September 8, 2006

The Honorable Randy J. Dunn
Superintendent of Education
Illinois Board of Education
100 North First Street
Springfield, Illinois 62777

Dear Superintendent Dunn:

Thank you for submitting Illinois' assessment materials for a second peer review under the standards and assessment requirements of the Elementary and Secondary Education Act (ESEA), as amended by the No Child Left Behind Act of 2001 (NCLB). We appreciate the efforts required to prepare for the peer review and hope that the process provides useful feedback that will support Illinois' efforts to monitor student progress toward challenging standards.

In my letter to you on June 23, 2006, I enumerated the fundamental components as well as a number of additional technical issues that had not met the standards and assessment requirements of the ESEA after the first peer review in May 2006. Specifically, the Department could not approve Illinois' standards and assessment system due to fundamental concerns with the Illinois Measures of Annual Growth in English (IMAGE) assessment that is given to limited English proficient students; the technical quality of the Prairie State Achievement Examination (PSAE) and the Illinois Alternate Assessment (IAA); and the alignment of the PSAE and the linkage of the IAA to grade-level content standards. The peer reviewers and Department staff evaluated Illinois' second peer review submission and found, based on the evidence received, that it still does not meet all the statutory and regulatory requirements of Section 1111(b)(1) and (3) of the ESEA. Specifically, the peer review of this evidence suggests that there remain concerns regarding the IMAGE assessment in reading/language arts and the alignment of the PSAE to grade-level content standards. However, Illinois' new evidence was sufficient to address concerns with the technical quality of the PSAE and the IAA.

Because Illinois' second peer review did not resolve all outstanding issues, the status of its standards and assessment system remains Approval Pending. However, due to the fact that the State was able to show cause that it had satisfactorily addressed two of the four fundamental components listed in my letter of June 23, 2006, and because Illinois has joined the LEP Partnership to address concerns with the IMAGE assessment, the Department will not withhold Title I, Part A administrative funds for fiscal year 2006. Please note, however, that Illinois must address all outstanding issues in order to have a fully compliant standards and assessment system under the ESEA by the end of the 2006-07 school year. Please refer to the enclosure for a detailed list of the evidence Illinois must still submit to meet the requirements for an approved standards and assessment system.

Because the status of Illinois' standards and assessment system is still Approval Pending, Illinois continues to be under Mandatory Oversight, as authorized under 34 C.F.R. §80.12. Under this status, we placed specific conditions on Illinois' fiscal year 2006 Title I, Part A grant award. In addition, Illinois must provide, not later than 20 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 November 2006, Illinois must also provide bi-monthly reports on its progress implementing the plan. If, at any time, Illinois 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 Illinois' fiscal year 2006 Title I, Part A administrative funds, which will then revert to local educational agencies in Illinois.

I appreciate the steps Illinois 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. I also appreciate your willingness to join the LEP Partnership; we believe that this is the first step in providing Illinois assistance in improving the IMAGE assessment. We also remain available to provide technical assistance regarding other issues that you identify. 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 Patrick Rooney (Patrick.Rooney@ed.gov) or Grace Ross (Grace.Ross@ed.gov) of my staff.

Sincerely,

Henry L. Johnson

Enclosure

cc: Governor Rod R. Blagojevich
Becky McCabe

Summary of Additional Evidence that Illinois Must Submit to Meet ESEA Requirements for the Illinois Assessment System

2.0 - ACADEMIC ACHIEVEMENT STANDARDS

1. Documentation of grade-level or grade-span descriptors of competencies associated with alternate achievement standards for reading, mathematics, and science.
2. Clear guidelines to assist Individualized Education Plan (IEP) teams in deciding when a student should be assessed against alternate achievement standards.
3. Evidence of clear procedures for notifying parents and informing parents when a child's achievement will be based on alternate achievement standards and any possible consequences imposed by the district or State.
4. Documentation showing the number and percentage of students with disabilities taking the alternate assessments, the regular assessments with accommodations, and the regular assessments without accommodations for grades 3-8 and 11 in reading and mathematics for 2005-06.
5. Completed grade-level descriptions of the competencies associated with achievement standards in mathematics and reading for grades 3-8 and documentation of how these competencies relate to the content standards in the Illinois Assessment Frameworks.
6. More complete documentation of the involvement of appropriately diverse groups (e.g. representing English language learners and students with disabilities) in developing academic achievement standards, alternate achievement standards, and cut scores.

3.0 - FULL ASSESSMENT SYSTEM

1. Evidence of a coherent assessment system including the design of the current assessment system and how the individual assessments fit into a meaningful system describing student achievement relative to Illinois' academic content standards. This evidence should include:
   1. Additional evidence regarding how the State uses information from multiple assessments to make meaningful decisions about student achievement. In particular, evidence of the validity and reliability of overall scores when the Illinois Measures of Annual Growth in English (IMAGE) mathematics and reading scores are combined with ACT, WorkKeys, and Illinois State Board of Education (ISBE) scores (which together make up the Prairie State Achievement Exam, or PSAE, scores).
   2. Additional documentation of how scores from the ACT, WorkKeys, and ISBE are combined, including the relative contribution of each to the overall PSAE score, and how this affects the interpretation of overall scores as representative of performance on the Illinois Learning Standards.
2. Evidence showing that the IMAGE mathematics and reading assessments are comparable to the Illinois Standards Achievement Test (ISAT) and PSAE.
3. Evidence that the ISAT grade-level assessments measure higher order thinking skills and student understanding of challenging content.

4.0 -TECHNICAL QUALITY

1. Plans and a timeline for determining whether the assessments are producing intended and unintended consequences.
2. Additional evidence of the technical adequacy of the current ISAT. This should include:
   1. Evidence of validity;
   2. Results of sensitivity and bias reviews, DIF analyses, and evidence of how ISAT results are used;
   3. Documentation that cut scores set for the 2005-06 ISAT in each content area and grade level relate to student performance on the Illinois Learning Standards, as delineated in the 2005-06 Assessment Frameworks;
   4. Documentation of the reliability, conditional standard errors of measurement, and generalizability of the ISAT assessments for all grades and content areas;
   5. Documentation of procedures for ensuring consistency of scores over time, including equating procedures and the consistency of the meaning of scores over time;
   6. Documentation of quality control procedures for scoring, analysis, and reporting.
3. Evidence of the technical adequacy of the IMAGE:
   1. Evidence of validity;
   2. Procedures used for sensitivity and bias reviews, DIF analyses, and evidence of how results are used;
   3. Evidence that the IMAGE cut scores in mathematics are comparable in meaning to the ISAT and PSAE;
   4. Evidence of a content-based rationale for the IMAGE reading cut scores and evidence that the cut scores are equivalent in meaning (i.e., represent the same degree of knowledge and skills in Illinois grade-level content standards) to those on the ISAT and PSAE reading assessments;
   5. Documentation of the reliability, conditional standard errors of measurement, and generalizability.
4. Evidence of the technical adequacy of the Illinois Alternate Assessment (IAA):
   1. The use of procedures for sensitivity and bias reviews and evidence of how the results are used.
5. Evidence that the State monitors the provision and use of accommodations to ensure that appropriate types of accommodations are provided for students with disabilities.
6. Evidence of the provision of linguistic accommodations for limited English proficient (LEP) students.
7. Evidence that the use of accommodations provided in Illinois yields meaningful scores.

5.0 - ALIGNMENT

1. Results of the ISAT alignment study and plans addressing areas where results indicate improvements are needed.
2. Results of the alignment studies for the science assessments in grades 4 and 7.
3. Plans and timeline for the revision of the PSAE that will address gaps and weaknesses in alignment in reading, mathematics, and science.
4. A plan and timeline for the revision of IMAGE reading assessment and the plan for addressing the minor alignment gaps in mathematics.
5. A plan and timeline to address any identified weaknesses in the linkage of the IAA.

6.0 - INCLUSION

1. Evidence showing the number of students enrolled and number of students tested, for each subgroup, within grade levels and content areas.
2. Documentation of Statewide training where schools are encouraged to include students with the most significant cognitive disabilities in assessments against grade-levels standards when appropriate.

7.0 - REPORTING

1. Complete 2005-06 score reports for grades 3 through 8.
2. Documentation of participation rates (enrolled vs. assessed) for each grade level and content area, at the State, district, and school levels.
3. Evidence of the timely delivery of individual student reports to parents, schools, and school districts so that instructional decisions and parental notification can be made, as required by NCLB.
4. Evidence that PSAE scores in reading and mathematics are reported relative to Illinois academic content standards.

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