of the statute makes clear the only category of students who are exempt from testing are students who have not attended schools in the local educational agency for a full academic year. We understand that New Hampshire has proposed a policy change that will require all students, including non-English proficient students, to be assessed, and that this policy change will soon be submitted to the State Board of Education for approval.
- Submit a technical report that summarizes the validity, reliability, item functions and test form consistency from year-to-year. This report is required to demonstrate that State assessments are valid, reliable, and consistent with relevant, nationally recognized professional and technical standards for such assessments.
- Provide information to the Department regarding the degree of alignment between your State assessment and your State content and student performance standards. As you know, Title I requires that final assessments be aligned with content and performance standards. Although New Hampshire generally addressed the process used to align its final assessment system with State standards, it did not submit evidence of the results of that process. Information such as the test blueprint that lays out the test specifications or the results of internal or external alignment studies would be appropriate evidence for demonstrating the degree of alignment.
- New Hampshire currently reports and includes in its measures of school progress under Title I the results for all students who participate in the regular State assessment. New Hampshire must develop a means of reporting and including for the purposes of accountability the results for students who participate in the State's alternate assessment. On the school profiles, all assessment results and exemptions must be disaggregated as required by Title I when statistically sound. The State's system for measuring Title I school progress must include all students who have attended schools in the LEA for a full academic year. There are several acceptable strategies for combining results from different assessments as well as for including the number of students exempted from testing (if any) in the State's accountability measures.
In order to complete this process, New Hampshire will need to submit a plan for meeting these conditions or making these changes to Mary Jean LeTendre, Director of Title I, within 30 days of receipt of this letter. We will work with you and your staff to support and monitor the implementation of your plan. When the required changes have been completed, the assessment system will be fully approved.
If, over time, changes are made to New Hampshire's assessment system, you must submit information about those changes to the Department as required by section 1111(e)(2) of Title I. For example, an increase in the limited English proficient population might cause New Hampshire to re-examine the manner in which LEP students are assessed, particularly the practicability of assessing those students in their native language in order to best determine what they know and can do.
As New Hampshire indicated in its submission of evidence, the State intends to include additional subjects-science and social studies-in the State assessment and accountability system. As performance standards and assessments are finalized in these subject areas, the State must submit information about those changes to the Department as required by section 1111(e)(2) of Title I.
Please note that the approval of New Hampshire's assessment system for Title I will not mean that the system complies with federal civil rights requirements, including Title VI of the Civil Rights Act of 1964, Title IX 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 Education Act.
Enclosed with this letter are detailed comments from the peer review team that evaluated the New Hampshire assessment documents. I hope you will find the reviewers comments and suggestions helpful. We look forward to working with New Hampshire to support high quality in the assessment system. If you would like to discuss this further, please do not hesitate to call me.