June 29, 2006
The Honorable Rafael Aragunde Torres
Secretary of Education
Puerto Rico Department of Education
P.O. Box 190759
San Juan, Puerto Rico 00919-0759
Dear Secretary Aragunde:
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 present the results of the peer review of Puerto Rico's standards and assessment system, which occurred on May 10-12, 2006, and to detail the additional evidence necessary for Puerto Rico to meet the statutory and regulatory requirements of Section 1111(b)(1) and (3) of the ESEA.
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 Puerto Rico standards and assessment system is Approval Pending. This status indicates that Puerto Rico'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 Puerto Rico can address the outstanding issues by the next administration of its assessment system, that is, by the end of the 2006-07 school year.
Puerto Rico's system has at least two fundamental components that warrant the designation of Approval Pending. Specifically, the Department cannot approve Puerto Rico's standards and assessment system due to outstanding concerns with the alignment of Las Pruebas de Aprovechamiento Académico (PPAA) to grade-level content standards and the performance level descriptors for the alternate assessment based on alternate achievement standards (Las Pruebas Puertorriqueñas de Evaluación Alterna, or PPEA). Please refer to the enclosure for a detailed list of the evidence Puerto Rico must submit to meet the requirements for an approved standards and assessment system.
Accordingly, Puerto Rico is placed under Mandatory Oversight, pursuant to 34 C.F.R. §80.12. Under this status, there will be specific conditions placed on Puerto Rico's fiscal year 2006 Title I, Part A grant award. Puerto Rico 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, Puerto Rico must also provide bi-monthly reports on its progress implementing the plan. If, at any time, Puerto Rico 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 Puerto Rico's fiscal year 2006 Title I, Part A administrative funds, which will then revert to Title I, Part A funds available for allocation to schools in Puerto Rico.
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 request reconsideration of the conditions, please do not hesitate to contact Patrick Rooney (Patrick.Rooney@ed.gov) or Carlos Martínez (Carlos.Martinez@ed.gov) of my staff.
Henry L. Johnson
cc: Governor Aníbal Acevedo Vilá
Waldo Torres Váquez
Summary of Additional Evidence that Puerto Rico Must Submit to Meet ESEA Requirements for the Puerto Rico Assessment System
2.0 - ACADEMIC ACHIEVEMENT STANDARDS
- Performance level descriptors for science.
- Performance level descriptors for basic levels on the Spanish and English as a Second Language assessments.
- Performance level descriptors for the alternate assessment.
4.0 - TECHNICAL QUALITY
- An analysis of the inter-correlations of sub-domains.
- An analysis of consequential and concurrent validity.
- An analysis of the efficacy and validity of accommodations.
- Completion of a technical manual for the alternate assessment for the operational test in 2005-06.
5.0 - ALIGNMENT
- A detailed plan and timeline that addresses the gaps in alignment that were identified in the alignment study.
- Documentation of the linkage of Las Pruebas Puertorriqueñas de Evaluación Alterna (PPEA) to content standards.
- Administration of an assessment aligned to content standards by April 2007.
- A plan to review and maintain alignment over time.
6.0 - INCLUSION
- An expansion of linguistic accommodations for limited Spanish proficient (LSP) students, such as English versions and simplified Spanish versions of the mathematics and science assessments.
- Policies, directives, and training on eligibility criteria for the PPEA.
7.0 - REPORTING
- Reports for results of the alternate assessment.