December 9, 2005

Honorable Dwight Johnson
Interim Executive Director
Idaho State Board of Education
PO Box 83720
Boise, Idaho 83720-0037

Honorable Marilyn Howard
Superintendent of Public Instruction
Idaho Department of Education
650 West State Street
P.O. Box 83720
Boise, Idaho 83720-0027

Dear Mr. Johnson and Dr. Howard:

Thank you for submitting Idaho's assessment materials for 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 your State's efforts to monitor student progress toward challenging standards.

External peer reviewers and U.S. Department of Education (ED) staff evaluated Idaho's submission and found, based on the evidence received, that it did not meet most of the statutory and regulatory requirements of Section 1111(b)(3) of ESEA. However, based on consultations with your staff, ED expects that Idaho can take the necessary steps to come into full compliance this school year. The status of the Idaho assessment system is Final Review Pending. In this status, a State must clearly articulate to ED how it will meet the remaining requirements and be able to fully implement a compliant standards and assessment system by the end of the 2005-2006 school year. Idaho must address the critical elements summarized below that did not meet the NCLB standards and assessment requirements and submit additional evidence to the Department for peer review. Critical elements that have met the requirements need no further review.

1.0 - Academic Content Standards: Idaho meets the requirements for development of content standards for reading/language arts, mathematics, and science under NCLB.

2.0 - Academic Achievement Standards: Idaho partially meets this requirement. Although alternate achievement standards are not required, a State may develop them to measure the achievement of students with the most significant cognitive disabilities. Idaho has developed such standards. As soon as it provides documentation of ISBE approval/adoption of the alternate achievement standards, Idaho will meet the requirements of 34 C.F.R. 200.1(d). Idaho may be among the first States to have constructed an alternative assessment system acceptable under NCLB. However, Idaho does not meet this requirement for reading/language arts, mathematics, and science regular assessments at grades 3-8 and high school. The State set achievement standards at 10th grade and applied a mathematical formula to establish standards in grades 2 through 9. This approach is inconsistent with NCLB in that it does not account for State content standards or mastery of State content standards at specific grade levels.

3.0 - Full Statewide Assessment System: Idaho meets this requirement with the on-grade level ISAT.

4.0 - Technical Quality: Idaho partially meets this requirement for the regular assessments and meets this requirement for the alternate assessments. Remaining issues include the comparability of ISAT forms from year to year, reliabilities of ISAT with subpopulations, and other technical quality information that will result from revisions to Idaho's academic achievement standards.

5.0 - Alignment: Idaho partially meets this requirement for the regular assessments and meets this requirement for the alternate assessments. The State has studied the issue of alignment both for the ISAT and the IAA. Findings indicated substantial deficits in the match and breadth between regular assessment items and Idaho's content standards. The alignment analysis results of the alternate assessment were positive.

6.0 - Inclusion: Idaho meets this requirement.

7.0 - Reporting: Idaho partially meets this requirement for the regular assessments and meets this requirement for the alternate assessments. Individual student reports did not express results in terms of the State's academic achievement standards or provide descriptions of what students know and can do at different performance levels. Although ISAT reports included the number of students who took valid tests, enrollment or total tested/not tested were not reported. The State indicated that the majority (99 of 114) of districts immediately displayed scores on computer screens. However, no evidence was provided indicating how reports were to be delivered to parents.

Additional evidence is needed to show how Idaho meets the critical elements identified as not fully meeting the requirements under the NCLB. More detailed information of the additional evidence that Idaho will need to be in compliance with NCLB is provided beginning on page four.

When the required additional evidence has been submitted, it will be subject to peer and ED staff review. You will need to schedule a second peer review consistent with the previously announced dates. Enclosed with this letter are detailed comments from the peer review team that evaluated the Idaho assessment materials. The peer reviewers are experts in the areas of standards and assessments. This panel of experts review and discuss a State's submission of evidence and prepare a consensus report that is documented as the Peer Notes. I hope you will find the reviewers' comments and suggestions helpful.

We look forward to working with Idaho to support a high-quality assessment system. If you would like to discuss this further, please do not hesitate to call David J. Harmon (202-205-3554) or Darla Marburger (202-260-2032) of my staff.

Sincerely,

Henry L. Johnson

Enclosures

cc: Governor Dirk Kempthorne
Saundra DeKlotz

2.0 - ACADEMIC ACHIEVEMENT STANDARDS

Additional evidence is required that sets forth a recognized standard setting procedure, timeline for implementation, and includes substantial evidence (test blueprints, item specifications, and descriptions of competencies associated with each achievement level) that the achievement standards are aligned to the State's grade level content standards.

• Documentation is required including re-established academic achievement standards that are ISBE- approved and show alignment to the State's grade level content standards. This documentation must provide technical details and evidence of broad-based stakeholder participation in the process, including a high proportion of participants with specific content-area expertise.
• Additional evidence is required that indicates ISBE has formally adopted and approved the alternate academic achievement standards.

4.0 - TECHNICAL QUALITY

• Documentation to support the comparability of ISAT forms from year to year.
• Evidence supporting the reliabilities of ISAT with subpopulations.
• Related technical information resulting from the revision of academic achievement standards, as the methodology designed to set the original achievement standards was not technically acceptable.

5.0 - ALIGNMENT

• Additional evidence is required that demonstrates adequate alignment of ISAT with Idaho's academic content and achievement standards in reading/language arts and mathematics.

7.0 - REPORTING

• Documentation that includes the enrollment or total tested/not tested on the student report.
• Evidence is required that ISAT results on individual student reports are expressed in terms of Idaho's academic achievement standards with descriptions of what students know and can do at different achievement levels.
• Information is required regarding how individual student ISAT results are delivered to parents.

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