May 17, 2006

The Honorable T. Kenneth James

Commissioner

Arkansas Department of Education

Four State Capitol Mall, Room 304 A

Little Rock, AR 72201-1071

Dear Commissioner James:

Thank you for submitting a proposal for the U.S. Department of
Education's (Department) growth-based accountability model pilot
project. I realize that our timelines were tight and sometimes
inconvenient; I appreciate the work you and your staff have done to
participate in this effort so far. The Department continues to believe
that this pilot project can help determine whether growth models will,
most importantly, provide a fair, reliable, and innovative mechanism for
holding schools accountable for ensuring that all students reach
grade-level standards in reading and mathematics by 2013--14.

In mid-March, the Department determined that Arkansas was meeting the
"bright line principles" of the law -- that is, ensuring all students
are learning, making the system accountable, providing information and
offering parents options, and improving teacher quality -- and that the
Arkansas growth model proposal seemed poised to meet the seven core
principles outlined by Secretary Spellings in her letter on November 21,
2005. As such, Arkansas' proposal was forwarded to a group of peer
reviewers who met on April 17--18, 2006. The range of changes and the
number of conditions that the peer reviewers indicated would be required
for Arkansas' model to be acceptable would be tantamount to writing a
new proposal. On that basis, the Department is not approving the
Arkansas proposal. However, with this letter I am inviting Arkansas to
consider the peer reviewers' feedback and submit a revised proposal by
September 15, 2006. Our intent is that the Department will again conduct
an initial review and advance acceptable proposals to a second peer
review to take place in mid-October that will be organized solely for
Arkansas and the five other States who have advanced to this point in
the process. If successful, Arkansas' growth model could be approved for
implementation for the 2006--07 school year. To help you with this
effort, in addition to the information in this letter, I am providing
two pieces of information: 1) the peer report for Arkansas; and 2) a
document produced by the peer review team that outlines several general
themes and cross-cutting concerns raised during the peer review,
although not necessarily specific to Arkansas' proposal. My staff and I
are willing to discuss this information with you to help refine
Arkansas' proposal.

The peers identified several strengths in the Arkansas proposal: the
growth model included result from students who were taking the alternate
assessment based on alternate achievement standards and the overall
proposal demonstrated a commitment to use accountability to improve
student achievement. However, the peers raised significant specific
concerns regarding the Arkansas proposal. (Please refer to the enclosed
peer report for details.) The peers were particularly concerned about
Arkansas' capacity, due to the implementation of a new tracking system,
to match students' records from one year to the next (a necessary step
in calculating growth), as there were inconsistencies in how the data
system was described and given the high percentage of unmatched
students. A related concern was with the State's untested plans to
impute missing data for students.

In addition, because the growth targets are reset annually, the peers
felt that some students would never be expected to reach proficiency. In
effect, some students would be counted as "proficient" (i.e., meeting
the growth target) every year but never actually achieve grade-level
standards. As a result, the growth model proposal did not support the
goal of ensuring all students reach grade-level standards in reading and
mathematics by 2013--14. 

The peers also expressed concern that the model that did not account for
both proficient and non-proficient students, possibly ignoring the
growth trajectories of proficient students. Empirical data from several
States suggest this is a problem because a substantial number of
students who are currently achieving on grade level do not seem poised
to continue achieving at such a level in future grades. The peers were
willing to entertain a model that calculated growth for all students
even if the trajectories were not used for all students in adequate
yearly progress (AYP) determinations; however, their other concerns with
Arkansas' proposal outweighed their interest in this approach. These and
additional concerns are presented in the peer report that is enclosed.

If Arkansas decides not to revise its current proposal based on this
feedback and submit revised proposal by September 15, please note that
the Department would welcome a new proposal from Arkansas along with
other States later this year; these proposals would be due to us by
November 1, 2006. The limit of approved plans through this pilot,
however, will remain at ten.

The Department will rigorously evaluate the approved proposals, review
information on how each pilot project is working, and share the results
with other States, policymakers, and the public. With the knowledge
gained from the approved growth models, the Department will be able to
make an informed decision on whether to expand the pilot project beyond
the 2006--07 school year.

Again, I appreciate your interest in the growth model pilot project and
your continued efforts to ensure quality education for all children.

Sincerely,

Henry L. Johnson

Enclosures

cc: Governor Mike Huckabee