August 18, 2008

Dear Chief State School Officers:

I am writing to offer your State an opportunity to submit a proposal to incorporate a measure of individual student academic growth into its accountability system for the 2008-09 school year. To date, I have approved growth model proposals from eleven States.

As I have consistently stated, I believe that growth models promote two important goals. First, growth models provide States another effective way of determining adequate yearly progress (AYP) by measuring individual student growth over time. Second, these models continue to expand the flexibility available to States under NCLB. Accordingly, I am extending the Department's existing growth model pilot, and I encourage any eligible State to submit a growth model proposal.

A State interested in submitting a proposal must meet the following criteria, which are the same as those I laid out in each of the last three years:

• A growth model proposal must meet the following seven core principles:

  1. Ensure that all students are proficient by 2014 and set annual goals to ensure that the achievement gap is closing for all groups of students identified in the statute.
  2. Set expectations for annual achievement based on meeting grade-level proficiency, not based on student background or characteristics.
  3. Hold schools accountable for student achievement in reading/language arts and mathematics separately.
  4. Ensure that all students in tested grades are included in the assessment and accountability system, hold schools and districts accountable for the performance of each student subgroup, and include all schools and districts.
  5. Include assessments that produce comparable results from grade to grade and year to year in grades three through eight and high school in both reading/language arts and mathematics, that have been operational for more than one year, and that have received Full Approval or Full Approval with Recommendations before the State determines AYP based on 2008–09 assessment results.
  6. Track student progress as part of the State data system.
  7. Include student participation rates and student achievement on a separate academic indicator in the State accountability system.

• The State must be making progress in the following areas:

  1. Raising overall achievement and closing the achievement gap.
  2. Ensuring that information is accessible and timely and that parents have options.
  3. Improving teacher quality, including providing parents and the public with accurate information on the quality of the local teaching force.

Please note that, in an effort to help States develop sound proposals, we will distribute, in early September, revised peer review guidance for growth models. The revised guidance will not change the core principles listed above, but the intent is to help States organize their proposals in a manner that facilitates peer review and ensures that critical pieces necessary to evaluate the proposal are easily identifiable. In the meantime, it is still appropriate for interested States to review the current version of the guidance. It and previous State proposals can be found on the Education Department's Web site at http://www.ed.gov/admins/lead/account/growthmodel/index.html.

We have learned a great deal from the prior rounds of growth model peer reviews, both from the peer reviewers' feedback and from States' experiences in the field. We urge you to take these lessons into account in developing your proposal. For example, based on the peers' comments and concerns, we have concluded that wide confidence intervals are inappropriate in measuring individual student growth. In fact, we have not approved the use of any confidence intervals in the growth model pilot. We also believe that a State should incorporate all available years of existing data in creating its growth trajectory. Additionally, we have not looked favorably on models that reset targets each year, average or aggregate the growth of students in a school rather than measuring each student's individual growth, do not measure growth for proficient or advanced students, or do not consider the impact on student growth trajectories of varying school configurations and of student movement between schools and districts. For more detailed information on crosscutting issues identified by the peer reviewers, I recommend that you consult the peer reviewers' summary of their April 2006 review of growth model proposals, on-line at http://www.ed.gov/admins/lead/account/growthmodel/cc.doc. In addition, please be aware that we will consider a State's growth model proposal in the context of the State's full accountability system. In particular, we will seek to ensure that adding growth to a State's accountability system does not dilute accountability. Finally, I strongly encourage any interested State to ensure that all students are included in its growth model proposal to the extent possible, particularly students with disabilities who take an alternate assessment based on alternate academic achievement standards or an alternate assessment based on modified academic achievement standards.

Our review process will be similar to the process that we have used for the past three years. All proposals for participation in the growth model pilot are due to the Department by October 15. We will conduct an initial review of each proposal to ensure that the State meets the criteria listed above. If we have questions, we will contact each State by October 24 and ask the State to respond by November 7. Then, those proposals that we have determined meet the criteria above will be forwarded to a group of peer reviewers who will meet by early December. I anticipate reaching a final decision on the States selected to participate in the growth model pilot in December.

I view growth models as a key component of a common-sense approach to implementing NCLB. Growth models give States greater flexibility in tracking individual students' progress, creating a more nuanced accountability system while still adhering to the goal of 100 percent proficiency by 2013-14. My hope is that, by continuing to consider a variety of models, we can ensure that growth models contribute to State accountability systems in a meaningful and reliable way.

cc: Governors