June 25, 2008
The Honorable D. Kent King
Commissioner of Education
Missouri Department of Elementary
& Secondary Education
205 Jefferson Street, 6th Floor
Jefferson City, Missouri 65102
Dear Commissioner King:
I am writing in response to Missouri's request to amend its State accountability plan 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). Following our discussions with your staff, the approved changes are now included in an amended state accountability plan that Missouri submitted to the Department on June 12, 2008. I am pleased to fully approve Missouri's amended plan, which we will post on the Department's website. A summary of the amendments submitted for the 2007-08 school year is enclosed with this letter. As you know, any further requests to amend Missouri's accountability plan must be submitted to the Department for review and approval as required by section 1111(f)(2) of Title I of the ESEA.
Please also be aware that approval of Missouri's accountability plan for Title I, including the amendments approved herein, does not indicate that the plan complies with Federal civil rights requirements, including Title VI of the Civil Rights Act of 1964, Title IX of the Education Amendments of 1972, Section 504 of the Rehabilitation Act of 1973, Title II of the Americans with Disabilities Act, and requirements under the Individuals with Disabilities Education Act.
I am confident that Missouri will continue to advance its efforts to hold schools and school districts accountable for the achievement of all students. If you need any additional assistance to implement the standards, assessment, and accountability provisions of NCLB, please do not hesitate to contact Jessica Morffi (Jessica.Morffi@ed.gov) or David Harmon (David.Harmon@ed.gov) of my staff.
Kerri L. Briggs, Ph.D.
cc: Governor Matt Blunt
Amendments to Missouri's Accountability Plan
The following is a summary of the state's amendment requests. Please refer to the Department's website (www.ed.gov/admins/lead/account/stateplans03/index.htmll) for Missouri's complete accountability plan.
The following amendments are aligned with the statute and regulations:
Inclusion of all schools and LEAs (Element 1.1)
Revision: Missouri public schools that do not have grades assessed on the MAP (e.g., K-2 buildings) are linked with and receive AYP determinations on the basis of test results of the schools their students attend in subsequent years.
Revision: A school is considered new if the building serves less than 50 percent of the students it previously served or would have served due to grade promotion. A school that has been assigned a new building code due to, for example, the creation of a new facility or a change in grade configuration, will be identified for improvement based upon the AYP status of the prior building or buildings serving the students, unless the school meets the "new school" criteria.
Accountability decisions (Element 1.4)
Revision: Missouri describes the current timeline for making AYP decisions before the first day of school, including a 30-day appeal period. For clarification purposes Missouri should refer to Section 1116(b)(2)(C) of the statute which says: "Not later than 30 days after a[n LEA] provides the school with the opportunity to review such school-level data, the [LEA] shall make public a final determination on the status of the school with respect to the identification."
Sanctions for non-Title I schools (Element 1.6)
Revision: Missouri establishes sanctions for non-Title I schools and includes a reference to the "Understanding Your AYP" document, which outlines the sanctions for all schools in school improvement, corrective action, or restructuring. Non-Title I schools and districts must write a school improvement plan to address areas of deficiency. Non-Title I schools and districts may also lose eligibility for a waiver of their on-site Missouri School Improvement Program (MSIP) review.
Full academic year (Element 2.2)
Revision: Missouri's "full academic year" definition includes any student who is enrolled the last Wednesday in September and is enrolled in the same building or district as of the MAP administration, without transferring out of the building or district for a significant period of time and re-enrolling. A significant period of time is considered "one more than half of the eligible days between the last Wednesday in September and the MAP administration".
Inclusion of growth model (Element 3.1)
Revision: As approved by the Department through a flexibility agreement, Missouri will implement a growth model as a means of determining AYP for schools and districts. Details regarding the growth model can be found at www.ed.gov/admins/lead/account/growthmodel/index.html.
Calculation of Safe Harbor (Element 3.2)
Revision: Missouri clarifies the calculation of safe harbor as follows: if a school, district, or subgroup meets the participation requirement, AND the school, district, or subgroup meets the additional attendance/graduation rate indicator targets, AND the school, district, or subgroup decreases the percentage of students scoring below the proficient level by at least ten percent, then the school, district, or subgroup makes AYP using safe harbor.
Method for calculating status (Element 4.1)
Revision: AYP is not met at the school or district level if the participation rate, proficiency target, or additional indicator(s) is not met for any subgroup or the all students group. Safe harbor is applied if the participation rate and additional indicator(s) are met and the percentage of students scoring non-proficient decreases by at least ten percent from the previous year.
District improvement decisions are based on not meeting the AYP annual objective in the same content area (communication arts or mathematics) or an additional indicator for two consecutive years.
Inclusion of students with disabilities (Element 5.3)
Revision: Missouri districts may appeal to have the scores of students who were previously identified as students with disabilities included in AYP calculations for the students with disabilities subgroup for up to two years after those students stop receiving special education and related services.
Inclusion of students with limited English proficiency (LEP) (Element 5.4)
Revision: Missouri clarifies the definition of LEP and the criteria for exiting the LEP subgroup. Students exit LEP status once they attain English language proficiency as determined by the state's English language proficiency exam. After these students exit, they are in monitoring status and continue to be included in AYP accountability for the LEP subgroup for up to two years.
Minimum group size (Element 5.5)
Revision: Missouri will use a uniform minimum group size of 30 students for all student subgroups when calculating the achievement component of AYP.
Public schools and LEAs held to the same criteria for AYP (Element 1.2)
Revision: Missouri's district level indicators are MAP assessments, attendance rate, and graduation rate, which are all evaluated at the district level.
Definition of student achievement levels (Element 1.3)
Revision: Missouri clarifies its workbook to reflect the current achievement levels of the MAP-Alternate (MAP-A) assessments. The MAP and MAP-A assessment achievement levels are: Below Basic, Basic, Proficient, and Advanced.
Inclusion of all students (Element 2.1)
Revision: Missouri clarifies its workbook to reflect Missouri state law, which allows charter schools to declare LEA status. Missouri state law defines "public schools" as all elementary and secondary schools operated at public expense. Consequently, charter schools may declare LEA status or are considered public schools within the school district of location.
Students with disabilities (Element 5.3)
Revision: Missouri clarifies its workbook to describe the relationship between the grade-level expectations and the MAP-A. Resulting scores are reported in achievement levels that correspond to MAP achievement levels, which allow them to be aggregated with MAP scores for accountability purposes.
Limited English Proficient Students (Element 5.4)
Revision: Missouri clarifies its workbook to reflect its current policy of assessing students with limited English proficiency (LEP). All LEP students that have been in United States schools for more than one year participate in the MAP, with appropriate accommodations if necessary. LEP students who have been in schools in the U.S. for less than one year participate in the mathematics MAP assessment, with accommodations if necessary; however, they may be exempt from the first administration of the communication arts MAP assessment for which they are eligible. Neither the mathematics nor communication arts score will be included in AYP calculations for one AYP cycle. All identified LEP students take the Missouri English Language Learning Assessment (MAC II), the state's English language proficiency assessment.
Science assessments (Element 6.1)
Revision: Missouri outlines its science assessment implementation for 2007-08. Beginning with the 2007-08 school year, MAP science assessments at grade 5, 8, and 11 are mandatory for all public school districts.
Accountability system produces reliable decisions (Element 9.1)
Revision: Missouri includes the following statement regarding its efforts to ensure that its assessments have an acceptable level of reliability: Missouri's Technical Advisory Committee (TAC) and its assessment contractors (CTB/McGraw-Hill, Riverside Publishing Company, and Measured Progress) work together to ensure that statewide assessments used for accountability determinations produce scores that are valid and reliable according to the technical standards defined by The Standards for Educational and Psychological Testing, published jointly in 1999 by the American Educational Research Association, the American Psychological Association, and the National Council on Measurement in Education. In addition, all assessments include an appeals process for parents and/or districts if they feel that assessment data may not be correct.
The following amendment is not yet timely and therefore it is not approved at this time and may not be included in Missouri's accountability plan:
Timeline for new assessment (Element 1.4, 3.1, and 9.3)
This proposed amendment describes Missouri's plans to incorporate end-of-course (EOC) assessments into its assessment system for 2008-09. The Department will review the EOC assessments through the established assessment review process. Since the assessments are not yet a part of the Missouri standards and assessment system and evidence regarding these assessments has not been submitted for NCLB assessment peer review, this request may not be included in the accountability workbook at this time.