June 22, 2006
The Honorable Susan Castillo
Superintendent of Public Instruction
Oregon Department of Education
255 Capitol Street NE
Public Service Building
Salem, Oregon 97310
Dear Superintendent Castillo:
Thank you for your participation in the U.S. Department of Education's (Department) standards and assessment peer review process 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). I appreciate the efforts required to prepare for the peer review. As you know, with the implementation of NCLB's accountability provisions, each school, district, and State is held accountable for making adequate yearly progress (AYP) towards having all students proficient by 2013-14. An assessment system that produces valid and reliable results is fundamental to a State's accountability system.
I am writing to follow up on the letter that was sent to you on January 25, 2006. In that letter we presented the results of the peer review of the Oregon standards and assessment system and detailed the additional evidence necessary for Oregon to meet the statutory and regulatory requirements of Section 1111(b)(1) and (3) of the ESEA. At this time, the need for that evidence remains.
As you will recall, the Department laid out new approval categories in the letter to the Chief State School Officers on April 24, 2006. These categories better reflect where States collectively are in the process of meeting the statutory standards and assessment requirements and where each State individually stands. Based on these new categories, the current status of the Oregon standards and assessment system is Approval Pending. This status indicates that Oregon's standards and assessment system administered in the 2005-06 school year has at least two fundamental components that are missing or that do not meet the statutory and regulatory requirements, in addition to other outstanding issues that can be addressed more immediately. These deficiencies must be resolved in a timely manner so that the standards and assessment system administered next year meets all requirements. The Department believes that Oregon can address the outstanding issues by the next administration of its assessment system, that is, by the end of the 2006-07 school year.
Oregon's system has a number of fundamental components that warrant the designation of Approval Pending. Specifically, the Department cannot approve Oregon's standards and assessment system due to outstanding concerns with the alignment of standards to grade-level content standards and the technical quality, including validity, reliability, and comparability of assessments in varying formats. Please refer to the enclosure for a detailed list of the evidence Oregon must submit to meet the requirements for an approved standards and assessment system.
Accordingly, Oregon is placed under Mandatory Oversight, as authorized under 34 C.F.R. §80.12. Under this status, there will be specific conditions placed on Oregon's fiscal year 2006 Title I, Part A grant award. In addition, Oregon must provide, not later than 25 business days from receipt of this letter, a plan and detailed timeline for how it will meet the remaining requirements to come into full compliance by the end of the 2006-07 school year. Beginning in September 2006, Oregon must also provide bi-monthly reports on its progress implementing the plan. If, at any time, Oregon does not meet the timeline set forth in its plan, the Department will initiate proceedings, pursuant to Section 1111(g)(2) of the ESEA, to withhold 15 percent of Oregon's fiscal year 2006 Title I, Part A administrative funds, which will then revert to local educational agencies in Oregon.
I know you are anxious to receive full approval of your standards and assessment system and we are committed to helping you get there. Toward that end, let me reiterate my earlier offer of technical assistance. We remain available to assist you however necessary to ensure you administer a fully approved standards and assessment system. We will schedule an additional peer review when you have evidence available to further evaluate your system. If you have any questions or would like to discuss this further, please do not hesitate to contact Patrick Rooney (Patrick.Rooney@ed.gov) or David Harmon (David.Harmon@ed.gov) of my staff.
Henry L. Johnson
cc: Governor Ted Kulongoski
Summary of Additional Evidence that Oregon Must Submit to Meet ESEA Requirements for the Oregon Assessment System
2.0 - ACADEMIC ACHIEVEMENT STANDARDS
- Additional evidence including approved, re-established academic achievement standards that show alignment to the State's grade level content standards with technical and stakeholder participation.
- Additional evidence including approved, re-established alternate academic achievement standards appropriately linked to Oregon's content standards.
- Additional evidence that all students are tested on academic content standards, not just on life skills.
- Document Oregon State Board of Education adoption of academic performance descriptors in science.
3.0 - FULL ASSESSMENT SYSTEM
- Document the consistency in achievement level definitions for adaptive and paper/pencil modes.
- Additional evidence supporting the comparability of tests based on the extended content standards and the Extended Career and Life Role Assessment (CLRAS).
- Additional evidence supporting the comparability of the plain language and regular test forms.
- Additional evidence supporting the comparability of the Juried assessments and the Knowledge and Skills Tests.
- Additional evidence supporting the comparability of Spanish and Russian side-by-side translations with English versions.
4.0 - TECHNICAL QUALITY
- Additional evidence for each assessment, including alternate assessments, that documents the standard setting process with descriptions of the selection of judges, methodologies employed, and final results.
- Additional evidence that adaptive tests are comparable to each other and paper/pencil versions at the achievement levels, restricted to grade-level content, and matched to detailed grade level test blueprints.
- Additional evidence that documents consistency of strand content among the paper-and-pencil and computer-adaptive versions that includes detailed test form construction rules and test maps.
- Additional evidence supporting the comparability of paper-and-pencil and computer-adaptive test difficulties between school years.
- Documentation that CLRAS (life skills) scores do not count for AYP, either alone or in combination with extended assessment scores.
- Documentation that supports the reliability and validity of alternate assessments.
5.0 - ALIGNMENT
- Document the alignment of 3-8 and high school assessments in reading/language arts and mathematics with academic content standards and with the re-established academic achievement standards.
- Document the alignment/linkages of the Oregon alternate assessments to the State's academic content standards and to re-established academic achievement standards.
7.0 - REPORTING
- Document that performance level descriptions appear on all student/parent reports.
- Document the existence of parent reports for extended assessments and for CLRAS.
- Document that alternate assessment performance ratings are tied to NCLB achievement levels used for reporting.