June 21, 2007
The Honorable Elizabeth Burmaster
Superintendent of Public Instruction
Wisconsin Department of Public Instruction
P. O. Box 7841
125 South Webster Street
Madison, WI 53707
Dear Superintendent Burmaster:
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 (ESEA), as amended by the No Child Left Behind Act of 2001 (NCLB).
In the letter to you on February 12, 2006, the Department enumerated one fundamental component as well as a number of additional technical issues that had not met the standards and assessment requirements of the ESEA. Specifically, the Department could not approve Wisconsin's standards and assessment system due to outstanding concerns regarding the technical quality and link to grade-level content standards of the Wisconsin Alternate Assessment for Students with Disabilities (WAA-SwD). The evidence Wisconsin submitted for peer review on May 21-25, 2007, demonstrated that Wisconsin's regular assessment meets all NCLB standards and assessment requirements. However, there remain concerns regarding the technical quality and link to grade-level content standards of the Wisconsin Alternate Assessment for Students with Disabilities (WAA-SwD) as administered in the 2006-07 school year. The plan Wisconsin submitted on April 11, 2007, demonstrates Wisconsin's commitment to address these concerns for the administration of the WAA-SwD in the 2007-08 school year. As indicated in the submitted plan, Wisconsin has already begun to develop a new alternate assessment based on alternate academic achievement standards that will be used to assess students with the most significant cognitive disabilities in the 2007-08 school year.
Because Wisconsin was not able to address the deficiencies for the administration of the WAA-SwD for the 2006-07 school year, Wisconsin cannot demonstrate that the full standards and assessment system it administered in 2006-07 meets NCLB requirements. As a result, Wisconsin's system remains Approval Pending and Wisconsin remains in Mandatory Oversight, as authorized under 34 C.F.R. §80.12. Under this status, we will place a condition on Wisconsin's fiscal year 2007 Title I, Part A grant award. Wisconsin may include the results of the alternate assessment based on alternate achievement standards in adequate yearly progress (AYP) determinations for the 2006-07 school year, so long as the percentage of proficient and advanced scores on that assessment does not exceed 1.0 percent of all students in the grades assessed at the district or State level.
In addition, Wisconsin must enter into an agreement with the Department demonstrating its commitment and investment of resources to be able to administer a fully approved standards and assessment system in the 2007-08 school year. Specifically, Wisconsin must submit a mutually acceptable timeline for how and when the remaining work will be completed and evidence submitted for peer review. In addition, Wisconsin must submit quarterly of its progress along this timeline. If, at any point, Wisconsin does not submit the evidence required or does not administer an approved standards and assessment system in 2007-08 that meets all NCLB requirements, the Department will initiate proceedings, pursuant to Section 1111(g)(2) of the ESEA, to withhold all or a portion of Wisconsin's Title I, Part A administrative funds, which will then revert to local educational agencies in Wisconsin.
I appreciate the steps Wisconsin has taken toward meeting the requirements of the ESEA, and I know you are anxious to receive full approval of your standards and assessment system. We are committed to helping you get there and remain available to provide technical assistance. 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 Valeria Ford (firstname.lastname@example.org) or Abigail Potts (email@example.com) of my staff.
Kerri L. Briggs, Ph.D.
Acting Assistant Secretary
cc: Governor Jim Doyle
SUMMARY OF ADDITIONAL EVIDENCE THAT WISCONSIN MUST SUBMIT TO MEET ESEA REQUIREMENTS FOR THE WISCONSIN STANDARDS AND ASSESSMENT SYSTEM
2.0 - ACADEMIC ACHIEVEMENT STANDARDS
- Evidence of approved/adopted alternate academic achievement standards for students with the most significant cognitive disabilities in reading/language arts and mathematics for each of grades 3 through 8 and high school.
- Evidence that the alternate academic achievement standards include for each content area:
- At least three levels of achievement, including two levels of high achievement (e.g., proficient and advanced) that determine how well students are mastering a State's academic content standards and a third level of achievement (e.g., basic) to provide information about the progress of lower-achieving students toward mastering the proficient and advanced levels of achievement;
- Descriptions of the competencies associated with each achievement level; and
- Assessment scores ("cut scores") that differentiate among the achievement levels
- Evidence that the Board or other authority has adopted all alternate academic achievement standards.
- Documentation that the State has reported separately the number and percent of those students with disabilities assessed against alternate academic achievement standards, those assessed on an alternate assessment against grade-level standards, and those included in the regular assessment (including those administered with appropriate accommodations).
- Evidence that the State has documented the involvement of diverse stakeholders in the development of its alternate academic achievement standards.
4.0 - TECHNICAL QUALITY
- Evidence that the State has documented validity (in addition to the alignment of the alternate assessment with the content standards), as described in the Standards for Educational and Psychological Testing (AERA/APA/NCME, 1999).
- For the alternate assessments, evidence that the State has provided documentation of the standard setting process including a description of the selection of judges, methodology employed, and final results.
- For the alternate assessments, evidence that the State has considered the issue of reliability, as described in the Standards for Educational and Psychological Testing (AERA/APA/NCME, 1999).
- Evidence that the State has ensured that its alternate assessment system is fair and accessible to all eligible students, including students with limited English proficiency.
- Evidence that the State has taken steps, such as bias review of items, to ensure fairness in the development of the alternate assessment.
- When different test forms or formats are used for the alternate assessment, evidence that the State has ensured that the meaning and interpretation of results are consistent.
- Evidence that the State has established:
- Clear criteria for the administration, scoring, analysis, and reporting components of its alternate assessment; and
- That the State has a system for monitoring and improving the on-going quality of its alternate assessment.
5.0 - ALIGNMENT
- Evidence that the State has taken steps to ensure alignment between its alternate assessment and the State's academic content and alternate academic achievement standards.
- Evidence that the State has developed ongoing procedures to maintain and improve alignment between the alternate assessment and standards over time, particularly if gaps have been noted.
6.0 - INCLUSION
- Evidence that the State has implemented alternate assessments for students whose disabilities do not permit them to participate in the regular assessment even with accommodations
- Evidence of guidelines and training that the State has in place to ensure that all students with disabilities taking the alternate are included appropriately in the State assessment system.
- Evidence that the State has developed clear guidelines for Individualized Educational Program (IEP) Teams to apply in determining which assessment is most appropriate for a student.
- Regarding the alternate achievement standards:
- Evidence that the State has developed clear guidelines for IEP Teams to apply in determining when a child's cognitive disability justifies assessment based on alternate academic achievement standards; and
- Evidence of the steps the State has taken to help regular and special education teachers and other appropriate staff know how to administer assessments, including making use of accommodations, for students with the most significant cognitive disabilities.
7.0 - REPORTS
- Evidence that the State's reporting system facilitates appropriate, credible, and defensible interpretation and use of its alternate assessment data.
- Evidence that the State has provided for the production of individual interpretive, descriptive, and [non-clinical] diagnostic reports that indicate relative strengths and instructional needs:
- Evidence that these individual student reports express results in terms of the State's alternate academic achievement standards rather than numerical values such as scale scores or percentiles;
- Evidence that these individual student reports provide information for parents, teachers, and principals to help them understand and address a student's specific academic needs. This information must be displayed in a format and language that is understandable to parents, teachers, and principals, for example through the use of descriptors that describe what students know and can do at different performance levels. The reports must be accompanied by interpretive guidance for these audiences; and
- Evidence that the State ensures that these individual student reports will be delivered to parents, teachers, and principals as soon as possible after the alternate assessment is administered.