June 20, 2006
Dr. Gerald L. Zahorchak
Secretary of Education
Pennsylvania Department of Education
333 Market Street, 10th Floor
Harrisburg, PA 17126-0333
Dear Secretary Zahorchak:
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 May 8, 2006. In that letter we presented the results of the peer review of the Pennsylvania standards and assessment system and detailed the additional evidence necessary for Pennsylvania 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 Pennsylvania standards and assessment system is Approval Pending. This status indicates that Pennsylvania'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 Pennsylvania can address the outstanding issues by the next administration of its assessment system, that is, by the end of the 2006-07 school year.
Pennsylvania's system has a number of fundamental components that warrant the designation of Approval Pending. Specifically, the Department cannot approve Pennsylvania's standards and assessment system due to outstanding concerns with the technical quality, including the validity and reliability of the general assessment (the Pennsylvania System of School Assessment, or PSSA) for grades 4, 6, and 7 and the validity of the alternate assessment based on alternate achievement standards (the Pennsylvania Alternate System of Assessment, or PASA) and the alignment of both the PSSA and PASA with grade-level content standards. Please refer to the enclosure for a detailed list of the evidence Pennsylvania must submit to meet the requirements for an approved standards and assessment system.
Accordingly, Pennsylvania is placed under Mandatory Oversight, as authorized under 34 C.F.R. §80.12. Under this status, there will be specific conditions placed on Pennsylvania' fiscal year 2006 Title I, Part A grant award. In addition, Pennsylvania 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, Pennsylvania must also provide bi-monthly reports on its progress implementing the plan. If, at any time, Pennsylvania 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 Pennsylvania's fiscal year 2006 Title I, Part A administrative funds, which will then revert to local educational agencies in Pennsylvania.
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 Catherine Freeman (Catherine.Freeman@ed.gov) or David Harmon (David.Harmon@ed.gov )of my staff.
Henry L. Johnson
cc: Governor Edward G. Rendell
Summary of Additional Evidence that Pennsylvania Must Submit to Meet ESEA Requirements for the Pennsylvania Assessment System
1.0 - ACADEMIC CONTENT STANDARDS
- Develop and formally adopt challenging academic content standards in reading and mathematics at grades 4, 6, and 7.
2.0 - ACADEMIC ACHIEVEMENT STANDARDS
- Approved academic achievement standards for PSSA at grades 3, 4, 6, and 7 and PASA at grades 4, 6, and 7 with documentation of diverse stakeholder participation (for both the PSSA and PASA).
- Additional documentation showing that parents are informed about and understand the consequences of agreeing to the use of alternate assessments.
3.0 - FULL ASSESSMENT SYSTEM
- Comparability of grade 3 PSSA reading forms with common and matrix items.
- Comparability of direct Spanish translations of PSSA mathematics with the English versions.
- Plan for increasing the cognitive demand of PSSA items.
4.0 - TECHNICAL QUALITY
- Documentation of validity and reliability of the PSSA at grades 4, 6, and 7.
- Evidence of validity of the PASA.
- Technical quality documentation for PSSA standard setting at grades 3, 4, 6, and 7 and PASA standard setting at grades 3-8 and 11.
- Documentation that the State monitors assessment system and testing activities with special attention to auditing IEP and LEP accommodations.
5.0 - ALIGNMENT
- Detailed plans to improve PSSA reading and math alignment at grades 3, 5, 8, and 11 with academic content standards and achievement standards.
- Documentation (including detailed test blueprints) of reading and math PSSA alignment at grades 4, 6, and 7 with academic content and achievement standards.
- Documentation of PASA alignment with grade-level content standards.
6.0 - INCLUSION
- Documentation of the inclusion of all migrant students (in all grades) and students with the most severe cognitive disabilities in grades 4, 6, and 7.
- Enrollment and number of students assessed by grade level, content area, and subgroup on both the PSSA and PASA.