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**Table of Contents**

[1.1. How does the State accountability model hold schools accountable
for universal proficiency by 2013-14? 5](#__RefHeading___Toc127781902)

[1.1.1. Does the State use growth alone to hold schools accountable for
100% proficiency by 2013-14? If not, does the State propose a sound
method of incorporating its growth model into an overall accountability
model that gets students to 100 % proficiency by 2013-14? What
combination of status, safe harbor, and growth is proposed?
5](#__RefHeading___Toc127781903)

[1.2. Has the State proposed technically and educationally sound
criteria for "growth targets" for schools and subgroups?
7](#__RefHeading___Toc127781904)

[1.2.1. What are the State's "growth targets" relative to the goal of
100% of students proficient by 2013-14? Examine carefully what the
growth targets are and what the implications are for school
accountability and student achievement. 7](#__RefHeading___Toc127781905)

[1.2.2. Has the State adequately described the rules and procedures for
establishing and calculating "growth targets"?
9](#__RefHeading___Toc127781906)

[1.3. Has the State proposed a technically and educationally sound
method of making annual judgments about school performance using growth?
9](#__RefHeading___Toc127781907)

[1.3.1. Has the State adequately described how annual accountability
determinations will incorporate student growth?
9](#__RefHeading___Toc127781908)

[1.3.2. Has the State adequately described how it will create a unified
AYP judgment considering growth and other measures of school performance
at the subgroup, school, district, and state level?
10](#__RefHeading___Toc127781909)

[1.4. Does the State proposed growth model include a relationship
between consequences and rate of student growth consistent with Section
1116 of ESEA? 11](#__RefHeading___Toc127781910)

[1.4.1. Has the State clearly described consequences the State/LEA will
apply to schools? Do the consequences meaningfully reflect the results
of student growth? 11](#__RefHeading___Toc127781911)

[2.1. Has the State proposed a technically and educationally sound
method of depicting annual student growth in relation to growth targets?
12](#__RefHeading___Toc127781912)

[2.1.1. Has the State adequately described a sound method of determining
student growth over time? 12](#__RefHeading___Toc127781913)

[3.1. Has the State proposed a technically and educationally sound
method of holding schools accountable for student growth separately in
reading/language arts and mathematics? 14](#__RefHeading___Toc127781914)

[3.1.1. Are there any considerations in addition to the evidence
presented for Core Principle 1? 14](#__RefHeading___Toc127781915)

[4.1. Does the State's growth model proposal address the inclusion of
all students, subgroups and schools appropriately?
15](#__RefHeading___Toc127781916)

[4.1.1. Does the State's growth model address the inclusion of all
students appropriately? 15](#__RefHeading___Toc127781917)

[4.1.2. Does the State's growth model address the inclusion of all
subgroups appropriately? 17](#__RefHeading___Toc127781918)

[4.1.3. Does the State's growth model address the inclusion of all
schools appropriately? 17](#__RefHeading___Toc127781919)

[5.1. Has the State designed and implemented a Statewide assessment
system that measures all students annually in grades 3-8 and one high
school grade in reading/language arts and mathematics in accordance with
NCLB requirements for 2005-06, and have the annual assessments been in
place since the 2004-05 school year? 19](#__RefHeading___Toc127781920)

[5.1.1. Provide a summary description of the Statewide assessment system
with regard to the above criteria. 19](#__RefHeading___Toc127781921)

[5.1.2. Has the State submitted its Statewide assessment system for NCLB
Peer Review and, if so, was it approved for 2005-06?
20](#__RefHeading___Toc127781922)

[5.2. How will the State report individual student growth to parents?
21](#__RefHeading___Toc127781923)

[5.2.1. How will an individual student's academic status be reported to
his or her parents in any given year? What information will be provided
about academic growth to parents? Will the student's status compared to
the State's academic achievement standards also be reported?
21](#__RefHeading___Toc127781924)

[5.3. Does the Statewide assessment system produce comparable
information on each student as he/she moves from one grade level to the
next? 21](#__RefHeading___Toc127781925)

[5.3.1. Does the State provide evidence that the achievement score
scales have been equated appropriately to represent growth accurately
between grades 3-8 and high school? If appropriate, how does the State
adjust scaling to compensate for any grades that might be omitted in the
testing sequence (e.g., grade 9)? Did the State provide technical and
statistical information to document the procedures and results? Is this
information current? 21](#__RefHeading___Toc127781926)

[5.3.2. If the State uses a variety of end-of-course tests to count as
the high school level NCLB test, how would the State ensure that
comparable results are obtained across tests? \[Note: This question is
only relevant for States proposing a growth model for high schools and
that use different end-of-course tests for AYP.\]
22](#__RefHeading___Toc127781927)

[5.3.3. How has the State determined that the cut-scores that define the
various achievement levels have been aligned across the grade levels?
What procedures were used and what were the results?
22](#__RefHeading___Toc127781928)

[5.3.4. Has the State used any "smoothing techniques" to make the
achievement levels comparable and, if so, what were the procedures?
23](#__RefHeading___Toc127781929)

[5.4. Is the Statewide assessment system stable in its design?
24](#__RefHeading___Toc127781930)

[5.4.1. To what extent has the Statewide assessment system been stable
in its overall design during at least the 2004-05 and 2005-06 academic
terms with regard to grades assessed, content assessed, assessment
instruments, and scoring procedures? 24](#__RefHeading___Toc127781931)

[5.4.2. What changes in the Statewide assessment system's overall design
does the State anticipate for the next two academic years with regard to
grades assessed, content assessed, assessment instruments, scoring
procedures, and achievement level cut-scores?
24](#__RefHeading___Toc127781932)

[6.1. Has the State designed and implemented a technically and
educationally sound system for accurately matching student data from one
year to the next? 25](#__RefHeading___Toc127781933)

[6.1.1. Does the State utilize a student identification number system or
does it use an alternative method for matching student assessment
information across two or more years? If a numeric system is not used,
what is the process for matching students?
25](#__RefHeading___Toc127781934)

[6.1.2. Is the system proposed by the State capable of keeping track of
students as they move between schools or school districts over time?
What evidence will the State provide to ensure that match rates are
sufficiently high and also not significantly different by subgroup?
25](#__RefHeading___Toc127781935)

[6.1.3. What quality assurance procedures are used to maintain accuracy
of the student matching system? 26](#__RefHeading___Toc127781936)

[6.1.4. What studies have been conducted to demonstrate the percentage
of students who can be "matched" between two academic years? Three years
or more years? 26](#__RefHeading___Toc127781937)

[6.1.5. Does the State student data system include information
indicating demographic characteristics (e.g., ethnic/race category),
disability status, and socio-economic status (e.g., participation in
free/reduced price lunch)? 27](#__RefHeading___Toc127781938)

[6.1.6. How does the proposed State growth accountability model adjust
for student data that are missing because of the inability to match a
student across time or because a student moves out of a school,
district, or the State before completing the testing sequence?
27](#__RefHeading___Toc127781939)

[6.2. Does the State data infrastructure have the capacity to implement
the proposed growth model? 27](#__RefHeading___Toc127781940)

[6.2.1. What is the State's capability with regard to a data warehouse
system for entering, storing, retrieving, and analyzing the large number
of records that will be accumulated over time?
27](#__RefHeading___Toc127781941)

[6.2.2. What experience does the State have in analyzing longitudinal
data on student performance? 27](#__RefHeading___Toc127781942)

[6.2.3. How does the proposed growth model take into account or
otherwise adjust for decreasing student match rates over three or more
years? How will this affect the school accountability criteria?
28](#__RefHeading___Toc127781943)

[7.1. Has the State designed and implemented a Statewide accountability
system that incorporates the rate of participation as one of the
criteria? 28](#__RefHeading___Toc127781944)

[7.1.1. How do the participation rates enter into and affect the growth
model proposed by the State? 28](#__RefHeading___Toc127781945)

[7.1.2. Does the calculation of a State's participation rate change as a
result of the implementation of a growth model?
28](#__RefHeading___Toc127781946)

[7.2. Does the proposed State growth accountability model incorporate
the additional academic indicator? 28](#__RefHeading___Toc127781947)

[7.2.1. What are the "additional academic indicators" used by the State
in its accountability model? What are the specific data elements that
will be used and for which grade levels will they apply?
28](#__RefHeading___Toc127781948)

[7.2.2. How are the data from the additional academic indicators
incorporated into accountability determinations under the proposed
growth model? 29](#__RefHeading___Toc127781949)

Appendix A. Calculation of Growth Model Trajectory Benchmarks 30

Appendix B. Example of how AYP will be calculated for a school 33

Appendix C. Florida Comprehensive Assessment Test (FCAT) Developmental
Scale Score 36

**Florida's Application for the NCLB Growth Model Pilot**

**Peer Review Documentation**

**September 15, 2006**

1.  l00% Proficiency by 2014 and Incorporating Decisions about Student
    Growth into School Accountability

**[Evidence for Core Principle 1 Provided on Florida's
CD:]{.underline}**

-   1.1.1.1: State of Florida Consolidated State Application
    Accountability Workbook.

-   1.3.2.1: 2006 AYP Report---example, State Level Report

-   1.3.2.2: 2006 Guide to Calculating AYP

"The accountability model must ensure that all students are proficient
by 2013-14 and set annual goals to ensure that the achievement gap is
closing for all groups of students." (Secretary Spellings' letter,
11/21/05)

**Introductory note:** The purpose of the growth model pilot is to
explore alternative approaches that meet the accountability goals of
NCLB. The intention is not to lower the expectations for student
performance. Hence, a State's accountability model incorporating student
growth must ensure that all students are proficient by 2013-14,
consistent with the NCLB statute and regulations. Annual measurable
objectives for school performance on student growth measures must also
ensure that the achievement gap is closing for all groups of students.

1.  []{#__RefHeading___Toc127781902 .anchor}How does the State
    accountability model hold schools accountable for universal
    proficiency by 2013-14?

    1.  []{#__RefHeading___Toc127781903 .anchor}Does the State use
        growth alone to hold schools accountable for 100% proficiency by
        2013-14? If not, does the State propose a sound method of
        incorporating its growth model into an overall accountability
        model that gets students to 100% proficiency by 2013-14? What
        combination of status, safe harbor, and growth is proposed?

**Indicate which of the four options listed below is proposed to
determine whether a school makes adequate yearly progress (AYP) and for
identifying schools that are in need of improvement, and explain how
they are combined to determine AYP:**

1.  **Growth alone**

2.  **Status and growth**

3.  **Status, safe harbor, and growth**

4.  **Safe harbor and growth**

**The Department is planning to evaluate the use of growth models. Once
implemented, States participating in the growth model pilot project will
be expected to provide data showing how the model compares to the
current AYP status and safe harbor approaches.**

Florida will maintain its current annual measurable objectives to reach
universal proficiency by 2013-14. These targets apply to schools,
districts, and the state. The growth model trajectory, along with the
status model and safe harbor, will ensure that by 2014 all students will
either be proficient or "on track to be proficient" within three years.
Under Florida's new proposal, a subgroup will have AYP calculated using
the status, safe harbor criteria, and a growth model calculation. Each
subgroup will be able to demonstrate the AYP criteria have been met
using any of the three calculations. The status and safe harbor
calculations have been used to determine AYP in Florida in previous
years.

The growth model is a new AYP calculation where each student within a
subgroup with at least two years of FCAT data will be included in the
denominator for the growth calculation. The numerator will include any
student in the subgroup who is proficient or "on track to be proficient"
in three years. A school or district will meet AYP for that subgroup if
the percentage of students who are proficient or "on track to be
proficient" using this calculation meets or exceeds the current state
annual measurable objectives (51 percent in reading and 56 percent in
mathematics in 2006-07).

Florida will continue to evaluate and analyze how growth serves as a
measure of accountability in comparison to the current status model by
comparing the number of schools and districts that meet the AYP criteria
using each method. All students will be included in the calculations.

Currently, there are several criteria a school to make AYP, meet the
state's annual measurable objectives in reading and mathematics and
attain at least 95% participation on the Florida Comprehensive
Assessment Test (FCAT), or an alternate assessment, and if the school
meets the "other" indicator writing, with 90% at a 3.0 and the
graduation rate of at least 85% or improvement of at least 1% for these
two criteria. If one or more subgroups do not meet the state measurable
objectives in reading or mathematics, the "safe harbor" criteria are
applied. These criteria require that the school demonstrate, for each of
the subgroups that did not meet the state objectives that the percent of
"non-proficient" students decrease by 10%. In addition, the subgroup(s)
must have met the total schools writing and graduation rate criteria, as
well as the subgroups, and each subgroup must have attained at least 95%
assessment participation. This process, as well as Florida's current
proficiency benchmarks, is detailed in Florida's approved Accountability
Workbook. **(See evidence 1.1.1.1)**

Florida will continue to hold schools and districts accountable for
universal proficiency by 2013-14 using option #3, a combination of
Status, Safe Harbor, and Growth, in determining whether a school makes
AYP. Our proposed model for determining Adequate Yearly Progress (AYP)
uses a combination of annual proficiency, safe harbor, and growth in the
assessed performance of individuals to hold schools and districts, as
well as the state, accountable for reaching 100% student proficiency by
2013-14.

Florida has evaluated the use of this growth model compared to the
current status and safe harbor AYP calculations using last year's data
to compare the approaches. These results are shared in the following
table.

+------------------------------------------------------+--------+------+
| **Figure 1:**                                        | *      | **   |
|                                                      | *Yes** | No** |
| **AYP Determination**                                |        |      |
+------------------------------------------------------+--------+------+
| 2006 AYP Results                                     | 916    | 2281 |
|                                                      |        |      |
| Status and Safe Harbor **(No Growth Model)**         |        |      |
|                                                      |        |      |
| Reading 44% and Mathematics 50%                      |        |      |
+------------------------------------------------------+--------+------+
| 2007 Projected AYP Results based on 2006-07 data,    | 743    | 2460 |
| Status and Safe Harbor **(No Growth Model)**,        |        |      |
| Reading 51% and Mathematics 56%                      |        |      |
+------------------------------------------------------+--------+------+
| 2007 Projected AYP Results based on 2005-06 data,    | 938    | 2259 |
| Status and Safe Harbor and Growth Model              |        |      |
|                                                      |        |      |
| Growth Model = On Track to be Proficient in Three    |        |      |
| Years with Annual Cut Points, Reading 51% and        |        |      |
| Mathematics 56%                                      |        |      |
+------------------------------------------------------+--------+------+

-   ***What are the grade levels and content areas for which the State
    proposes to measure growth (e.g., from 2004-05 to 2005-06 in reading
    and mathematics for grade levels 3-8)?***

Florida assesses all students in reading and mathematics in grades 3-10
and measures student growth in grades 4-10, and includes retained third
graders. First time third graders are considered "on track to be
proficient" in the growth model. For AYP calculations in 2007, the data
from 2005-06 will be used in determining each student's growth benchmark
in reading and mathematics in grades 3-10. Determining "on track to be
proficient" for grade 3 students, who do not have a prior year score,
will be determined by proficiency. All grade 3 students will be included
in the growth model and considered "on track to be proficient" if they
are currently proficient in third grade. If the third grade student is
not proficient and does not have prior year data, then the student would
included in the growth model as NOT "on track to be proficient."

-   ***If the State does not propose to implement its Growth model in
    all grade levels 3-8 and high school and for both subjects, where
    are the gaps in Growth Model decisions and what are the implications
    of those gaps for school accountability?***

Florida will implement this model in grades 3-10 for both reading and
mathematics and therefore will not have any gaps in growth model
decisions in those grades. Growth model decisions are possible in grade
3 for retained students and students in grade 3 with no prior year data
will be considered "on track to be proficient" if they are currently
proficient on the grade 3 assessment.

1.  []{#__RefHeading___Toc127781904 .anchor}Has the State proposed
    technically and educationally sound criteria for "growth
    targets"[^1] for schools and subgroups?

    1.  []{#__RefHeading___Toc127781905 .anchor}What are the State's
        "growth targets" relative to the goal of 100% of students
        proficient by 2013-14? Examine carefully what the growth targets
        are and what the implications are for school accountability and
        student achievement.

To ensure consistency in our approach to meeting the goal of 100% of
students proficient by 2013-14, Florida will use the annual measurable
objectives established in Florida's approved Accountability Workbook as
the growth targets for use in growth model decisions. **(See evidence
1.1.1.1.)**

-   ***The State should note if its definition of proficiency includes
    "on track to be proficient" or a related growth concept. For
    example, a State may propose that a student who is not proficient in
    the current grade must be on track to proficiency within three years
    or by the end of the grade span (e.g., elementary).***

Based solely on student performance and ignoring demographic factors,
Florida proposes that its three year growth trajectories will capture
students who will be proficient within three years of entering the
tested grades in Florida.

The three-year growth trajectory is built based on students' previous
test scores compared to proficiency at a later point in time. For a
third grade student (as an example), their baseline score from the end
of third grade on the Florida Comprehensive Assessment Test (FCAT)
Developmental Scale Score (DSS) -that is a continuous scale used from
grade 3 through grade 10 will be used. The numeric difference between
their third grade DSS score and the DSS to be proficient at the end of
the sixth grade will be calculated. At the end of the fourth grade, if
their DSS score has closed the distance from the third grade baseline to
proficient at the end of sixth grade by at least one-third (33.3
percent) the student would count in the calculations as being "on track
to be proficient" in the growth model. Similarly, the same student could
count in the fifth grade if the student's (second year) score has closed
the gap by at least two-thirds (66.67 percent). In the sixth grade
(third year), the gap would be closed, meaning the student would need to
be at the proficient level.

The students "on track to be proficient" will be a percentage of all
students which will be used in determining if the school or district has
met its AMO for the group(s) to which the student is a member.

In addition to "on track to be proficient," the other academic
indicators, writing, graduation, and participation targets, are still
required. If a group misses one of these targets they cannot recover
using growth calculations. The educational rational is straightforward.
Participation is not a function of growth, schools either administer the
appropriate assessments to their students or they do not.

The subgroup size and AMO targets are the same for each subgroup; there
is no differentiation. In this way, our proposed methods still directly
maintain and adhere to the original tenant of NCLB -- closing
achievement gaps between groups with no exceptions. Florida will use a
definition of proficiency that includes both students who are proficient
and "on track to be proficient". A student will be considered "on track
to be proficient" if his or her individual trajectory meets or exceeds
the proficiency cut points each year to attain the proficiency threshold
in three years or less. A student will not be considered "on track to be
proficient" if his or her trajectory does not reach the proficiency
threshold in three years based on meeting the cut points each year. For
students in high school, the end proficiency target is proficient on the
grade 10 FCAT.

-   ***A growth model that only expects "one year of progress for one
    year of instruction" will not suffice, as it would not be rigorous
    enough to close the achievement gap as the law requires.***

Florida's growth model maintains Florida's high expectations for student
proficiency by including only those students who will meet or exceed the
proficiency threshold in three years or less. As a result, the farther
below proficiency that students initially score, the more they must
improve in succeeding years in order to be on track to be proficient.

Florida believes this approach will continue the trend of rising student
achievement, and therefore, a closing of the achievement gap. The FCAT
results released in 2006 provide evidence of rising student achievement
in Florida. The greatest improvements over 2005 continued to be in
reading among elementary grades, with 70 percent of third, fourth and
fifth grade students reading at or above grade level, compared to 54
percent in 2001.

From 2001 to 2006, Florida students have shown significant progress in
both reading and mathematics. Last year, minority students continued to
narrow the achievement gap, with both Hispanic and African American
students improving nearly twice as fast in reading and three times as
fast in mathematics as their white counterparts (see Figures 2 and 3).
The data include the percentage of students scoring at Level 3 and
above. Five categories of achievement describe the success students have
with the content tested on FCAT reading and mathematics; Level 5 is the
highest, Level 1 is the lowest, with Levels 3 and above considered on or
above grade level.

+-------------------------+------+------+------+-----+--------+---+-------+
| **Figure 2:**           |      |      |      |     |        |   |       |
|                         |      |      |      |     |        |   |       |
| **Reading FCAT, Grades  |      |      |      |     |        |   |       |
| 3-10, Percent Level 3   |      |      |      |     |        |   |       |
| and Above**             |      |      |      |     |        |   |       |
+-------------------------+------+------+------+-----+--------+---+-------+
|                         | 2001 | 2002 | 2003 | 2   | 2005   |   | 2006  |
|                         |      |      |      | 004 |        |   |       |
+-------------------------+------+------+------+-----+--------+---+-------+
| White                   | 59%  | 60%  | 62%  | 63% | 64%    |   | 67%   |
+-------------------------+------+------+------+-----+--------+---+-------+
| African American        | 26   | 28   | 30   | 32  | 34     |   | 39    |
+-------------------------+------+------+------+-----+--------+---+-------+
| Hispanic                | 35   | 38   | 40   | 42  | 45     |   | 50    |
+-------------------------+------+------+------+-----+--------+---+-------+
| All Students            | 47   | 47   | 50   | 52  | 53     |   | 57    |
+-------------------------+------+------+------+-----+--------+---+-------+

+-------------------------+------+------+------+-----+-------+-------+
| **Figure 3:**           |      |      |      |     |       |       |
|                         |      |      |      |     |       |       |
| **Math FCAT, Grades     |      |      |      |     |       |       |
| 3-10, Percent Level 3   |      |      |      |     |       |       |
| and Above**             |      |      |      |     |       |       |
+-------------------------+------+------+------+-----+-------+-------+
|                         | 2001 | 2002 | 2003 | 2   | 2005  | 2006  |
|                         |      |      |      | 004 |       |       |
+-------------------------+------+------+------+-----+-------+-------+
| White                   | 63%  | 64%  | 66%  | 68% | 70%   | 72%   |
+-------------------------+------+------+------+-----+-------+-------+
| African American        | 26   | 27   | 31   | 34  | 37    | 41    |
+-------------------------+------+------+------+-----+-------+-------+
| Hispanic                | 41   | 42   | 46   | 49  | 53    | 56    |
+-------------------------+------+------+------+-----+-------+-------+
| All Students            | 50   | 51   | 54   | 56  | 59    | 61    |
+-------------------------+------+------+------+-----+-------+-------+

2.  []{#__RefHeading___Toc127781906 .anchor}Has the State adequately
    described the rules and procedures for establishing and calculating
    "growth targets"?

As explained in Section 1.2.1, Florida will use the annual measurable
objectives established in Florida's approved Accountability Workbook as
the growth targets for use in growth model decisions. **(See evidence
1.1.1.1.)**

2.  []{#__RefHeading___Toc127781907 .anchor}Has the State proposed a
    technically and educationally sound method of making annual
    judgments about school performance using growth?

    1.  []{#__RefHeading___Toc127781908 .anchor}Has the State adequately
        described how annual accountability determinations will
        incorporate student growth?

```{=html}
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```
A.  **Has the State adequately described and provided a rationale for
    how Annual Measurable Objectives (AMOs) or other criteria for growth
    would be determined? Has the State provided a table giving the
    values for the AMOs from the first year the growth model will be
    applied (e.g., 2005-06) through 2013-14 that includes rigorous
    increases in school performance throughout that time? Does the model
    set reasonable, challenging, and continuously improving annual
    expectations for student growth?**

    -   ***"Growth models that rely on substantial increases in the
        growth rates of students or schools in the last few years are
        not acceptable, but the Department is open to models that set a
        point in time as the goal (e.g., end of grade in a particular
        school; within four years). In setting these standards, the
        State should demonstrate how accountability is distributed among
        all the grades and not postponed to this point in time. The
        Department is concerned that if the State's Growth Model allows
        attainment of the proficiency standard by individual students to
        be delayed or is tied to standards that are not considerably
        more rigorous with each consecutive grade, then it becomes too
        easy to minimize or delay the importance of accelerated growth"
        (Secretary Spellings' letter, 11/21/05).***

As explained in section 1.2.1, Florida will use the annual measurable
objectives established in Florida's approved Accountability Workbook as
the growth targets for use in growth model calculations. **(See evidence
1.1.1.1.)** This approach maintains the high accountability expectations
while recognizing the growth of individual students. Because the FCAT
DSS required for a determination of proficiency, increases with each
grade level, the standards for proficiency are more rigorous with each
consecutive grade. Accountability is distributed among all grades
because a student will not be considered "on track to be proficient"
unless their proficiency trajectory will meet or exceed the proficiency
threshold in three years or less based on the annual cut point
benchmarks.

The method proposed follows a process presented at national
conferences/meetings and makes no adjustments for differences in student
background characteristics. It is straightforward and easy to understand
conceptually.

In Florida, the proficiency AMOs for reading and mathematics were set
using the method described in the NCLB legislation and subsequent
regulations. The decision was made to have annual increases in
proficiency goals on the way to universal (100%) proficiency by 2013-14.
The growth proposal honors the intent of this method by aligning the
targets for growth to the established AMOs. Each year, schools still
required to meet the AMOs. If a school does not meet this target using a
strict status model, the safe harbor and growth models will be applied.

B.  **For any proposed confidence intervals or other statistical methods
    to be applied to the decision about meeting the AMO for growth, has
    the State clearly described the rationale for the use of the
    specific statistical method (including minimum group size and any
    multi-year averaging), and the procedures for applying the method?**

This question is not relevant to Florida because our model does not
propose the use of confidence intervals or other statistical methods in
making decisions about meeting or exceeding annual measurable objectives
for growth.

C.  **For future evaluation purposes, does the State's proposal provide
    evidence of the validity and reliability of the proposed growth
    model, including impact of use/non-use of the growth model on
    validity and reliability of overall school accountability
    judgments?**

Florida will provide evidence of the validly and reliability of the
proposed growth model for AYP determinations. Florida will conduct and
provide analysis of the difference between AYP determinations for status
and safe harbor and the model that include status, safe harbor, and
growth. Florida will also continue to model different growth scenarios
to determine if the three year growth trajectory is a valid measure
compared to other growth models. This will be done by modeling several
different growth scenarios and comparing the lists of schools to ensure
that all the models are capturing the same growth.

1.  []{#__RefHeading___Toc127781909 .anchor}Has the State adequately
    described how it will create a unified AYP judgment considering
    growth and other measures of school performance at the subgroup,
    school, district, and state level?

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A.  **Has the State proposed a sound method for how the overall AYP
    judgment (met/not met) for the school will be made, incorporating
    judgment of student growth?**

Florida will have a unified AYP determination when considering the
growth model and other measures of school performance at the subgroup,
school, district, and state levels. The growth model will be applied at
the same time the status and safe harbor criteria are calculated
providing a subgroup with one additional way to meet the AYP criteria.
For the purposes of creating a unified approach to meeting Florida's
goals, Florida will use the annual measurable objectives established in
Florida's approved Accountability Workbook as the growth targets for use
in growth model decisions. **(See evidence 1.1.1.1.)**

B.  **Has the State proposed a sound method for how the overall AYP
    judgment for the school will incorporate growth in subgroup
    performance?**

-   ***Are the method and criteria for determining subgroup performance
    on growth the same as for students in the school as a whole?***

Each AYP determination will be made by calculating to determine if the
entity made AYP using the status model, safe harbor, and the growth
model. Schools and districts may make AYP with one or more subgroups
meeting requirements of the status model, one or more subgroups using
safe harbor, and one or more subgroups meeting the growth model
requirements. All subgroups must have at least 95% tested, the whole
school and the subgroup must meet the writing criterion, and the whole
school and the subgroup must meet the graduation criterion (for high
schools) to be eligible to use the safe harbor and growth model options
to make AYP.

C.  **Has the State proposed categories for understanding student
    achievement at the school level and reports for growth performance
    and AYP judgments that are clear and understandable to the public?**

With a few modifications, Florida will maintain the current format for
reports on AYP determinations **(see evidence 1.3.2.1)**. Florida has
found the current report format to be clear and understandable to the
public. The layout consists of: a summary of the AYP criteria met with
the use of a 39-cell matrix -- indicating which of the AYP criteria were
met and which criteria were not met (page 1), the school or district
level data that helped make the "yes" and "no" determinations reported
in the matrix (page 2), and details on the number of students that were
included in each of the AYP criteria (page 3).

This same format has been used the last three years. To the public
reviewing only the first page of the AYP report, the addition of the
growth model component will be transparent. Information regarding
whether a subgroup met AYP using growth will be provided along with the
status and safe harbor delineations. This information will allow the
public, schools, and districts, to be able to isolate the actual
performance using the growth component.

In addition, Florida will add the growth model component explanation
logic to the technical assistance paper currently available online
**(see evidence 1.3.2.2)**.

1.  []{#__RefHeading___Toc127781910 .anchor}Does the State proposed
    growth model include a relationship between consequences and rate of
    student growth consistent with Section 1116 of ESEA?

    1.  []{#__RefHeading___Toc127781911 .anchor}Has the State clearly
        described consequences the State/LEA will apply to schools? Do
        the consequences meaningfully reflect the results of student
        growth?

-   ***The proposed interventions must comply with the Section 1116
    requirements for public school choice, supplemental educational
    services, and so on.***

-   ***If proposed, the State should explain how it plans to focus its
    school intervention efforts by incorporating the results from a
    growth model. For instance, a State should be prepared to explain
    how a school that does not meet either traditional AYP goals or
    growth-based accountability goals might be subject to more rigorous
    intervention efforts than schools not making AYP on only one
    accountability measure.***

Florida's growth model does not change the current structure for
consequences. Florida's proposed growth model includes a relationship
between consequences and the rate of student growth consistent with the
No Child Left Behind Act. If a school or district makes AYP using the
growth model component, then the school or district is considered to
have made AYP. Florida will continue to require Title I schools that do
not meet AYP for two years in a row to provide the students in the
school choice with transportation options. For Title I schools not
making AYP for three years in a row, students will be offered
Supplemental Educational Services on a need first basis. Title I schools
that have not made AYP for four consecutive years are subject to
restructuring.

2.  Establishing Appropriate Growth Targets at the Student Level

**[Evidence for Core Principle 2 Provided on Florida's
CD:]{.underline}**

-   1.1.1.1: State of Florida Consolidated State Application
    Accountability Workbook

"The accountability model must establish high expectations for
low-achieving students, while not setting expectations for annual
achievement based upon student demographic characteristics or school
characteristics." (Secretary Spellings' letter, 11/21/05)

**Introductory note:** A State may, in its growth model, use student
longitudinal data to adjust for the fact that students who score below
proficiency may still be making substantial growth from year to year. As
part of including student growth in its AYP accountability model, a
State must establish how it would determine whether the growth achieved
by a student is adequate. Expectations for growth must not be based on
student demographics or school characteristics.

1.  []{#__RefHeading___Toc127781912 .anchor}Has the State proposed a
    technically and educationally sound method of depicting annual
    student growth in relation to growth targets?

    1.  []{#__RefHeading___Toc127781913 .anchor}Has the State adequately
        described a sound method of determining student growth over
        time?

        **A. Is the State's proposed method of measuring student growth
        valid and reliable?**

-   ***Are the "pre-" and "post-" test scores appropriately defined and
    adequately measured?***

-   ***If the State will not use a single score for pre- and/or post-
    test scores (e.g., using an aggregation of multiple scores from
    multiple years), does the State adequately explain and justify how
    the scores would be combined, what the weights are for each score,
    and how and whether the scores are/are not comparable across
    students and across time?***

-   ***Information about the availability and technical quality of
    proposed data will be considered in Core Principle 5. The probes
    associated with Principle 2 are focused on how the change in
    achievement is measured and valued.***

The three-year growth trajectory of students will be built using the
method detailed in Appendix A. Briefly, to build the three-year growth
trajectory, we must be able to use a student's starting point (initial
test score) and proficient ending point in three years and determine if
the student's actual scores in the interim are at or above that
trajectory benchmark. The student's initial score for most third graders
is the Florida Comprehensive Assessment Test (FCAT) administered at the
end of the third grade. The other grades growth will begin in fourth
grade using the end-of-grade assessment from the previous year as the
baseline. The target is the score on the state's growth scale that is
equivalent to the passing score on the test administered three years
after entry into the tested grades in Florida. For each year, the
trajectory target is a one-third (33.33 percent) decrease in the
difference from the baseline score on the state's growth scale to the
score necessary to be proficient on the test three years after entry
into a tested grade in Florida. Using this method, a student's position
on a trajectory path could be determined and documented as on- or
off-trajectory benchmark in any given year.

For students in grades 4-10 who are lacking the necessary prior year
scores, their participation is limited to their absolute status in AYP
calculations. Students who use alternate assessments that are not on the
FCAT developmental scale will have growth calculated based on progress
or improving achievement levels or maintaining a proficient level. It is
important to note that all Florida students are included in the growth
model. Proficient students are included in growth trajectories for AYP
purposes. Proficient students not meeting their growth targets will not
be considered "on track to be proficient." A student who scores
proficient is weighted the same as a student who is on track to be
proficient only if the proficient student meets his or her annual
benchmark. In this way, the growth of high-performing or proficient
students does not compensate for the lack of growth among other
students.

All students will be included in the growth trajectory, including highly
mobile students. As long as a student is enrolled in the current school
for the full year, the student will be included in the growth
trajectory. A student does not have to be in the school for multiple
years to be included.

B.  **Has the State established sound criteria for growth targets at the
    student level, and provided an adequate rationale?**

-   ***If the State is assigning a value determination at the student
    level annually with regard to each student's growth, has it used a
    sound process and assigned specific values for those growth targets?
    For example, if a State has four performance categories, would
    movement between each category be weighted equally or would some
    categories be weighted more heavily than others?***

The annual measurable objective, or growth target, may only be met by
students who are proficient or "on track to be proficient" using
Florida's approved definition of proficiency. Therefore, while all
growth is weighted equally, only students with a growth trajectory
meeting or exceeding the proficiency threshold will contribute to
meeting the growth target.

-   ***If the State would only calculate "difference" or "change" scores
    for each student, and then aggregating to the subgroup and/or school
    levels, then the State should clearly give its rationale in this
    section.***

This question is not relevant to Florida because our model is not simply
calculating a change or difference in scores for each student.

-   ***Would the model ensure that student growth expectations are not
    set or moderated based on student demographics or school
    characteristics? The model must have the same proficiency
    expectations for all students, while setting individual growth
    expectations for students to enable them to meet grade level
    standards.***

The growth model Florida is proposing ensures that the growth
expectations are not set or moderated based on student demographics or
school characteristics. The proficiency levels are the same statewide
based on grade level and subject (reading or mathematics). Only prior
year assessment data is used to determine a student's individual growth
trajectory to the proficiency standard.

-   ***If the State proposes a regression or multivariate/multi-level
    model, the independent variables may not include race/ethnicity,
    socio-economic status, school AYP status, or any other non-academic
    covariate.***

This question is not relevant to Florida because our proposed model does
not use a regression, multivariate, or multi-level model, to determine a
student's growth trajectory. The only student level data used to
determine the growth trajectory is the prior year and current year
assessment scores of that student.

-   ***Does the model establish growth targets in relation to
    achievement standards and not in relation to "typical" growth
    patterns or previous improvement, unless there is evidence and a
    clear rationale that those factors are related to the overall goal
    of achieving proficiency for all students?***

Florida's growth targets are established in relation to the percentage
of students meeting the achievement standards at the level of
proficiency. Florida will use the annual measurable objectives
established in Florida's approved Accountability Workbook as the growth
targets for use in growth model decisions. **(See evidence 1.1.1.1.)**

-   ***Would gains of high performing students compensate for lack of
    growth among other students?***

The gains of high performing students would not compensate for the lack
of growth among other students. High performing students are included
equally and carry the same weight as low performing students. The lower
performing students who meet their individual growth targets are
included in the growth model the same way a high performing, proficient
student is included. A high performing student cannot compensate for the
lack of growth if a a low performing student; all students carry the
same weight.

-   ***Does the State have a plan for periodically evaluating the
    appropriateness of the student-level growth targets criteria?***

Each year Florida will evaluate the progress of each student and the
accuracy of the growth expectation determined the prior year. Florida
will continue to calculate AYP using the status and safe harbor method
to determine the impact of the growth model. These results will be
analyzed to ensure that the growth calculation is a valid and reliable
measure of projected student performance.

3.  Accountability for Reading/Language Arts and Mathematics Separately

"The accountability model must produce separate accountability decisions
about student achievement in reading/language arts and in mathematics."
(Secretary Spellings' letter, 11/21/05)

**Introductory note:** The NCLB statute specifies that a State's
accountability system must produce separate accountability decisions
about student achievement in reading/language arts and mathematics. This
must also be true for school accountability decisions based on measures
of student growth.

1.  []{#__RefHeading___Toc127781914 .anchor}Has the State proposed a
    technically and educationally sound method of holding schools
    accountable for student growth separately in reading/language arts
    and mathematics?

    1.  []{#__RefHeading___Toc127781915 .anchor}Are there any
        considerations in addition to the evidence presented for Core
        Principle 1?

-   ***The growth model proposal must include separate decisions for
    reading/language arts and mathematics, and maintain validity and
    reliability, minimize measurement error, and support empirical
    integrity in the accountability system. How does the model achieve
    these specifications, especially in small schools or schools with
    high mobility?***

Florida's growth model will calculate growth using reading scores for
the reading results and mathematics scores for the mathematics results.
Separate reading and mathematics growth calculations will be used. A
student will have two growth trajectories and two proficiency
thresholds, one for reading and one for math. Likewise, there will be
two different calculations used in the growth model for determining if
the benchmarks have been met, one for determining reading and one for
determining mathematics. Thus, results will remain separate and clearly
delineated between reading and mathematics.

The determination of whether or not a student is on track to be
proficient is based only on the use of prior year student data and the
established proficiency threshold. These assessments, FCAT reading and
mathematics, and the DSS are valid and reliable measures of both student
and school achievement. Evidence of this claim is found in the annual
FCAT technical report. The model does not rely on complex statistical
procedures or imputed values for students. School-based fluctuations in
student growth (referred to as error) will be minimized in Florida
because the students on which growth will be calculated will be a true
cohort of students, unlike the current AYP determinations based on
year-to-year status scores and improvements. All data used in the AYP
determinations are actual data.

Schools that are very small or that have highly mobile populations will
still have an AYP determination. All full academic year students are
included in the AYP calculation.

-   ***Does the model include assessments for other content areas (e.g.,
    covariance matrices to estimate student performance or projected
    performance in a content area)? If so, the State should demonstrate
    that achievement on those other assessments does not compensate for
    failure to achieve proficiency in reading/language arts or
    mathematics.***

Florida's proposed growth model is not based on assessments for other
content areas nor does it rely on the use of covariance matrices to
estimate or project student performance. All growth trajectories for
reading and mathematics are respectively based on prior year scores and
each student's individual trajectory to proficiency in three years.

4.  Inclusion of All Students

**[Evidence for Core Principle 4 Provided on Florida's
CD:]{.underline}**

-   1.1.1.1: State of Florida Consolidated State Application
    Accountability Workbook.

"The accountability model must ensure that all students in the tested
grades are included in the assessment and accountability system. Schools
and districts must be held accountable for the performance of student
subgroups. The accountability model, applied statewide, must include all
schools and districts." (Secretary Spellings' letter, 11/21/05)

**Introductory note:** The State's growth model should hold schools
accountable for their students by including all students, consistent
with NCLB requirements (e.g., "full academic year" (FAY), and minimum
group size requirements). In addition, the State's model must include
all schools and districts.

1.  []{#__RefHeading___Toc127781916 .anchor}Does the State's growth
    model proposal address the inclusion of all students, subgroups and
    schools appropriately?

    1.  []{#__RefHeading___Toc127781917 .anchor}Does the State's growth
        model address the inclusion of all students appropriately?

**A.** **Ideally, every student will have a pre- and a post-score, and a
school will be clearly accountable for all students' achievement even
when applying the "full academic year" parameters. However, there will
be situations in which this is not the case. Are the State's proposed
rules for determining how to include student achievement results (when
data are missing) in the growth model technically and educationally
sound?**

-   **For example, if a State proposes to "impute" missing data, it
    should provide a rationale and evidence that its proposed imputation
    procedures are valid. A State proposing such a growth model must
    address how many students would be excluded from its calculations of
    growth because they lack a score, and provide an acceptable
    explanation of how these exclusions would not yield invalid or
    misleading judgments about school performance.**

This question is not relevant to Florida as our model does not allow for
imputing missing data. We believe imputing missing data may introduce
statistical error by inputting unessential data.

Florida will be using the same status and safe harbor model but adding a
growth model component. For this reason, two years of data are not
required for a student to be included in the AYP calculation. If the
student does not have two years of data, the student is still included
in every part of the AYP calculation, status, safe harbor,
participation, and other indicators (writing and graduation rate) but
will not be used in the growth model calculation if the growth model
calculation is used for that school with the exception of grade three
students where proficiency will be the indicator of being "on track to
be proficient" in three years.

Any full academic year student who participates in a valid test
administration will be included in the growth calculations either on the
basis of proficiency (when baseline scores are not available) or in the
trajectory calculation. No modification is made to the minimum N size of
30, or 15 percent of the tested school population, for a subgroup.

Florida will include all students, subgroups, schools, and districts in
the growth model. All students in all schools taking the Florida
Comprehensive Assessment Test or state approved alternate assessment for
Students with Disabilities or limited English proficient students will
be included in the growth model for reporting and for accountability
determination purposes.

The school as a whole and the subgroups are required to meet the 95%
participation rate. If the school does not meet this target, they have
not met AYP and growth cannot compensate for this issue.

-   **Does the State have an appropriate proposal for including students
    who participate with alternate assessments and/or alternate/modified
    achievement standards (in one or more years for calculating
    growth)?**

Florida is including alternate assessments in the proposed growth model
for the 2006-07 AYP determinations. Approximately one percent of
students take a reading alternate assessment and approximately one
percent of students take a mathematics alternate assessment. A growth
scale is applied to the alternate assessments these students take based
on improving an achievement level or maintaining a proficient level from
the prior year. These students will still be included in the status and
safe harbor calculations of AYP too.

-   **Does the State's definition of FAY include students appropriately
    when applied in the growth model context? For example, a State that
    defines FAY as "participating in the assessment in the same school
    the previous year" will need to modify that definition for its
    growth proposal to include students who cross school boundaries over
    time.**

Florida will include any student in the growth model that has current
year and prior year data (no prior year data is needed for grade three
students) regardless of where the student attended school the prior
year. Because the FCAT is given in the spring, a majority of the
instruction since the last administration occurred in the current year
school. The student must be in the same current year school for the full
academic year to be included in any AYP school calculation.

-   **What does the State propose to do to measure academic growth for
    students in grade three or the initial grade tested?**

Florida will include third grade students in the growth model
calculation using proficiency as the benchmark for being on track to be
proficient in the growth model. All third grade students are included in
the AYP calculation for status and safe harbor as well.

-   **How does the State propose to distinguish between growth for a
    student who moves from one grade level to another and growth for a
    student who is retained in a grade level for two years or is
    promoted at mid-year?**

Growth for a student, who moves from one grade to the next; is retained;
or promoted mid-year, will be calculated the same way. Students must
reach their annual individual targets to be considered "on track to be
proficient" in three years. A student who is retained for the full year
and tested in the same retained grade may still meet proficiency or be
"on track to be proficient" if the student meets the proficiency
standards for that year. Because FCAT is vertically aligned and has a
continuous developmental scale score it is possible to track student
performance against the state standard regardless of the grade in which
the student is enrolled.

B.  **What other strategies will the State use to include, in its NCLB
    accountability system, students who might be excluded from the
    growth model calculations?**

Florida will include all students in the AYP accountability system even
if they are not included in the growth model because all students will
be included in participation, status, and safe harbor, and other
indicators (writing and graduation rate).

1.  []{#__RefHeading___Toc127781918 .anchor}Does the State's growth
    model address the inclusion of all subgroups appropriately?

**A. States must ensure that student subgroups are neither
systematically nor inadvertently excluded from participation in the
growth model; the model cannot eliminate or minimize the contribution of
each subgroup. Are the State's proposed rules for determining how to
include subgroup accountability in the growth model technically and
educationally sound?**

-   **Has the State adequately addressed implications of its proposed
    growth model for subgroup inclusion in addition to that in Core
    Principle 1? (For example, has it addressed "minimum group-size"
    requirements for subgroups?)**

The minimum group size does not change when using a growth model. The
group size approved in Florida's Accountability Workbook (at least 30
students representing 15% of the school's tested population or 100
students) will be used in AYP and for the growth model calculation
**(see evidence 1.1.1.1)**. If the subgroup does not have this
requirement for the status model, the subgroup is not included in the
AYP calculation. However, if the subgroup has this cell size for the
status model, it will be included for the AYP calculation even if the
subgroup does not meet the subgroup size requirement for the growth
model calculation.

-   ***Does the State have an appropriate proposal for including
    students who change subgroup classification over the time period
    when growth is calculated (e.g., LEP to non-LEP)?***

If a student changes subgroup classification over the growth trajectory
time period, the student will be included in the subgroup he is reported
in during the current year of the calculation.

-   ***If applicable, how does the State proposal address the needs of
    students displaced by Hurricanes Katrina and Rita? For example, how
    does the proposal interact with State plans, if any, to develop a
    separate subgroup of displaced students, consistent with the
    Secretary's guidance of Sept. 29, 2005.***

Florida does not have a separate plan for displaced students. Displaced
students will be treated like all other Florida students.

1.  []{#__RefHeading___Toc127781919 .anchor}Does the State's growth
    model address the inclusion of all schools appropriately?

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A.  **Does the State provide an adequate plan and rationale for how the
    system will be applied to all schools consistently across the State
    to yield an AYP determination each year? Has the State adequately
    described and provided a rationale for any proposed exceptions?**

    -   **The State may propose to apply the growth model only to
        schools with adequate assessment data. If that is the case, it
        should propose how other schools, such as K-2 schools,
        single-grade schools, and high schools, will be held accountable
        (e.g., through continuing its approved statutory AYP/safe harbor
        accountability system for those schools).**

Florida will include all students in the AYP accountability system
because all students will be included in participation, status, safe
harbor, and growth. Because Florida has a statewide K-20 Education Data
Warehouse, even single grade schools, like a ninth grade center, will
have a baseline data for their students from grade 8 and the trajectory
benchmarks. So when results from their grade 9 students in the current
year are available, a "on track to be proficient: calculation can be
completed. Also, since Florida has grade 9 and 10 assessments, high
schools are not typically limited to one grade. K-2 schools earn the AYP
designation of the intermediate 3-5 school that the students directly
feed into.

-   **The State should propose how it will deal with common conditions
    that would preclude the calculation of a growth score (e.g., school
    boundary changes, school closings, new schools, grade
    reconfiguration).**

Florida will include any student in the growth model that has prior year
data regardless of where the student attended school the prior year.
Because the FCAT is given in the spring, a majority of the instruction
since the last administration occurred in the current year school. The
student must be in the same school for the full academic year to be
included in any AYP school calculation.

-   **How would the model ensure that all schools are accountable for
    student achievement, even when the number of tested students in the
    school is small or constantly changing?**

Schools that are very small or that have highly mobile populations will
still have an AYP determination. However, these schools may not have the
opportunity to participate in the growth model component of AYP.

5.  State Assessment System and Methodology

**[Evidence for Core Principle 5 Provided on Florida's
CD:]{.underline}**

-   5.1.1.1: Section 1008.22, Florida Statutes, Student assessment
    program for public schools.

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-   5.1.1.2: Statewide Comparison of Reading/Mathematics Scores.

-   5.1.1.3: 2005 Understanding FCAT Reports.

-   5.1.1.4: Individual Student Report -- Sample 2006.

-   5.1.1.5: 2005 FCAT Demographic Reports for the SSS and NRT, Grades
    3-10.

-   5.1.1.6: FCAT Demographic Reports Website (screen shots included).

-   5.2.1.1: FCAT Developmental Scale Score Website.

-   5.2.1.2: FCAT Developmental Scale Score DPS Memorandum #03-015.

-   5.3.1.1: FCAT Technical Report on Vertical Scaling for Reading and
    Mathematics.

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-   5.3.3.1: FCAT 2005 Technical Report, pages 51-58 (Reliability) and
    pages 65-68 (Classification Accuracy).

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-   5.3.3.2: 2001 Standard Setting Report for Reading (3, 5, 6, 7, & 9)
    and Mathematics (3, 4, 6, 7, & 9).

-   5.3.4.1: FCAT Standard Setting Procedures, PowerPoint presentation
    at the January 17, 2002, CIA Conference.

-   5.4.1.1: FCAT Handbook

-   5.4.2.1: Sunshine State Standards Proposed Six-year Cycle

"The State\'s NCLB assessment system, the basis for the accountability
model, must include annual assessments in each of grades three through
eight and high school in both reading/language arts and mathematics,
must have been operational for more than one year, and must receive
approval through the NCLB peer review process for the 2005-06 school
year. The assessment system must also produce comparable results from
grade to grade and year to year." (Secretary Spellings' letter,
11/21/05)

**Introductory note:** NCLB requires a student assessment system that
produces timely and accurate information. Under the statutory scheme,
decisions about AYP are based on the "academic status" of students
compared to a target---the State's annual measurable objectives -- or
the change in the percentage of students who are not proficient. All
States have submitted accountability plans that fit within this
structure. Measuring student depends upon the quality of the State's
assessment system. An assessment system that is adequate for the
"status" or "safe harbor" model might not be adequate for a growth
model.

1.  []{#__RefHeading___Toc127781920 .anchor}Has the State designed and
    implemented a Statewide assessment system that measures all students
    annually in grades 3-8 and one high school grade in reading/language
    arts and mathematics in accordance with NCLB requirements for
    2005-06, and have the annual assessments been in place since the
    2004-05 school year?

    1.  []{#__RefHeading___Toc127781921 .anchor}Provide a summary
        description of the Statewide assessment system with regard to
        the above criteria.

-   ***For both 2004-05 and 2005-06, did the State implement an
    assessment system that measures State adopted content standards in
    reading/language arts and mathematics?***

Florida has designed a standards-based assessment system in reading and
mathematics for students in grades 3-10 that measures students annually.
The annual assessment system for all grades 3-10 has been implemented
for the past six years, since 2000-01. The core components of the
Florida assessment began in 1998 with the administration of tests in
reading (grades 4, 8, and 10) and mathematics (grades 5, 8, and 10).
With the passage of Governor Bush's A+ Plan in 1999, the assessment was
expanded to grades 3-10, and reading and mathematics assessments at all
of these grade levels have been administered and reported since 2001,
which serves as the baseline. Consistent data on student learning gains
are available for the past five years 2001-2002, 2002-03, 2003-04,
2004-05, and 2005-06.[^2] The assessment of learning gains will continue
in 2006-07 and into the foreseeable future.

The annual standards-based assessment, called the Florida's
Comprehensive Assessment Test (FCAT), is based on the state's content
standards, the *Sunshine State Standards* (SSS), and approved in May
1996 by the Florida State Board of Education. These standards specify
challenging expectations for the educational achievement of Florida
students in seven content areas including reading, writing, science, and
mathematics. Beyond measuring the attainment of challenging content, the
FCAT program was developed to address all of the purposes and scope of
the state assessment program described in Florida Statutes, Section
1008.22, F.S. **(see evidence 5.1.1.1)**. This statute indicates that
Florida's assessment program is intended to provide information needed
to improve the public schools by enhancing **the learning gains** of all
students and informing parents of the educational progress of their
public school children.

Specifically, the program is intended to include for the following
provisions:

-   **To assess the annual learning gains of each student toward
    achieving the Sunshine State Standards**,

-   To provide data for making decisions regarding school
    accountability,

-   To identify the educational strengths of students,

-   To identify the readiness of students to be promoted to the next
    grade level or to graduate from high school,

-   To assess how well educational goals and performance standards are
    met at all levels,

-   To provide information to aid in the evaluation and development of
    educational programs and policies, and

-   To provide information on the performance of Florida students
    compared with others across the United States.

(Emphasis added.)

The annual proficiency results from FCAT are used to determine if the
schools, districts, and state of Florida have met AYP. Additionally, the
state also uses the annual learning gains data to determine if students
make progress from year to year, and if the lowest performing students
(lowest 25%) also make progress. These data are used to go beyond the
requirements of NCLB and provide a school grade (A-F) to each school. A
school that attains only a D or F does not make AYP even if the percent
proficient meets the AYP target.

-   ***Did the State produce individual student, school, and district
    test results for both years?***

Florida has been reporting student results for FCAT reading and
mathematics in grades 3-10 since 2001 **(see evidence 5.1.1.2)**. The
reports available for FCAT are extensive and include individual student,
school, and district reports, as well as state summaries. In order to
support appropriate uses and interpretations of the scores, Florida has
prepared a guide to the reports, called *Understanding FCAT Reports.*
This publication is designed to help educators understand how to
interpret the scores included on all reports of FCAT results. As a
result, educators are equipped to help parents and others make better
use of the information provided on the reports. **(See evidence
5.1.1.3)**

In the *Understanding FCAT Reports* publication, the Student and Parent
Report is described on page 7. This report includes information about
the total score and its meaning for one year, and also the comparison of
the student's historical scores available in the data base. The student
and parent report is designed to support appropriate use of the test
data and includes information on the amount of error (the Standard Error
of Measurement) associated with the score provided in the form of the
range of scores likely if the student were to be tested again. In
addition, the Content Scores (subdomains) are presented as raw scores to
provide transparency about the number of items on which these scores are
based. However, a comparison of these content scores to other students
in the state helps parents interpret their student's success. **(See
evidence 5.1.1.4)**

Several types of reports summarize FCAT scores for schools, districts,
and the state, also described in the *Understanding FCAT Reports*
publication. These reports present the data contained on the student
report, but aggregated across schools, districts, and the state. There
are lists of student scores, lists of school and district average
scores, and reports that breakout scores for various demographic groups
in schools, districts, and for the state as a whole.

Florida provides summary reports and demographic reports for both the
FCAT-SSS and the FCAT-NRT **(see evidence 5.1.1.5)**. In addition to the
printed reports, Florida also provides an electronic form of the reports
through a queriable web-based system **(see evidence 5.1.1.6)**.

1.  []{#__RefHeading___Toc127781922 .anchor}Has the State submitted its
    Statewide assessment system for NCLB Peer Review and, if so, was it
    approved for 2005-06?

-   **If it was not fully approved, what are the deficiencies and to
    what extent will they affect the State's ability to measure growth
    in each subject?**

-   **If the State has not yet received approval of its assessment
    system, when does the State plan to submit evidence of compliance
    with the NCLB standards and assessment requirements?**

Florida submitted the Standards and Assessment Peer Review documents to
USED for the review to be conducted in February 2006. It is anticipated
that Florida will be approved [without]{.underline} any deficiencies
that would affect the State's ability to measure growth in reading or
mathematics before the 2007 AYP designations are calculated.

1.  []{#__RefHeading___Toc127781923 .anchor}How will the State report
    individual student growth to parents?

    1.  []{#__RefHeading___Toc127781924 .anchor}How will an individual
        student's academic status be reported to his or her parents in
        any given year? What information will be provided about academic
        growth to parents? Will the student's status compared to the
        State's academic achievement standards also be reported?

        The student and parent report is introduced in section 5.1.1
        with supporting evidence 5.1.1.3 and 5.1.1.4. The information on
        this annual report provides both an indication of current
        academic status in relation to the states academic achievement
        standards (this year's score) and also an indication of academic
        status and growth over time. The student's current year academic
        status is reported as the FCAT DSS, the scale used to report
        grade-to-grade growth that is described more fully in the next
        paragraph, and as the academic achievement level using a color
        coded bar graph display. In addition, Florida's data system, in
        particular the use of a unique student identification code
        provides the opportunity to capture and retain historical
        information on student progress over time. Therefore, the
        student's academic status for all previous years is also shown
        on the student report sent home to parents. The historical trend
        data are compared to annual on-grade-level performance and
        projected growth and shown graphically. Showing students and
        parents the trend in performance enables them to evaluate
        progress over time. As noted in Section 5.1, the historical data
        included on the 2006-07 reports can include up to seven years of
        historical data for some students and five years of data for all
        students who have been in the Florida system for that many
        years.

Florida's DSS or the vertical scale scores, report student scores on a
scale ranging from 0 to 3000. This continuous scale begins low in third
grade and reaches its maximum in tenth grade. It allows student growth
to be monitored from one tested grade to the next. In addition to
reporting this score to students and parents on the individual student
report, Florida maintains a website where parents are able to better
understand the FCAT DSS and convert FCAT scale scores (used for
reporting prior to the use of the vertical scale) to development scale
scores **(see evidence 5.2.1.1)**. This website also provides a
comparison to the average scores of students in the same grade level.
Upon introduction of the FCAT DSS, a technical assistance memo was
distributed to school districts. Background and appropriate
interpretations are provided in DPS Memorandum #03-015 **(see evidence
5.2.1.2)** and in the *Understanding FCAT Reports* publication **(see
evidence 5.1.1.3)**.

2.  []{#__RefHeading___Toc127781925 .anchor}Does the Statewide
    assessment system produce comparable information on each student as
    he/she moves from one grade level to the next?

**The State assessment system -- that is the achievement levels and
content expectations -- needs to make sense from one grade to the next,
and even within achievement levels for it to support a growth model.
These probes will help the peers understand the assessment system's
capability for use in growth models.**

1.  []{#__RefHeading___Toc127781926 .anchor}Does the State provide
    evidence that the achievement score scales have been equated
    appropriately to represent growth accurately between grades 3-8 and
    high school? If appropriate, how does the State adjust scaling to
    compensate for any grades that might be omitted in the testing
    sequence (e.g., grade 9)? Did the State provide technical and
    statistical information to document the procedures and results? Is
    this information current?

In order to establish the growth scale for FCAT, an equating design had
to be developed and implemented. After tests were developed in reading
and mathematics for all grades 3 through 10 and field tested in 2000, an
equating design was established and put in place during the first year
of implementing the tests at all grades. The *FCAT Technical Report on
Vertical Scaling* **(see evidence 5.3.1.1.)** provides an overview of
the steps used to construct the vertical scales. Guidance for this
process was provided by the FCAT Technical Advisory Committee (TAC).
Each of the separate grade-level tests in FCAT is designed to
concentrate on content and skills defined for each grade by the grade
level expectations of the Florida Sunshine State Standards. These
grade-level differences were used to determine the equating links that
would be used to establish the FCAT development scale. Then equating
forms were prepared for each adjacent pair of grades and given to
students in a grade higher and a grade lower than the established grade
level in order to obtain information about grade level performance
differences on the selected test items. These equating forms were
administered to students using a matrix sampling approach during the
test administration of 2000-01. As described in the *FCAT Technical
Report on Vertical Scaling*.

While the Florida Department of Education was convinced the most
appropriate methodology for determining the grade-to-grade linkages and
establishing the overall vertical scale in 2000-01, it was not satisfied
that stability of the vertical scale could be taken for granted.
Therefore, in 2001-02 a validation of the vertical scaling methodology
was conducted. Data from this study was presented to and reviewed by the
FCAT TAC at its annual meeting. The validation (replication) study
resulted in similar grade-to-grade linkages and would have resulted in a
similar vertical scale. Because the results were so similar, the FCAT
TAC advised the Department to keep the initial scale, but to monitor the
stability of the links and the overall scale periodically using the
validations study approach. Consequently, the Department conducted a
second validation (replication) of the vertical scale study in 2004-05
and reviewed it with the FCAT TAC at its meeting in November 2005. Again
the conclusion was that the changing the vertical scale could not be
justified because the grade-to-grade linkages were similar and the
resulting vertical scale changes would be minimal. It was determined
that minor adjustments in the resulting scales would not change the
scale enough to warrant the confusion it would cause for students,
parents, and educators as they attempt to interpret student learning
gains and for the use of learning grades to determine school grades. The
FCAT DSS will continue to be studied approximately every three years
until such time as the results indicate a need to implement a
differently linked scale or the assessed content changes enough to
require a new scale.

Because the FCAT DSS in both reading and mathematics was developed using
contiguous grades, 3-10, no adjustment was necessary for missing grade
levels.

2.  []{#__RefHeading___Toc127781927 .anchor}If the State uses a variety
    of end-of-course tests to count as the high school level NCLB test,
    how would the State ensure that comparable results are obtained
    across tests? \[Note: This question is only relevant for States
    proposing a growth model for high schools and that use different
    end-of-course tests for AYP.\]

This question is not relevant to Florida because we use our
comprehensive assessment of reading and mathematics in grades 9 and 10
to assess growth from middle school through high school.

3.  []{#__RefHeading___Toc127781928 .anchor}How has the State determined
    that the cut-scores that define the various achievement levels have
    been aligned across the grade levels? What procedures were used and
    what were the results?

The annual FCAT Technical Report (**see evidence 5.3.3.1**) provides
detailed analysis of data, including performance by achievement levels
for all grades and information on the classifications accuracy for the
achievement levels across all grades. These data provide evidence that
support in 2001 Florida implemented a vertical scale that was used to
confirm the alignment of the recommended achievement standards across
grade levels and moderate them if needed.

The cut scores recommended for the achievement standards in Florida were
established via a process using the Bookmark method and modifications of
it. This method helps teachers and curriculum experts in making
recommendations about performance expectations for students that are
based on the academic content standards. Florida was among the first
states to apply these bookmark methodologies to its standards-based
state assessment. The bookmark process involves grade-level teachers and
curriculum leaders reviewing the content included in the test and
recommending four points at which the amount of knowledge and skill
required to be successful increases at the identified cut points.

[]{.mark}

Florida's academic achievement standards were recommended by groups of
Florida educators after a thorough review of the assessments and were
later adopted by the State Board of Education. Florida established
academic achievement standards for FCAT Reading and FCAT Mathematics in
three phases. In 1999, standards were established for the Reading and
Mathematics tests at three grade levels (the grades being tested at the
time). Later, graduation standards were established for the tenth grade
tests. In 2001, standards were established for the grade levels added to
the state assessment in 2000. All of these efforts used a methodology
similar to the bookmark process **(see evidence 5.3.3.1)**. In 2001,
Florida also implemented a vertical scale that was used to confirm the
alignment of the recommended achievement standards across grade levels
and moderate them if needed **(see evidence 5.3.1.1)**.

[]{.mark}

From time to time, the task of identifying points where an increased
content demand occurs is challenging for the panelists, especially when
the empirical evidence contradicts panelists' a priori ideas about
content difficulty. For example, the same content element or concept can
appear at several different difficulty levels in an ordered book,
especially when the complexity or density of the text, or the level of
cognitive application required in the test question alters the
difficulty of an item, without altering the content assessed. Therefore,
panelists are guided by a generic set of achievement descriptions to
help them make decisions **(see evidence 5.3.3.2)**.

4.  []{#__RefHeading___Toc127781929 .anchor}Has the State used any
    "smoothing techniques" to make the achievement levels comparable
    and, if so, what were the procedures?

The work on Florida's developmental scale was completed in the late
summer 2001, just prior to the Department's activities to establish the
academic achievement levels for the expanded grade levels, field tested
in 2000. The Department had previously, in the fall of 1998, established
academic achievement levels for reading at grades 4, 8, and 10 and
mathematics at grades 5, 8, and 10. At the September 2001 meetings the
development scale was used in before the final round of educator
judgments to compare of the 2001 achievement level recommendations to
the 1998 levels, as well as to compare the 2001 recommendations across
grade levels. They helped educators evaluate the degree of alignment of
their recommendations with the pre-existing standards. There was a clear
articulation among the group of participants that having achievement
standards that fluctuated greatly from grade-to-grade was confusing to
students, parents, educators, and other consumers of assessment results
and should be avoided. (Special note: This meeting will always be
memorable for the local and state educators involved because the meeting
began on the morning of September 11, 2001, and deliberations planned
for the first day were delayed to permit participants to contact family
members.)

Later in the process of setting achievement levels, that is, after the
educator recommendations were submitted for review by other groups,
Florida Department of Education staff used the developmental scale to
adjust the cut points for some achievement levels at some grade levels.
First, the trend lines were smoothed using a logarithmic function. The
result of this statistical smoothing was that the pre-established
standards for Grades 4 and 5 standards would have been lower and the
Grade 8 and 10 achievement levels would have been lower. Since the
academic achievement levels for these grades were already codified in
State Board (SBE) rule, the Department implemented a second statistical
smoothing that used these standards as fixed points during the smoothing
of the other grades. The second smoothing resulted in only one
problematic area -- little or no growth would occur in Grades 9 to 10.
Therefore slight mathematical adjustments were made to the ninth grade
cut scores to provide standardized expectations from 8^th^, to 9^th^, to
10^th^ grades. The final cut points were presented to the SBE in 2002
and adopted for use in reporting FCAT scores (see evidence 5.3.3.4). For
more detailed descriptions of the process used to establish the academic
achievement levels using the development scale, **see evidence 5.3.4.1**
and **5.2.1.2**.

3.  []{#__RefHeading___Toc127781930 .anchor}Is the Statewide assessment
    system stable in its design?

    1.  []{#__RefHeading___Toc127781931 .anchor}To what extent has the
        Statewide assessment system been stable in its overall design
        during at least the 2004-05 and 2005-06 academic terms with
        regard to grades assessed, content assessed, assessment
        instruments, and scoring procedures?

The FCAT developmental scale (vertical) has been stable for the past
five years, since 2001. As described under section 5.1, Florida's
statewide assessment system in reading and mathematics has been stable
in its overall design since 2000. The first operational assessment and
reporting of student scores took place in the spring of 2001 and the
establishment of the vertical scale occurred in that same year. Although
student growth was not reported until 2002 because two years of
contiguous data were needed, learning gains have been reported for all
students taking the tests each year since that time. Additionally, the
FCAT DSS system has proven to be stable as demonstrated through the
results of validation studies conducted in 2002 and 2005. **(See
evidence 5.4.1.1.)**

2.  []{#__RefHeading___Toc127781932 .anchor}What changes in the
    Statewide assessment system's overall design does the State
    anticipate for the next two academic years with regard to grades
    assessed, content assessed, assessment instruments, scoring
    procedures, and achievement level cut-scores?

-   **What impact will these changes have on the State's proposed growth
    model? How does the State plan to address the assessment design
    changes and maintain the consistency of the proposed growth model?**

Currently, Florida is beginning a new six-year cycle of review and
revision of the SSS that will focus first on the reading/language arts
standards and the mathematics standards **(see evidence 5.4.2.1)**.
Science and other curriculum areas will be reviewed and revised in
subsequent years. The new revised standards will include expectations
for each grade level and/or course, as appropriate. Depending on the
depth and breadth of the standards revisions, changes in the content
assessed may be needed. However, these changes will be methodically
implemented so that schools have the opportunity to focus instruction on
new skill areas and/or adopt newly aligned curriculum and instructional
materials. The process for modifying FCAT and the various scales for
reporting (including the vertical scale) will be determined based on the
extensiveness of the change in the standards assessed. Because the
degree of change in the standards is unspecified at this time, the
possible change in FCAT is only speculative. However two scenarios can
be anticipated.

-   If minor revisions to the content standards are made and there is
    minimal or moderate impact on the content tested on FCAT, the
    changes can be made over a two year period. During this time a third
    validation of the vertical place will occur and the vertical scale
    can be adjusted as necessary. The extent of the adjustment to the
    vertical scale would determine the impact on the accountability
    system and any needed changes. The earliest these changes could be
    determined would be in 2007-08.

-   If the revisions to the content standards are substantial and
    extensive changes are necessary to the content being tested on FCAT,
    there will be a need to establish a new vertical scale and revisit
    the use of this scale in reporting student learning gains in the
    accountability system. The earliest these changes could occur would
    be in 2010-11.

6.  Tracking Student Progress

**[Evidence for Core Principle 6 Provided on Florida's
CD:]{.underline}**

-   6.2.2.1: FETPIP 2005 Annual Outcomes Report

"The accountability model and related State data system must track
student progress." (Secretary Spellings' letter, 11/21/05)

**Introductory note:** NCLB established the goal of having all students
reach "proficiency" in reading/language arts and mathematics by 2013-14.
To reach this goal, it is necessary to monitor students' progress as
they move from grade level to grade level. Status models take a snapshot
of a school's or subgroup's level of achievement to see if the school or
subgroup has met the established proficiency target. Implicit in any
system of growth measurement is the necessity of being able to track
individual students over time. This section facilitates Peer Reviewers'
efforts to review a State proposal with regard to the State's data
system and the proposed methods for tracking student progress.

1.  []{#__RefHeading___Toc127781933 .anchor}Has the State designed and
    implemented a technically and educationally sound system for
    accurately matching student data from one year to the next?

    1.  []{#__RefHeading___Toc127781934 .anchor}Does the State utilize a
        student identification number system or does it use an
        alternative method for matching student assessment information
        across two or more years? If a numeric system is not used, what
        is the process for matching students?

Florida has designed and implemented a technically and educationally
sound system for accurately matching student data from one year to the
next. For many years, Florida has had a student identification system
that assigns a unique number to each student upon initial enrollment.
Because the number follows the student throughout his/her academic
career, an opportunity is available to analyze achievement data in terms
of community demographic variables, school characteristics, staff
characteristics, and the enacted curriculum. Florida uses a student
identification number that can track student test results over the
student's educational career in Florida public schools as part of our
K-20 Educational Data Warehouse. This unique identification number is
assigned by the state and retains information about the district
identification number a student uses. Districts report to the state
student information using the identification number assigned by the
district, and the state matches that identification number to the one in
the data warehouse to match data for use and storing.

2.  []{#__RefHeading___Toc127781935 .anchor}Is the system proposed by
    the State capable of keeping track of students as they move between
    schools or school districts over time? What evidence will the State
    provide to ensure that match rates are sufficiently high and also
    not significantly different by subgroup?

Florida's system is able to track students as they move through the
state from school to school and district to district. Florida has been
tracking student information for years and has developed a data
warehouse to help with the process. Because of the statewide matching
capability, there is virtually no difference between the subgroup match
rates. Florida currently has a 99 percent match rate for students to
data. In addition to matching students, the department sends unmatched
data to districts and schools for review/correction in order to maintain
Florida's high match rates. Florida is in the process of working with
school districts and schools to improve this match rate using a secure
website to transfer student data and information to match more student
records with prior year assessment. This process gives school and
district personnel the opportunity to ensure accuracy and integrity of
their data as well as provide additional information about the student
that leads to an increase in the match rate.

The match rates for reading and mathematics are both at 99 percent. The
match rates for both reading and math vary by only one half of one
percent from the subgroup with the highest match rate to the subgroup
with the lowest match rate, with all of the match rates rounding to 99
percent as the nearest whole number for both reading and mathematics.
Overall the match rate is 99 percent, for white students the match rate
is 99 percent, for black students the match rate is 99 percent, for
Hispanic students the match rate is 99 percent, for Asian students the
match rate is 99 percent, and for Native American students the match
rate is 99 percent.

3.  []{#__RefHeading___Toc127781936 .anchor}What quality assurance
    procedures are used to maintain accuracy of the student matching
    system?

There are several quality assurance procedures used to maintain the
accuracy of the student matching system. Scores are matched to students
using the fields of school number, district number, and student
identification number in the Evaluation and Reporting Office using SAS
software and replicated by the Education Data Warehouse (EDW) at the
Florida Department of Education. Records that do not match using the
described method are then matched using a different six dimensional
matrix of matching criteria established by the EDW. Only records with a
high level of match confidence (matching on a combination of at least
three factors) are considered matched records. Once the department has
matched all possible student records, the department sends all the
records, matched and unmatched, to the districts and schools for
verification of matched records and to update information for unmatched
records to create more matches based on data available to the school and
district administrators. If a student does not have matching data, the
district and school assist the department in locating the data. The
districts and schools also review the student data to ensure the student
match process appropriately matched the correct data. Receiving this
additional information allows the department to update their records in
the EDW and create more valid record matches. Requiring the schools and
districts to review verify and update the student records being used for
AYP gives the department a very high level of confidence that matches
are accurate and comprehensive.

4.  []{#__RefHeading___Toc127781937 .anchor}What studies have been
    conducted to demonstrate the percentage of students who can be
    "matched" between two academic years? Three years or more years?

For the 2005-06 AYP calculations, a very small percent of students in
grades 4-10 do not have prior year data. Of the grade 4-10 students that
have been in Florida for two years, over 97 percent have at least two
years of data. Florida continues to work with the local schools and
districts to improve the percent of student with matching prior year
data. Florida's website for making updates to prior year student data to
allow for additional matches. Please see chart below for the current
racial and economic breakout.

  -------------------- ------------------------- -------------------------
  Prior Year Data      Reading - Percent of      Math - Percent of grade
                       grade 4-10 students' with 4-10 students' with at
                       at least 2 years of data  least 2 years of data

  Total                97                        97

  White                98                        98

  Black                96                        96

  Hispanic             97                        97

  Asian                98                        98

  American Indian      98                        98

  Free/Reduced Lunch   97                        98

  Not Free/Reduced     98                        97
  Lunch                                          
  -------------------- ------------------------- -------------------------

5.  []{#__RefHeading___Toc127781938 .anchor}Does the State student data
    system include information indicating demographic characteristics
    (e.g., ethnic/race category), disability status, and socio-economic
    status (e.g., participation in free/reduced price lunch)?

Florida's data warehouse includes information for each student
indicating demographic characteristics, ethnic or race category,
disability status, and socio-economic status (participation in
free/reduced price lunch).

6.  []{#__RefHeading___Toc127781939 .anchor}How does the proposed State
    growth accountability model adjust for student data that are missing
    because of the inability to match a student across time or because a
    student moves out of a school, district, or the State before
    completing the testing sequence?

> The growth model does not adjust for missing student data because of
> the potential error it introduces to the calculations. Because Florida
> is able to match approximately 99 percent of the current year student
> data and has a 97 percent match rate to prior year data, imputing
> values for missing data is not necessary. If there is missing data, it
> will remain missing data since it accounts for so few records.
> Students who change schools or districts can easily be located by the
> state or by asking the districts to help locate the data by providing
> additional information about the student from the prior year. Students
> who do not have two years of data will not be included in the growth
> component, but they will be included in AYP in the status and safe
> harbor calculations.

In many cases, schools and districts are able to assist Florida's
Education Data Warehouse in resolving missing student data using data
analysis procedures at the local level.

2.  []{#__RefHeading___Toc127781940 .anchor}Does the State data
    infrastructure have the capacity to implement the proposed growth
    model?

    1.  []{#__RefHeading___Toc127781941 .anchor}What is the State's
        capability with regard to a data warehouse system for entering,
        storing, retrieving, and analyzing the large number of records
        that will be accumulated over time?

The data infrastructure in Florida has the capacity to implement the
proposed growth model. Florida's K-20 Education Data Warehouse has
immense capabilities for entering, storing, retrieving, and analyzing
large number of records that have been accumulated over time in Florida.
The warehouse boasts over a 99 percent matching rate with stringent
matching criteria. Florida's K-20 Education Data Warehouse has had this
matching capability and experience for several years. Tracking student
growth and data for the purposes of accountability is something the
state of Florida has been doing for five years. Florida's model does not
take into account, or adjust, for decreasing student match rates over
three or more years because Florida only needs two years of data, the
current and prior years, to determine a student's growth trajectory.
Florida has been using the matching process including the schools and
districts for the last three years so the data collected during those
times is accurate and matched at a very high level. While we have
updated prior year data records for students over the past three years,
Florida is still in the process of developing a system to allow for
verification and updates of a student's entire assessment record history
at one time rather than on a year by year basis.

2.  []{#__RefHeading___Toc127781942 .anchor}What experience does the
    State have in analyzing longitudinal data on student performance?

Florida has extensive experience analyzing longitudinal data on student
performance. For several years Florida has been analyzing longitudinal
student data to make policy decisions and for purposes of accountability
**(see evidence 6.2.2.1)**.

3.  []{#__RefHeading___Toc127781943 .anchor}How does the proposed growth
    model take into account or otherwise adjust for decreasing student
    match rates over three or more years? How will this affect the
    school accountability criteria?

The match rate for students will only continue to improve with time. The
students will be included in the growth component for their current year
school only. Based on the current three-year trajectory, we will
determine if each student is going to reach proficiency within three
years. If so, they are included positively in the growth calculation, if
not, they are included negatively in the growth calculation.

7.  Part**i**cipation Rates and Additional Academic Indicator

The accountability model must include student participation rates in the
State\'s assessment system and student achievement on an additional
academic indicator. (Secretary Spellings' letter, 11/21/05)

**Introductory Note:** In determining AYP, a State must include, in
addition to academic achievement, (1) participation rates on the State's
assessment, and (2) "at least one other academic indicator, as
determined by the State for all public elementary school students" and
graduation rate for public high schools, and may include other academic
indicators such as "decreases in grade-to-grade retention rates." For
purposes of developing a growth model, these requirements must be
addressed in a State's proposal.

1.  []{#__RefHeading___Toc127781944 .anchor}Has the State designed and
    implemented a Statewide accountability system that incorporates the
    rate of participation as one of the criteria?

    1.  []{#__RefHeading___Toc127781945 .anchor}How do the participation
        rates enter into and affect the growth model proposed by the
        State?

The participation rate will be used in the AYP calculation with a growth
model the same way it is currently used. Schools and districts that did
not meet AYP using the status model are eligible to meet AYP using the
safe harbor model only if the school and all the subgroups have tested
at least 95% of the students in reading and mathematics. The same 95%
tested requirement for the school and subgroups used to determine
eligibility for safe harbor must be met for a school or district to be
eligible to use the growth model to meet AYP.

2.  []{#__RefHeading___Toc127781946 .anchor}Does the calculation of a
    State's participation rate change as a result of the implementation
    of a growth model?

Florida will not change the participation rate calculation for AYP; it
will remain the same when the growth component is included.

2.  []{#__RefHeading___Toc127781947 .anchor}Does the proposed State
    growth accountability model incorporate the additional academic
    indicator?

    1.  []{#__RefHeading___Toc127781948 .anchor}What are the "additional
        academic indicators" used by the State in its accountability
        model? What are the specific data elements that will be used and
        for which grade levels will they apply?

The additional academic indicators used in Florida's AYP calculation are
writing for all schools and graduation rate for high school.

Writing is administered in grades 4, 8, and 10, and applies to the
school AYP calculation. Total writing must be met to utilize safe harbor
and the growth model. Writing proficiency is calculated at the school
and district level for the primary AYP calculation. Writing proficiency
is also calculated for each of the eight subgroups, but the data
currently is used for safe harbor provisions and will be used the same
way for the growth component. For purposes of AYP, students scoring
level 3 and above on the FCAT Writing or an appropriate alternative
assessment are considered to have met state standards. In addition, only
students enrolled in the same school for a full academic year (same
district for the district calculation) are included in proficiency
calculations. The percent of students meeting state standards in writing
is determined by dividing the total number of students meeting state
standards by the total number of students assessed.

The graduation rate used for AYP is calculated using the federal
definition of a regular diploma and does not include some of the diploma
types we offer in Florida, such as a Special Diploma for students with
disabilities. Because the AYP calculation is performed prior to the end
of summer school, graduation rates used for AYP are based on the prior
two years. The graduation rate and change in the graduation from prior
year to current year is calculated at the school and district level for
the primary AYP calculation. The change in graduation rate is also
calculated for each of the eight subgroups and the data is used for safe
harbor provisions and will also be used as a provision for the growth
model component.

2.  []{#__RefHeading___Toc127781949 .anchor}How are the data from the
    additional academic indicators incorporated into accountability
    determinations under the proposed growth model?

The model does not change the way Florida utilizes the other academic
indicator(s). Florida will use the same rules for eligibility for safe
harbor as well as the growth component. For the school to be eligible to
utilize the growth component, the school must have at least 95% tested
in each subgroup, meet the writing criterion and graduation criterion
for the whole school, as well as the subgroup using the growth
calculation.

**Appendix A -- Calculation of Growth Model Trajectory Benchmarks**

Table 1. Grades and Tests Used for Trajectory Growth and the Percent of
Closing Needed Per Year

  ------------ --------------- --------------- ------------ ---------------
  Grade Of     Test Used As    Test Used As    Years In     Percent Of
  First        The Basis For   Target For      Trajectory   Difference
  Enrollment   Trajectory      Proficiency                  Closed Per Year

  3            3               6               3            33%

  4            3               7               3            33%

  5            4               8               3            33%

  6            5               9               3            33%

  7            6               10              3            33%

  8            7               10              3            33%

  9            8               10              3            33%

  10           9               10              2            50%
  ------------ --------------- --------------- ------------ ---------------

The trajectory benchmarks are built individually for students and
separately for reading or mathematics. Therefore, a student will have a
trajectory based on their baseline mathematics score and the proficiency
cut score for mathematics which is separate from reading.

The following table displays the performance expected of students to be
counted as on trajectory for inclusion in the proposed method of
comparing school performance to AMO targets.

Table 2. The Amount of Improvement in Terms of Decrease in the Distance
Between Baseline Performance and Proficiency Benchmark in the Target
Grade

  --------------------- -------------------------------------------------
  Year In State-Tested  Decrease From Baseline Assessment In Performance
  Grade                 Discrepancy

  1                     33% of original gap

  2                     66% of original gap

  3                     Student must be proficient
  --------------------- -------------------------------------------------

If the total and all subgroups have met the 95% participation target in
reading and mathematics, and the total and subgroup have met the other
academic indicator (writing and graduation), and the proficiency target
has not been met, the process is as follows:

1.  1\) Identify if the student has been in membership the full academic
    year and is tested.

    2\) Identify the number of years the student has been in the state,
    using the historic files from the state's accountability system.

    3\) If the student has been in the state public schools, locate the
    correct baseline score (using the table above).

    4\) Based on the student's baseline score and proficiency in the
    target year, calculate the difference.

    5\) Compare the decrease in the difference will be compared against
    Table 2 (above) based on the number of years the student has been in
    the state.

    6\) Determine if the student's performance on the current assessment
    is equal to or better than the minimum from the previous step, the
    student will be included in the percent "on track to be proficient"
    growth calculation to compare against the state's AMO's.

An example follows for a non proficient student:

This example is for a student who enters third grade and remains in
Florida for the next three academic years. The student does not need to
remain in Florida for three years to be included in the growth
calculation; this is just to give an example. The student scores below
proficient in the current school year in reading. This child's known
test scores are listed below.

  -------------------------------------- -------- -------- -------- --------
  Grade                                  3        4        5        6

  Student's Actual Reading Developmental 1001     1325     1450     1635
  Score                                                             

  Required DSS Score for Proficiency     1198     1456     1510     1622

  Cut score needed to be "on track to be NA       33% of   66% of   100% of
  proficient"                                     621      621      621

  Is student "on track to be proficient" No       Yes      Yes      Yes
  -------------------------------------- -------- -------- -------- --------

The student's first full year in the state is third grade, the student
will need to be on trajectory to be proficient by the end of the sixth
grade, demonstrating proficient on the sixth grade FCAT for reading. The
developmental score for sixth grade reading is 1622.

The third grade DSS score will be used as the baseline. The difference
between the baseline and proficient on the sixth grade test is 621 DSS
points (take 1622 and minus 1001). For the current year (fourth grade,
the second year in the state), the student must perform well enough on
the test to meet the trajectory benchmark, a student must, close the gap
by 33.3 percent of the difference between the score for proficiency and
his baseline (grade 3 FCAT) DSS score (divide 621 by 3 = 207).

The student would need to score at least 1208 in grade 4 to be
considered to be on track to be proficient (take 1001 plus 207). The
student's actual DSS score is 1325 which means the child met the
standard to be deemed on trajectory for the current year and thus will
be included in the growth model percentage for comparison to the AMO for
the school as a whole and any subgroups the student may be a part of.

An example follows for a student that is currently proficient:

A student enters Florida in the third grade and remains in Florida for
the next three academic years. The student scores proficient or above in
the current school year in reading. This student's known test scores are
listed below.

  ------------------------------------- -------- -------- -------- --------
  Grade                                 3        4        5        6

  Student's Actual Reading              1205     1475     1480     1675
  Developmental Score                                              

  DSS Score for Proficiency             1198     1456     1510     1622

  Cut score needed to be "on track to   NA       33% of   66% of   100% of
  be proficient"                                 417      417      417

  Is student "on track to be            Yes      Yes      No       Yes
  proficient"                                                      
  ------------------------------------- -------- -------- -------- --------

The student's first full year in the state is third grade, the student
will need to be on trajectory to be proficient by the end of the sixth
grade and thus on the sixth grade FCAT for reading. The developmental
score for sixth grade reading equivalent to proficient is 1622.

The third grade DSS score will be used as the baseline. The difference
between the baseline and proficient on the sixth grade test is 417 DSS
points (take 1622 and minus 1205). For the current year (fourth grade,
the second year in the state), the student must perform well enough on
the test to meet the trajectory benchmark, a student must, close the gap
by 33.3 percent of the difference between the score for proficiency and
his baseline (grade 3 FCAT) DSS score (divide 417 by 3 = 139).

The student would need to score at least 1344 in grade 4 to be
considered to be on track to be proficient (take 1205 plus 139). The
student's actual DSS score is 1475 which means the student met the
standard to be deemed on trajectory for the current year and thus will
be included in the percent of students on trajectory or proficient for
comparison to the AMO for the school as a whole and any subgroups the
child may be a part of.

**Appendix B - Example of how AYP will be calculated for a school**

**Compute Adequate Yearly Progress**

Based on the federal No Child Left Behind Act, schools must meet 39
criteria for adequate yearly progress to have been made at that school.
Districts must meet the same criteria as schools, except that school
grades are not taken into consideration. If any one of the 39 criteria
is not met, the school has not made adequate yearly progress under the
federal accountability plan. Below are the 39 cells that are evaluated
to determine AYP.

  ----------------------------- ----------- ---------- ----------- ------------
  **AYP STATUS**                **YES**                            

                                                                   

  **Writing Criteria Met**      YES                                

  **Graduation Criteria Met**   YES                                

  **School Grade Not D or F**   YES                                

                                                                   

                                **Reading   **Math 95% **Reading   **Math
                                95%         Tested**   Criteria    Criteria
                                Tested**               Met**       Met**

  **Total**                     YES         YES        YES         YES

  **White**                     YES         YES        YES         YES

  **Black**                     YES         YES        YES         YES

  **Hispanic**                  YES         YES        YES         YES

  **Asian**                     YES         YES        YES         YES

  **American Indian**           YES         YES        YES         YES

  **Economically                YES         YES        YES         YES
  Disadvantaged**                                                  

  **Limited English             YES         YES        YES         YES
  Proficient**                                                     

  **Students with               YES         YES        YES         YES
  Disabilities**                                                   
  ----------------------------- ----------- ---------- ----------- ------------

**1. Participation:** **Did the school in total and each subgroup test
at least 95% of students?**

If the current year participation rate or the average participation rate
for the subgroup being evaluated is 95% or more, then the participation
criterion has been met.

**2. Writing Criteria:** **Did the school demonstrate a 1% improvement
in the percentage of students proficient in writing?** If the increase
in writing proficiency is at least 1% or if the school has a writing
proficiency rate of 90% or better, then the writing criterion has been
met.

**3. Graduation Rate: Did the school demonstrate a 1% improvement in
graduation rate?** If the increase in graduation rate is at least 1% or
if the school has a graduation rate of 85% or better, then the
graduation rate criterion has been met.

**4. School Grade: Is the school grade a D or F?** If a school is a D or
F in 2004-05, then the school grading criterion has not been met.

**5. Reading Criteria: Did the school in total and each subgroup meet
the reading proficiency target or Safe Harbor provisions or the Growth
Model provisions?** If the school and all subgroups have at least 44% of
students scoring at the proficient level in reading, then the school has
met the reading criterion. Those subgroups not meeting the reading
proficiency target may still demonstrate adequate yearly progress if
Safe Harbor provisions are met or the Growth Model provisions are met.

Safe Harbor: The school must meet the participation criterion (#1
above), the writing criterion (#2 above), the graduation rate criterion
(#3 above), and the school grade criterion (#4 above) in order for any
subgroup to be eligible for Safe Harbor provisions. If any of the first
4 criteria above are not met, then Safe Harbor may not be applied to any
group not meeting proficiency targets. If all of the first 4 criteria
are met, then the group or subgroup evaluated must demonstrate the
following:

a.  the percent of non-proficient students have decreased by at least
    10% from the preceding year [and]{.underline}

b.  the group has met the writing criteria (the increase in writing
    proficiency is at least 1%, or the school has a writing proficiency
    rate of 90% or better) [and]{.underline}

c.  the group has met the graduation rate criterion, (the increase in
    graduation rate is at least 1%, or the school has a graduation rate
    of 85% or better).

> Growth Model: The school must meet the participation criterion (#1
> above), the writing criterion (#2 above), the graduation rate
> criterion (#3 above), and the school grade criterion (#4 above) in
> order for any subgroup to be eligible for Growth Model provisions. If
> any of the first 4 criteria above are not met, then the Growth Model
> may not be applied to any group not meeting proficiency targets. If
> all of the first 4 criteria are met, then the group or subgroup
> evaluated must demonstrate the following:

a.  the percent of students "on track to be proficient" in three years
    or less in reading is at least 44% [and]{.underline}

b.  the group has met the writing criterion (the increase in writing
    proficiency is at least 1% or the school has a writing proficiency
    rate of 90% or better) [and]{.underline}

c.  the group has met the graduation rate criterion (the increase in
    graduation rate is at least 1% or the school has a graduation rate
    of 85% or better).

> If the school and all subgroups either meet the reading proficiency or
> meet Safe Harbor provisions or the Growth Model provisions, then the
> reading criterion has been met.

**6. Math Criteria: Did the school in total and each subgroup meet the
math proficiency target or Safe Harbor provisions or the Growth Model
provisions?** If the school and all subgroups have at least 50% of
students scoring at the proficient level in math, then the school has
met the math criterion. Those subgroups not meeting the math proficiency
target may still demonstrate adequate yearly progress if Safe Harbor
provisions are met or the Growth Model provisions are met.

Safe Harbor: The school must meet the participation criterion (#1
above), the writing criterion (#2 above), the graduation rate criterion
(#3 above), and the school grade criterion (#4 above) in order for any
subgroup to be eligible for Safe Harbor provisions. If any of the first
4 criteria above are not met, then Safe Harbor may not be applied to any
group not meeting proficiency targets. If all of the first 4 criteria
are met, then the group or subgroup evaluated must demonstrate the
following:

a.  the percent of non-proficient students has decreased by at least 10%
    from the preceding year [and]{.underline}

b.  the group has met the writing criterion (the increase in writing
    proficiency is at least 1% or the school has a writing proficiency
    rate of 90% or better) [and]{.underline}

c.  the group has met the graduation rate criterion (the increase in
    graduation rate is at least 1% or the school has a graduation rate
    of 85% or better).

> Growth Model: The school must meet the participation criterion (#1
> above), the writing criterion (#2 above), the graduation rate
> criterion (#3 above), and the school grade criterion (#4 above) in
> order for any subgroup to be eligible for Growth Model provisions. If
> any of the first 4 criteria above are not met, then the Growth Model
> may not be applied to any group not meeting proficiency targets. If
> all of the first 4 criteria are met, then the group or subgroup
> evaluated must demonstrate the following:

a.  the percent of students "on track to be proficient" in three years
    or less in math is at least 50% [and]{.underline}

b.  the group has met the writing criterion (the increase in writing
    proficiency is at least 1% or the school has a writing proficiency
    rate of 90% or better) [and]{.underline}

c.  the group has met the graduation rate criterion (the increase in
    graduation rate is at least 1% or the school has a graduation rate
    of 85% or better).

> If the school and all subgroups either meet the math proficiency or
> meet Safe Harbor provisions or the Growth Model provisions, then the
> math criterion has been met.

**7. Adjustment: Did the school not make AYP solely because the SWD
subgroup did not make the reading or mathematics criterion?** If the
school did not make AYP solely because the SWD subgroup missed its
proficiency target (in reading, math, or both), a mathematical
adjustment is applied to the percent proficient. If applying the
mathematical adjustment increases the SWD percent proficient to meet or
exceed the state proficiency target, the SWD subgroup will be considered
to make AYP. The same mathematical adjustment is applied to the reading
and mathematics criteria. The mathematical adjustment does not apply to
participation, writing, or graduation.

**Appendix C -- Florida Comprehensive Assessment Test (FCAT)
Developmental Scale Score**

The FCAT vertical developmental scale score does account for an
increased score for the "same" performance level cut point at every
higher grade. Please refer to charts below:

Reading developmental scale scores (86 to 3008) for each achievement
level on the Florida Comprehensive Assessment Test

  ------- ------------ ------------ ------------ ------------ ------------
  Grade   Level 1      Level 2      Level 3      Level 4      Level 5

  3       86-1045      1046-1197    1198-1488    1489-1865    1866-2514

  4       295-1314     1315-1455    1456-1689    1690-1964    1965-2638

  5       474-1341     1342-1509    1510-1761    1762-2058    2059-2713

  6       539-1449     1450-1621    1622-1859    1860-2125    2126-2758

  7       671-1541     1542-1714    1715-1944    1945-2180    2181-2767

  8       886-1695     1696-1881    1882-2072    2073-2281    2282-2790

  9       772-1771     1772-1971    1972-2145    2146-2297    2298-2943

  10      844-1851     1852-2067    2068-2218    2219-2310    2311-3008
  ------- ------------ ------------ ------------ ------------ ------------

Mathematics developmental scale scores (375 to 2709) for each
achievement level on the Florida Comprehensive Assessment Test

  ------- ------------ ------------ ------------ ------------ ------------
  Grade   Level 1      Level 2      Level 3      Level 4      Level 5

  3       375-1078     1079-1268    1269-1508    1509-1749    1750-2225

  4       581-1276     1277-1443    1444-1657    1658-1862    1863-2330

  5       569-1451     1452-1631    1632-1768    1769-1956    1957-2456

  6       770-1553     1554-1691    1692-1859    1860-2018    2019-2492

  7       958-1660     1661-1785    1786-1938    1939-2079    2080-2572

  8       1025-1732    1733-1850    1851-1997    1998-2091    2092-2605

  9       1238-1781    1782-1900    1901-2022    2023-2141    2142-2596

  10      1068-1831    1832-1946    1947-2049    2050-2192    2193-2709
  ------- ------------ ------------ ------------ ------------ ------------

![](media/image2.png){width="1.1701388888888888in"
height="1.1701388888888888in"}

[^1]:  "Growth target" denotes the level of performance required in
    order to meet AYP. The State may propose different "growth targets"
    for reading/language arts and mathematics, different grade spans,
    etc. This document uses the term "growth target" to try to minimize
    confusion with "expected growth," "projected growth," "growth
    expectations," and other terms used in value-added and other student
    longitudinal growth approaches that denote an empirically derived
    student performance score not necessarily related to the NCLB policy
    goals of proficiency.

[^2]: The first year of Florida's contiguous grade level assessment
    provided annual learning gains for a few grades, but not for all
    grades, 3-10. Therefore, five years of growth data are available for
    all students and six years of growth data are available for some
    cohorts (those in 4^th^, 5^th^, or 9^th^ grades in 2000-01).