June 27, 2007
Honorable Alice Seagren
Commissioner of Education
Minnesota Department of Education
1500 Highway 36 West
Roseville, Minnesota 55113
Dear Commissioner Seagren:
I am writing regarding our review of Minnesota's standards and assessment system under Title I of 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 Minnesota's efforts to monitor student progress toward challenging standards.
External peer reviewers and Department staff evaluated Minnesota's 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 Minnesota must provide in order to have a fully compliant system. Specifically, we did not find sufficient evidence to address all required elements regarding Minnesota's new alternate assessment based on alternate academic achievement standards for students with the most significant cognitive disabilities and the Mathematics Test for English Language Learners (MTELL). The complete list of evidence needed to address these concerns is on the last pages of this letter.
We know that the Minnesota will be able to address many of these concerns within the next few months. Therefore, we are not assigning an approval status to Minnesota's system at this time. Because that system is not fully approved, however, we will place a condition on Minnesota's 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 Minnesota 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 Minnesota 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 continuing Mandatory Oversight pursuant to 34 C.F.R. §80.12. 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 Minnesota's assessment materials. I hope you will find the reviewers' comments and suggestions helpful.
We look forward to working with Minnesota to support a high-quality standards and assessment system. If you would like to discuss this further, please do not hesitate to call Valeria Ford (202-205-2213) or Martha Snyder (202-260-0941) of my staff.
Kerri L. Briggs, Ph.D.
cc: Governor Tim Pawlenty
Summary of Additional Evidence that Minnesota Must Submit to Meet ESEA Requirements for its Standards and Assessment System
1.0 - ACADEMIC CONTENT STANDARDS
- Documentation on how the content standards in mathematics are challenging and rigorous.
2.0 - ACADEMIC ACHIEVEMENT STANDARDS
- Documentation of alternate achievement standards linked to grade-level content standards.
- Evidence of participation of a diverse group of stakeholders in the development of the alternate achievement standards.
4.0 - TECHNICAL QUALITY
- Technical manual for the alternate assessment.
- Comparability of the Math Test for English Language Learners (MTELL) to the Minnesota Comprehensive Assessments Series II (MCA-II). This includes comparability at each grade level and comparability of individual tests over time.
- Evidence that the use of accommodations on the MCA-II results in valid scores and that those scores can be aggregated with scores from non-accommodated assessments.
5.0 - ALIGNMENT
- Study of the alignment between the alternate assessment, the content standards, and the alternate academic achievement standards.
- Results of the linking and validity study planned for the MTELL.
- Evidence of a plan and timeline that specifies when and how the State will use the information from the alignment study to strengthen the overall alignment.
6.0 - INCLUSION
- Documentation and data to show that all students are included in the assessment system.
- Training documents for Individualized Education Program (IEP) team members regarding State guidelines for determining students with the most significant cognitive disabilities who will be assessed based on alternate academic achievement standards and training documents provided to parents regarding the alternate assessment based on alternate academic achievement standards.
7.0 - REPORTING
- Complete series of alternate assessment reports and reports for the MTELL. Evidence should include information that students taking the alternate assessment are aggregated into the totals for the school, district, and State.