July 17, 2014

The Honorable Kevin Huffman
Commissioner of Education
State Department of Education
6th Floor, Andrew Johnson Tower
710 James Robertson Parkway
Nashville, TN 37243

Dear Commissioner Huffman:

I am writing regarding the Tennessee Department of Education’s (TDOE) decision to not administer in the 2014–2015 school year the Partnership for Assessment of Readiness for College and Careers (PARCC) consortium assessments, as originally indicated in its approved ESEA flexibility request. To meet the requirements of ESEA flexibility, a State educational agency (SEA) must develop and administer annual, Statewide, high-quality assessments aligned with college- and career-ready standards, and corresponding academic achievement standards, in reading/language arts and mathematics in grades 3 through 8 and once in high school. These assessments must be fully implemented no later than the 2014–2015 school year. Among other characteristics, a high-quality assessment must be valid, reliable, and fair for its intended purposes, produce student achievement data and student growth data that can be used to determine whether an individual student is college- and career-ready or on track to being college- and career-ready, and provide an accurate measure of student growth over a full academic year or course. In its approved ESEA flexibility request, TDOE met this requirement through its participation in PARCC. As a result of TDOE no longer administering PARCC in the 2014–2015 school year, it must amend its ESEA flexibility request to demonstrate how it will meet the requirement to develop and administer high-quality assessments aligned with college- and career-ready standards in reading/language arts and mathematics by the 2014–2015 school year. This letter details how TDOE must amend its request in order to remain in compliance with ESEA flexibility requirements.

The U.S. Department of Education (ED) provided an SEA with three options to address how it would meet the requirement to develop and administer high-quality assessments aligned with college- and career-ready standards: (a) provide evidence that the SEA is participating in one of the two State assessment consortia — i.e., PARCC or SBAC; (b) provide the SEA’s plan to develop and administer high-quality assessments aligned with college- and career-ready standards no later than 2014–2015; or (c) provide evidence that the SEA submitted previously developed high-quality assessments aligned with college- and career-ready standards to ED for peer review or provide a timeline of when the SEA will submit them for peer review.

Since TDOE is no longer administering PARCC assessments in the 2014–2015 school year, and TDOE contends that it is implementing ESEA flexibility by administering its own high-quality assessment aligned to college- and career-ready standards, TDOE must provide a description and, as needed, supporting evidence of the steps that it took to determine that its assessment is a high-quality assessment aligned with the State’s college- and career-ready standards, consistent with the definitions in the document titled ESEA Flexibility (available at: http://www.ed.gov/esea/flexibility/documents/esea-flexibility-acc.doc), including, in particular, a description of the steps TDOE took to obtain an independent evaluation of alignment of the assessment with the State’s college- and career-ready standards and feedback from the State’s technical advisory committee indicating that the assessment meets the high-quality assessment criteria.

Please note that the submission of this information does not constitute submission for the required peer review, nor would ED’s approval of the submission constitute approval of the assessments. Additional information is forthcoming about the ED’s process to review and approve State assessment systems.

To amend its approved request for ESEA flexibility, TDOE must submit both the amendment request template (available at: http://www2.ed.gov/policy/elsec/guid/esea-flexibility/index.html) and a redlined version of its currently approved request reflecting that it has changed its approach to developing and administering high-quality assessments. The information requested above may either be inserted into the redlined request or submitted as an attachment to the redlined request. TDOE must submit this amendment request as part of its request to extend flexibility for the 2014–2015 school year. ED will review the request and will notify TDOE, in writing, of its determination.

ED has already spoken with Hanseul Kang, your ESEA flexibility lead, regarding this amendment request. If you have any questions, please do not hesitate to contact Victoria Hammer of my staff at: victoria.hammer@ed.gov.

Sincerely,

Deborah S. Delisle
Assistant Secretary

cc: Hanseul Kang, Chief of Staff