May 7, 2001
Honorable E. Vernon Coffey
Commissioner of Education
Tennessee Department of Education
Sixth Floor, Andrew Johnson Tower
710 James Robertson Parkway
Nashville, Tennessee 37243-0375
Dear Commissioner Coffey:
It was a pleasure speaking with you about the outcome of the Department's review of Tennessee's final assessment system under the requirements of Title I of the Elementary and Secondary Education Act. We appreciate the effort Tennessee made 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.
We were pleased to learn that Tennessee is moving forward with the development of performance standards and will conduct a study of the alignment of your assessments with those standards during the Summer of 2001. In response to your questions regarding the statutory requirements for assessments to include multiple measures of student performance, enclosed is a copy of the guidance peer reviewers used in reviewing evidence submitted by the States to the Department. Please refer to the section on multiple measures on pages 6-8 of the Peer Reviewer Guidance.
As we discussed, Tennessee does not yet meet the assessment requirements of the Title I statute including the requirement for adoption of performance standards. Based on the evaluation conducted by external peer reviewers and U.S. Department of Education (ED) staff, in order to meet the requirements of Title I, Tennessee must:
- Provide evidence of inclusion practices, alignment with standards, and technical quality for the Tennessee Comprehensive Assessment Program (TCAP), including new items to be implemented during the 2002-03 school year.
- Provide evidence of how the new assessments will be incorporated in the Tennessee accountability system. In particular, please provide us with information on how Tennessee plans to incorporate data obtained using multiple measures (i.e., multiple format examination items and cognitively complex items) into the value-added accountability system that is mandated by the Tennessee legislature.
- Clarify which high school mathematics test the State will require all students in the 10-12 grade span to take. In addition, we request that you provide documentation that the high school mathematics test is aligned with the high school mathematics standards. In addition, in order for the Department to determine if the majority of students taking the mathematics test are high school students, please provide us with data showing how many of Tennessee high schools are structured as 9-12 buildings and how many are configured as 10-12 buildings.
- Change the State's limited English proficiency (LEP) inclusion policy to require LEP students to be held to the same standards as non-LEP students after one year of enrollment in a Tennessee school district. Under Title I, if non-LEP students are required to take all of the State's assessments (in Tennessee's case, the TCAP), then LEP students must also take the assessments with appropriate accommodations or in their native language.
- Document how data for students who take the alternate form of the TCAP and students administered assessments with accommodations will be incorporated into the accountability system, at minimum for Title I purposes. Your Department should also submit information on how exempted students are accounted for in the TCAP for accountability purposes.
- Provide participation rate data for all students, students with disabilities (SWD), and limited English proficient students for the 2000-01 test administration. This information should specify which tests these students took (including the TCAP-Alt and whether they were tested with accommodations). You should also specify the extent (by number and percentage) to which SWD and LEP students' test results are used in determining school accountability. In addition, please specify plans for increasing the future participation rates of SWD and LEP children in assessment reporting and accountability.
- Provide a technical report on the reliability, validity, and item characteristics of all components of the TCAP and the TCAP-Alternate.
- Provide evidence that Tennessee has implemented performance standards in at least reading and mathematics at one grade in each of three grade spans (3-5, 6-9, and 10-12) that are aligned with content standards and the final assessment system. Under the Title I statute, performance standards must have at least three performance levels, one of which must be "advanced." They must be challenging and inclusive of all students. Finally, the performance standards must be developed and reviewed with the broad-based involvement of special educators, educators of second language learners, and language arts and mathematics content experts, among others.
- Provide updated information on the process you have used to align Tennessee standards with all of the TCAP components, including test blueprints, test item maps, and other illustrative documents or reports.
- Clarify and document the State's plan for disaggregating and reporting student performance by the mandated categories and provide copies of those reports at the State, district, and school levels.
- Clarify the weight that the final assessment system will contribute to the determination of school progress and indicate what components of the Tennessee assessment system factor into measures of school progress.
- Provide your plan for identifying small schools needing improvement and for use of local assessment data to evaluate the performance of K-2 schools.
We understand that Tennessee will need additional time to meet the remaining Title I requirements. Therefore, you may request, within 45 days, a waiver of the timeline for completion of Tennessee's final assessment system to ensure the State's continued eligibility for receiving Title I funds. In your request, please include an action plan that includes a timeline with specific steps Tennessee will take to meet the requirements of the Title I statute. The plan would also include quarterly milestones and a projected date for Board action on your revised LEP policy.
The Department's Title I staff will monitor progress against the timeline. Failure of the State to complete activities as scheduled may make it necessary for this office to consider the other courses of action available to the Department. Potential actions include requiring Tennessee 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 the State.
We will confer full approval of Tennessee's assessment system upon completion of the actions described in your plan. Enclosed with this letter are detailed comments from the peer review team that evaluated the Tennessee assessment documents. I hope you will find the reviewers' comments and suggestions helpful. Our Title I staff will be pleased to work with you and your staff to achieve consistency between the Title I requirements and the Tennessee 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