June 23, 2006
The Honorable Peter McWalters
Commissioner of Education
Rhode Island Department of Education
255 Westminster Street
Providence, RI 02903
Dear Commissioner McWalters:
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 peer review of Rhode Island’s standards and assessments, which occurred May 10-12, 2006. The results of this peer review process indicated that additional evidence was necessary for Rhode Island 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 may 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 Rhode Island system is Approval Pending. This status indicates that Rhode Island’s standards and assessment system administered in 2005–06 has one fundamental component that does 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 Rhode Island can address the outstanding issues by the next administration of its assessment system, that is, by the end of the 2006–07 school year.
Rhode Island’s system has one fundamental component that warrants the designation of Approval Pending. Specifically, we cannot approve Rhode Island’s alternate assessments based on alternate achievement standards for students with the most significant cognitive disabilities as administered in the 2005-06 school year. Two-thirds of eligible students took one version of the alternate assessment and one-third took a pilot version of the new Rhode Island Alternate Assessment (RIAA). The alternate assessment administered to two thirds of students with significant cognitive disabilities in 2005-06 does not meet the requirements for an alternate assessment based on alternate achievement standards because it does not yield separate valid results in reading and mathematics for AYP, nor report results by performance level within content area to parents and teachers. Please refer to the enclosure for a detailed list of evidence Rhode Island must submit to meet the requirements for an approved standards and assessment system.
Accordingly, Rhode Island is placed under Mandatory Oversight, pursuant to 34 C.F.R. §80.12. Under this status, there will be specific conditions placed on Rhode Island’s fiscal year 2006 Title I, Part A grant award. Rhode Island 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, Rhode Island must also provide bi-monthly reports on its progress implementing the plan. If, at any time, Rhode Island 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 10 percent of Rhode Island’s fiscal year 2006 Title I, Part A administrative funds, which will then revert to local educational agencies in Rhode Island.
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 call Abigail Potts (firstname.lastname@example.org) or Sue Rigney (email@example.com) of my staff.
cc: Governor Donald L. Carcieri
Summary of Additional Evidence that Rhode Island Must Submit to Meet ESEA Requirements for the Rhode Island Assessment System
1.0 - ACADEMIC CONTENT STANDARDS
- Documentation of Board approval of science content standards.
2.0 - ACADEMIC ACHIEVEMENT STANDARDS
- A detailed description of standard setting for the revised RIAA to be carried out this summer on the basis of pilot results.
- Documents showing that the State Board has approved the alternate achievement standards and performance descriptors for the revised RIAA.
4.0 - TECHNICAL QUALITY
- A completed technical manual for the NECAP that includes:
- An investigation of the relationship of the domains and sub-categories;
- Studies of the relationship of the NECAP with external measures;
- Interpretation of the reliability information for the total test, sub scores, and classification consistency at the cut scores;
- Test development process, bias and sensitivity review, test form construction as well as the expertise of the panelists involved in these processes (e.g., race/ethnicity, special populations, region, and student SES populations);
- Detailed plan for equating tests from year to year, including the number of horizontal linking items used between years and the methodology for equating the items and tests; and
- A quality control process for monitoring test administrations including: administration irregularities and accommodation usage.
- The state must provide technical documentation for the revised RIAA including a detailed description of the design, technicalqualities, validity, reliability, and standard setting, as information is available from the pilot administration.
5.0 - ALIGNMENT
- The State must provide a clear description of how the test development process for NECAP supports the alignment of the test and academic standards including:
- Item specifications in final form;
- Finalized test specifications and designs;
- Examples of cognitive level coding of items;
- Test design tables used for constructing each test;
- Test maps;
- The process for assessing the degree of match between the test maps and the test design; and
- Test development process establishes and maintains alignment to the GLEs.
- The State must provide a clear description of how the test development process for the alternate assessment supports the alignment of the test and academic standards.
- The state must conduct an independent alignment study or provide results from another appropriate procedure for the NECAP and the alternate assessment to confirm that the final test forms are aligned with the State’s standards.
6.0 - INCLUSION
- A description of the procedures used to ensure inclusion of special groups of students, including clear and concise descriptions of the processes used to ensure that all students are included in the assessment system, such as Rhode Island’s annual check of special education and LEP student census against assessment records.