June 29, 2007
The Honorable Christopher Koch
Superintendent of Education
Illinois Board of Education
100 North First Street
Springfield, Illinois 62777
Dear Superintendent Koch:
I am writing regarding our review of Illinois' standards and assessment system under the Elementary and Secondary Education Act of 1965 (ESEA), as amended by the No Child Left Behind Act of 2001 (NCLB). We appreciate the efforts required to prepare for the peer review and hope that the process provides useful feedback that will support Illinois' efforts to monitor student progress toward challenging standards.
External peer reviewers and Department staff evaluated Illinois' third peer review submission and found, based on the evidence received, that it still does not meet all the statutory and regulatory requirements of section 1111(b)(1) and (3) of the ESEA. I know that my staff has discussed the results of this review with your staff. However, I want to take this opportunity to enumerate the evidence that Illinois must provide in order to have a fully compliant system.
Specifically, we still have concerns with the Illinois Measures of Annual Growth in English (IMAGE) assessment that is given to limited English proficient students; the technical quality of the Illinois Standards Achievement Test (ISAT) and the IMAGE; and the weighting of the different components of the Prairie State Achievement Examination (PSAE) so that it represents the Illinois Learning Standards. The complete list of evidence needed to address these concerns is on the last pages of this letter.
We know that Illinois may be able to address many of our major concerns within the next few months. Therefore, we are not assigning an approval status to Illinois' system at this time. Because that system is not fully approved, however, we will place a condition on your fiscal year 2007 Title I, Part A grant award.
To ensure that all remaining work occurs in a timely manner, I request that, within two weeks of the date of this letter, you provide my staff with a detailed timeline for how and when Illinois will satisfy the remaining requirements. As part of that timeline, please indicate when you will submit evidence as it becomes available. We will review that evidence and schedule an additional peer review, if necessary.
If Illinois is unable to resolve the remaining issues with its assessment system by the agreed upon timeline, we will take appropriate enforcement actions as outlined in the Department's May 10, 2007 fact sheet, including the possibility of a Compliance Agreement under Section 457 of the General Education Provisions Act. For your convenience, I am enclosing a copy of that fact sheet, which is also available on the Department's website (www.ed.gov/admins/lead/account/statesystems.html).
Also enclosed with this letter are detailed comments from the peer review team that evaluated Illinois' assessment materials. I hope you will find the reviewers' comments and suggestions helpful.
We look forward to working with Illinois to support a high-quality standards and assessment system. If you would like to discuss this further, please do not hesitate to call Grace Ross (202-260-0967) or Patrick Rooney (202-205-8831) of my staff.
Kerri L. Briggs, Ph.D.
cc: Governor Rod R. Blagojevich
Summary of Additional Evidence that Illinois Must Submit to Meet ESEA Requirements for the Illinois Assessment System
2.0 - ACADEMIC ACHIEVEMENT STANDARDS
- Documentation of grade-level or grade-span descriptors of competencies associated with alternate achievement standards for reading, mathematics, and science.
- Documentation of committee review and approval of IAA Participation Guidelines.
- Documentation of the number and percentage of students with disabilities taking the alternate assessments, the regular assessments with accommodations, and the regular assessments without accommodations for grades 3-8 and 11, broken down by content area for reading and mathematics for 06-07.
- More complete documentation of the involvement of appropriately diverse groups (e.g., representing English language learners and students with disabilities) in developing academic achievement standards, alternate achievement standards, and cut scores.
3.0 - FULL ASSESSMENT SYSTEM
- Documentation of (1) the weighting procedure actually used to create PSAE scores and (2) how the procedure will affect the interpretation of overall scores as representative of performance on the Illinois Learning Standards and ensure overall scores are equally representative of performance on the Illinois Learning Standards from year to year.
- Documentation showing that the IMAGE mathematics and reading assessments are comparable to the ISAT and PSAE.
4.0 - TECHNICAL QUALITY
- Plans and a timeline for determining whether the assessments are producing intended and unintended consequences.
- Evidence of the technical adequacy of the current ISAT.
- Results of sensitivity and bias reviews, DIF analyses, and evidence of how ISAT results are used;
- Documentation that cut scores set for the 2005-06 ISAT in each content area and grade-level relate to student performance on the Illinois Learning Standards, as delineated in the 2005-06 Assessment Frameworks; and
- Documentation of quality control procedures for scoring, analysis, and reporting.
- Evidence of validity;
- Procedures used for sensitivity and bias reviews, DIF analyses, and evidence of how results are used;
- Evidence of a content-based rationale for the IMAGE reading cut scores and evidence that the cut scores are equivalent in meaning (i.e., represent the same degree of knowledge and skills in Illinois' grade-level content standards) to those on the ISAT and PSAE reading assessments; and
- Provide documentation of the standard setting process. Describe the selection of judges, methodology employed and final results.
5.0 - ALIGNMENT
- Plans and timeline for the revision of the ISAT that will address gaps and weaknesses in the alignment study for reading and grade 7 science.
- Plans and timeline for the revision of the PSAE that will address gaps and weaknesses in the alignment study for mathematics and science.
- Documentation of the alignment of 2007 IMAGE reading assessment, a plan and timeline for addressing alignment gaps in reading, and a plan and timeline for addressing the minor alignment gaps in mathematics.
7.0 - REPORTING
- Documentation of participation rates (enrolled vs. assessed) for each grade-level and content area at the State level for the migrant subgroup.