October 8, 2008

The Honorable Jim Rex
State Superintendent of Education
South Carolina Department of Education
1006 Rutledge Building
1429 Senate Street
Columbia, South Carolina 29201

Dear Superintendent Rex:

I am writing regarding our review of South Carolina’s science assessments under the Elementary and Secondary Education Act (ESEA), as amended by the No Child Left Behind Act of 2001 (NCLB).

As outlined in my letter of February 28, 2008, states had to meet four basic requirements in science for the 2007–08 school year. In particular, each state was required to: (1) have approved content standards in science; (2) administer a regular and alternate science assessment in each of three grade spans; (3) include all students in those assessments; and (4) report the results of the regular and alternate science assessments on state, district, and school report cards. After reviewing the evidence submitted, I am pleased to inform you that it appears that South Carolina has met the basic requirements for administering science assessments in 2007–08. However, South Carolina has not yet submitted data to the Department demonstrating that all students were included in the science assessments. Please let us know within 10 days of receipt of this letter when South Carolina will have those data available so that we can confirm that it has, in fact, met the basic requirements for administering science assessments in 2007–08. States that do not provide the outstanding evidence to verify that they have met the four criteria for the 2007–08 school year have not met the basic requirements of the statute and will be subject to consequences, such as withholding of Title I, Part A administrative funds.

In 2008–09, South Carolina must provide evidence for peer review that demonstrates full compliance of its science standards and assessments. In anticipation of that required peer review, South Carolina chose to participate in an optional technical assistance peer review in May 2008. I appreciate the efforts that were required to prepare for the technical assistance peer review and hope that the process provided useful feedback to support South Carolina’s efforts to monitor student progress toward meeting challenging science standards.

Based on the evidence received from South Carolina, which was reviewed by the peers and Department staff, we have concluded that South Carolina does not yet meet all the statutory and regulatory requirements of section 1111(b)(1) and (3) of the ESEA. Specifically, we have concerns with the technical quality and alignment of the science component of the Palmetto Achievement Challenge Tests (PACT) and the End-of-Course Program–Physical Science (EOCEP-PS) and require evidence regarding the inclusion of all students. In addition, the Department recently conducted a separate peer review of the South Carolina’s new alternate assessments based on alternate academic achievement standards for students with the most significant cognitive disabilities. A summary of that review and any concerns as they relate to reading/language arts, mathematics, and science assessments will be forthcoming in a separate letter.

The complete list of evidence needed to address the concerns with the South Carolina science assessments is enclosed with this letter. We have scheduled peer reviews for states’ science assessments for the weeks of October 25 through November 2, 2008, and March 23 through 27, 2009. All materials for review must be provided to the Department three weeks before the peer review is scheduled.

Please keep in mind that science assessments represent a piece of a state’s complete standards and assessment system, which also includes regular and alternate assessments for reading and mathematics. As stated in my letter to you on February 15, 2006, South Carolina’s standards and assessment system is currently fully approved. In order to remain fully approved, South Carolina must demonstrate that all components of its standards and assessment system, including general and alternate assessments for reading, mathematics, and science, comply with all ESEA requirements for standards and assessment systems as administered in 2008–09.

We look forward to working with South Carolina to support a high-quality standards and assessment system, of which science standards and assessments are an integral part. If you would like to discuss this further, please do not hesitate to contact Valeria Ford (Valeria.Ford@ed.gov) or Lauren Prehoda (Lauren.Prehoda@ed.gov) of my staff.

Sincerely,

Kerri L. Briggs, Ph.D.

Enclosure

cc: Governor Mark Sanford
Nancy Busbee

SUMMARY OF ADDITIONAL EVIDENCE THAT SOUTH CAROLINA MUST SUBMIT TO MEET ESEA REQUIREMENTS FOR SCIENCE STANDARDS AND ASSESSMENTS

2.0 – ACADEMIC ACHIEVEMENT STANDARDS

1. Complete achievement level descriptors for both the Palmetto Achievement Challenge Tests (PACT) and the End-of-Course Program–Physical Science (EOCEP-PS) that cover the full range of the performance level and not just the cut-score descriptors are required.
2. Technically sound standard setting for the EOCEP-PS that produces the required descriptors and cut-scores. Currently, the standards appear to be only pass/fail and lack the required number of levels of achievement.
3. Acceptable descriptors for the South Carolina Alternate Assessment (SC-Alt) that do not reference process tasks (such as participate, attend, observe) and contain sufficient description of content.

3.0 – FULL ASSESSMENT SYSTEM

1. Evidence that the PACT and EOCEP-PS science assessments address higher thinking skills, as per the recommendation of the Education Oversight Committee.

4.0 – TECHNICAL QUALITY

1. Evidence of consequential and discriminant/convergent validity for all tests. Criteria for the selection of judges for the PACT standard setting are also required.
2. Evidence regarding the reliability of scores for subpopulations for the PACT and EOCEP-PS, the conditional standard error of measurement (CSEMs) for the EOCEP-PS and the SC-Alt, as well as a plan to increase the overall reliability of assessments.
3. A plan to remedy the alignment gap noted by the Education Oversight Committee that assures the integrity of equating of the EOCEP-PS and addresses the alignment gaps related to the Inquiry and Physics standard.
4. The Technical Manual for 2008 for the PACT and EOCEP-PS assessments, including CSEMs at all levels, as well as a description of the linking and equating methodology.
5. Equating and calibration details for the SC-Alt.
6. A revised copy of page five of the PACT manual reflecting the elimination of the reference to out-of-level testing.

5.0 – ALIGNMENT

1. A comprehensive independent alignment study for the PACT and the EOCEP-PS.
2. A plan for addressing the concerns/findings from the SC-Alt alignment study.
3. Additional explanation of the SC-Alt linking design and the use of the Student Placement Questionnaire in determining starting tasks for the students.

6.0 – INCLUSION

1. Data that show that all students in the grades tested are included in the assessment system for both the PACT and EOCEP-PS.

7.0 – REPORTING

1. PACT and EOCEP-PS score reports that include performance descriptors, and guidance for interpretation and use.
2. PACT and EOCEP-PS summary reports that include the numbers of students tested/not tested or the total number of students enrolled/tested.

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