March 22, 2006
Honorable Alice Seagren
Minnesota Department of Education
1500 Highway 36 West
Roseville, MN 55113
Dear Commissioner Seagren:
Thank you for submitting Minnesota's assessment materials for review under the standards and assessment requirements of the Elementary and Secondary Education Act (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 Minnesota's efforts to monitor student progress toward challenging standards.
External peer reviewers and U.S. Department of Education (ED) staff evaluated Minnesota's submission and found, based on the evidence received, that it did not meet all the statutory and regulatory requirements of Section 1111(b)(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 Minnesota must provide in order to have a fully compliant standards and assessment system under NCLB. That evidence is listed on the last pages of this letter.
I urge you to submit any available evidence demonstrating how the system meets the standards and assessment requirements as soon as possible. I also request that, as soon as possible, you provide us a plan with a detailed timeline for how Minnesota will meet any remaining requirements for which evidence is not currently available. After receiving those materials, I will then determine the appropriate approval status for Minnesota's standards and assessment system.
Enclosed with this letter are detailed comments from the peer review team that evaluated Minnesota's assessment materials. The peer reviewers, experts in the areas of standards and assessment, review and discuss a State's submission of evidence and prepare a consensus report. I hope you will find the reviewers' comments and suggestions helpful. Based on this review, Minnesota should anticipate the need to submit materials for a second peer review.
We look forward to working with Minnesota to support a high-quality assessment system. If you would like to discuss this further, please do not hesitate to call Valeria Ford (202-205-2213) or Catherine Freeman (202-401-3058) of my staff.
Henry L. Johnson
cc: Tim Vansickle
Summary of Additional Evidence that Minnesota Must Submit to Meet ESEA Requirements for the Minnesota Assessment System
1.0 - ACADEMIC CONTENT STANDARDS
- Commissioner's formal approval of content standards for language arts, mathematics and science.
- Documentation and description of the process used to develop the content standards, and documentation to ensure that such content standards are challenging and rigorous.
- Documentation of how stakeholders were involved in developing the content standards. It is not clear that there was active participation by individuals with experience with LEP students and students with disabilities in the development of the regular standards.
- Documentation that the content standards also apply to students with the most significant cognitive disabilities
2.0 - ACADEMIC ACHIEVEMENT STANDARDS
- Approved academic achievement standards (including descriptors and cut scores) in reading/language arts and mathematics for grades 3-8 and 10/11.
- Approved alternate achievement standards linked to grade-level content standards.
- Approved achievement descriptors for science (due 2005-06).
- Completed alignment studies of the academic achievement standards and the alternate academic achievement standards to the content standards.
- Evidence that a diverse group of stakeholders will be involved in the development of the State's academic achievement standards and alternate academic achievement standards.
3.0 - FULL ASSESSMENT SYSTEM
- Documentation of the process used to associate levels of cognitive complexity with each benchmark and/or assessment item for the MCA-II.
- Documentation of how the TEAE aligns with the new language arts content standards, achievement standards, and MCA-II assessments.
- Validity study showing that the reading section of the TEAE is comparable to the reading MCA-II, and documentation that scores from the TEAE and MCA-II generate comparable scores.
4.0 - TECHNICAL QUALITY
- Technical quality, validity and reliability of all assessments (those based on grade level and alternate achievement standards).
- Comparability of assessments, both regular and alternate. This includes comparability of various test alternatives used at each grade level and comparability of individual tests over time.
- Plans for equating the MCA-II, such as a signed contract with the scope of work and/or detailed plans of the equating process and timelines. Results from an equating study that equates the MCA IIs to the previous forms of this assessment.
- Updated accommodation guidelines for the new Minnesota assessment system and information that the use of such accommodations results in valid scores and that those scores can be aggregated with scores from non-accommodated assessments.
- Constancy in administration, scoring, analysis, and reporting for all of the grades and content areas when such assessments are handled by multiple contractors for the 2005-06 assessment system.
- Monitoring policies regarding the use of accommodations allowed for students with disabilities and LEP students.
5.0 - ALIGNMENT
- Alignment studies on all 2005-06 assessments demonstrating that the assessments cover the standards in a comprehensive fashion and reflect the full range of content standards and a plan for how any identified gaps or weaknesses will be addressed.
- Alignment studies on the alternate assessments (for students with disabilities and those given to LEP students) demonstrating these assessments are based on the State's content standards.
- Use of alignment studies to improve the alignment between the assessments and the content and achievement standards. Minnesota must provide evidence such as plans and timelines that specify when and how the state will use that information to make critical decisions to strengthen the overall alignment.
6.0 - INCLUSION
- Policy and procedures to ensure the inclusion of all students in the MCA-II in 2006.
- Policy and procedures pertaining to the inclusion of students in alternate assessments, including how parents and IEP team members will be trained in the new alternate assessment system.
- The use of accommodations for LEP students.
- Policies ensuring test results of LEP students who take either the TEAE or use an accommodation are included in determining AYP.
- Appropriate use of accommodations for students with disabilities.
- Policies and guidelines providing guidance to IEP teams about how to determine which assessment is most appropriate for individual students with disabilities (e.g., updated guidelines for student participation in alternate assessments in light of the new information in the December 2003 regulation on the 1% cap when calculating AYP).
- Training for IEP team members regarding State guidelines for determining students with the most significant cognitive disabilities who will be assessed based on alternate achievement standards.
7.0 - REPORTING
- Detailed plans for reporting results of all 2005-06 assessments.