May 11, 2001
Honorable Vito Gagliardi
Commissioner of Education
New Jersey Department of Education
P.O. Box 500
Trenton, New Jersey 08625-0500
Dear Commissioner Gagliardi:
It was a pleasure talking with you regarding the outcome of the final assessment review under the requirements of Title I of the Elementary and Secondary Education Act. We appreciate the efforts New Jersey made 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 Jersey is to be commended for the breadth of its assessment system.
This letter provides the results of the Department's review of New Jersey's submissions in two areas: performance standards and the final assessment system.
With regard to New Jersey's performance standards, our external reviewers judged them acceptable in reading/language arts and mathematics and satisfying the Title I requirement for including at least three levels of proficiency. I am happy to notify you of approval of the New Jersey performance standards.
External peer reviewers and U.S. Department of Education staff evaluated New Jersey's assessment system and found that completion of several important policies and procedures are required in order to meet the Title I requirements. The review found that the tasks noted below must be completed to ensure that New Jersey's assessment system meets the requirements of Section 1111(b)(3) and 1116(a) of Title I.
- New Jersey must complete the development of and implement a test aligned with the New Jersey standards in grades 10-12 in at least reading/language arts and mathematics by your deadline of spring 2002.
- New Jersey must document the alignment between the State standards and the State assessments; if gaps exist, the State should also document the steps being taken to improve alignment. This is a fundamental requirement for final assessment systems under Title I and is the basis for test validity.
- New Jersey must resolve conflicting requirements in the current administrative code regarding participation of all students in the assessment and accountability system. In addition, New Jersey must develop specific guidance for local educational agencies (LEAs) on how they are to implement the State's inclusion policy, and clearly communicate this guidance to all LEAs. This guidance must include procedures for determining how each student with disabilities and each student with limited English proficiency is to be included in the assessment system and details about how scores for these students will be reported and included as an indicator of school progress. The State must also monitor local implementation of the inclusion procedures.
- New Jersey must develop procedures to ensure participation of all students in the State's assessment system or must provide detailed guidance to LEAs about how to develop or adopt the alternate assessments required by the New Jersey administrative code for students with disabilities and students with limited English proficiency for whom the standard statewide assessments are not appropriate. If locally developed and administered assessments are to be employed, the State must assure the technical quality of those assessments and the comparability of results across schools and over time. New Jersey must document how it intends to include students with disabilities in the State assessment program until the proposed Alternate Proficiency Assessment is implemented in 2002-2003 (because Title I cannot waive the Individuals with Disabilities Education Act requirement for having an alternate assessment in place by July 1, 2000).
- New Jersey must report results for all students tested and report the number of students exempted. At present, school reports include only students who take the standards assessment. School accountability must be based on all students, including those who take alternate assessments and students who, for whatever reason, are not assessed.
- New Jersey must document the technical quality of the assessments as they are used for school accountability. Documentation should include, but need not be limited to: criteria used for item reviews and how the results of item analyses and reviews are used in test construction; the reliability of school and student scores in mathematics and language arts literacy; the methods used for evaluating item and test bias; evidence that the SDE monitors administration, scoring, analysis, reporting, and security procedures to assure accurate results; evidence that the SDE has clearly communicated information about appropriate interpretation and use of assessment results to New Jersey educators; and the plan and timeline for periodic review and revision of standards and assessments to ensure continued alignment.
- New Jersey must report disaggregated assessment results for each of the required subgroups at the state, LEA, and school levels, including direct comparison of the performance of students with disabilities as compared to nondisabled students, and economically disadvantaged students as compared to students who are not economically disadvantaged.
In order to complete the review process, New Jersey will need to submit within 45 days a plan for making the above changes. When we receive your detailed plan and timeline, we will be happy to approve your request for a waiver of timeline. The Title I office will work with you and your staff to monitor the implementation of your plan. When the
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required changes have been completed, we will consider the assessment system for final approval. If New Jersey is unable to complete these tasks as scheduled, this office will consider the other courses of action available to the Department, such as requiring New Jersey to enter into a compliance agreement in order to remain eligible to receive Title I funds.
Enclosed with this letter are detailed comments from the peer review team that evaluated the New Jersey assessment documents. I hope you will find the reviewers' comments and suggestions helpful. We look forward to working with New Jersey to support high quality in the assessment system. If you would like to discuss this further, please do not hesitate to call me.
Thomas M. Corwin
Acting Deputy Assistant Secretary