November 8, 2000
Mary L. Peterson
Superintendent of Public Instruction
700 East Fifth Street
Carson City, Nevada 89701-5096
Dear Superintendent Peterson:
It was a pleasure speaking with you about the outcome of the review of Nevada'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 review and hope that the process provides useful feedback that will support your State's efforts to monitor student progress toward challenging standards.
As a result of our discussion, it is clear to me that Nevada is on track in many areas to expand its assessment and accountability system to include standards-based assessments that are aligned with the Nevada learning standards and that include all children in the grades assessed. Nevada has already accomplished a great deal: implementation of the criterion referenced assessments in grades 3 and 5; development underway on a standards-based version of the High School Proficiency Exam for 2001-02; and completion of the development phase of the Skills and Competencies Alternate Assessment of Nevada. These accomplishments indicate that you and your staff have the expertise and commitment required to complete plans for an assessment system that is consistent with Title I requirements. The plans that you shared with me indicate a thorough understanding of what still needs to be done to meet the Title I assessment requirements.
The evaluation conducted by external peer reviewers and U.S. Department of Education staff found that Nevada's current assessment program provides a solid foundation for future work. Nevada must now complete the transition to a unified, standards-based assessment system by improving and documenting the alignment of its assessments with state standards. This will assure that the assessment results provide a valid representation of school performance relative to state standards.
Nevada has completed an essential first step in this process by drafting descriptors for performance standards at grades 2, 3, 5, 8, and 12. The descriptors were evaluated by external reviewers and judged to meet the criteria set forth in the Reviewer Guidance for State Content and Performance Standards under Title I. Nevada's performance standards descriptors are therefore approved.
To fully meet the requirements of Section 1111(b)(3) and 1116(a) of the Elementary and Secondary Education Act, Nevada must address the following tasks.
- Develop and implement a standards-based assessment in at least reading/language arts and mathematics to be administered at some time during grades 6 through 9. Nevada's current system lacks only a standards-based assessment component that is administered in the middle grades. Successful completion of the new standards-based assessments at grades 3 and 5 demonstrates Nevada's capacity to design and implement all components required by the Title I legislation.
- Develop school, district, and state profiles that include the performance of all students tested, including those who participate in the alternate assessment. The performance of all students tested and the number of students exempted must be disaggregated as required by Title I insofar as statistically defensible. The design of reports must be completed and appropriate data collection procedures defined and communicated to schools and districts in order to produce the required reports.
- Develop a method of increasing the proportion of Limited English Proficient (LEP) students that participate in the state assessments. State policies must guarantee that each LEP student is included in the State assessment system; procedures must ensure an individualized determination of the most appropriate language and form of assessment for that student; and results for LEP students must be included in determinations of school accountability. Section 1111(b)(3)(G) of the Title I statute makes it clear that the only category of students who may be exempt from testing are students who have not attended schools in the local educational agency for a full academic year. Data provided by Nevada indicates that in 1999-2000, 58% of LEP students were exempted or tested with non-permissible accommodations, effectively removing these students from measures of school progress. The current writing and high school graduation tests are more inclusive than the norm-referenced test now in use. As new assessment components are included for Title I accountability, it will be essential for Nevada to expand the opportunities for LEP students to participate in the assessment process.
- For Title I, student and school reports must be based on performance standards that have been defined by Nevada educators and subsequently approved or adopted by the State. Student results must be expressed in terms of these performance standards. Much of the work needed to satisfy this requirement has already been completed. When assessments that fully reflect the performance standards have been adopted at each of the required grade spans and cut points have been established for each performance level, a description of the process employed and the final results should be submitted for approval.
- Complete the design of a school accountability system that is based primarily on results from Nevada's standards-based assessments. The current norms-based information will continue to be useful and can be incorporated as part of the Title I accountability system.
Please send your plan for making these changes to Mary Jean LeTendre, Director of Title I, within 30 days of receipt of this letter. If you can also provide assurances that the State will support implementation of the plan, we will be pleased to work with you to arrange for a waiver of the requirement that a State's final assessment system be implemented in the 2000-2001 school year. If the State is unable to provide assurances of support for implementation, we will discuss with you the steps necessary to remain in compliance with Title I.
We will work with you and your staff to support the implementation of your plan by providing technical assistance, if that would be helpful. When the required changes have been completed, Nevada's assessment system will be fully approved.
Enclosed with this letter are detailed comments from the peer review team that evaluated Nevada's assessment documents. We hope this information will be useful to the Nevada Department of Education in its efforts to implement a high quality assessment system.