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# **UNITED STATES DEPARTMENT OF EDUCATION**

## THE UNDER SECRETARY

> July 1, 2003

The Honorable Paul Vance

District of Columbia Public Schools

825 North Capitol Street NE

Suite 900

Washington, DC 20002

Dear Superintendent Vance:

I am writing to follow up on Secretary Paige's letter of June 9, 2003,
in which he approved the basic elements of the District of Columbia's
(DCPS) State accountability plan under Title I of the Elementary and
Secondary Education Act (ESEA), as amended by the No Child Left Behind
Act of 2001 (NCLB). I join Secretary Paige in congratulating you on
DCPS' commitment to holding all schools accountable for the achievement
of *all* students.

I appreciate DCPS' efforts to meet the Title I requirements and your
responsiveness to making changes as a result of the external peer review
of DCPS' accountability plan. The purpose of this letter is to document
those aspects of DCPS' plan for which final action is still needed.

-   DCPS must finalize its regulatory policies, as outlined in the
    enclosure to this letter, to reflect how adequate yearly progress
    (AYP) will be implemented. DCPS has indicated it will make these
    changes in the summer of 2003. Please let the Department know as
    soon as those regulations are final.

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-   DCPS must issue a report card that contains all the necessary
    information as specified in section 1111(h) of Title I. Please
    provide a prototype containing all the required data elements as
    soon as one is available this summer.

-   DCPS must determine the targets for schools and the LEA to make AYP
    for the additional academic indicator of the graduation rate at the
    high school level. Please submit this information to the Department
    as soon as DCPS makes a determination this summer.

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-   DCPS' accountability plan indicated that students who receive
    alternative diplomas are not counted as graduates. While students
    receiving alternative diplomas cannot be counted as graduates in the
    numerator of the graduation rate calculation, such students must be
    accounted for in the denominator. Please specify that students
    receiving alternative degrees that are not fully aligned with DCPS'
    academic standards, such as a certificate or GED, will be accounted
    for in the denominator of the graduation rate calculation.

Provided DCPS meets the conditions above, subject to the Department's
review and consideration, we will fully approve DCPS' accountability
plan. Please submit the information requested above to:

Ms. Darla Marburger

Deputy Assistant Secretary

Office of Elementary and Secondary Education

U.S. Department of Education

> 400 Maryland Avenue, S.W.
>
> Washington, D.C. 20202

With regard to one issue in DCPS' accountability plan, the Secretary has
exercised his authority to permit the orderly transition from
requirements under the Improving America's Schools Act (IASA) to NCLB.

-   DCPS plans, consistent with §200.19 of the Title I regulations, to
    use a definition of graduation rate that follows a cohort of
    students from entry in ninth grade through graduation in four years.
    To do so, however, DCPS must have four years of data, which it will
    not have until school year 2004-05. In the transition, DCPS may
    calculate graduation rate under its current system.

DCPS is operating under a compliance agreement to complete certain
assessment requirements under the IASA. This agreement affects DCPS'
accountability plan. Under the compliance agreement, DCPS will complete
development of new assessments to yield results in reading and
mathematics in school year 2004-05. Consistent with the terms of the
compliance agreement, DCPS may implement its accountability plan by
establishing starting points, intermediate goals, and annual measurable
objectives based on its current assessments and make annual school
accountability decisions based on that data until the new
standards-based assessments are implemented.

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As required by section 1111(b)(2) of Title I, DCPS must implement its
accountability plan to identify schools and school districts in need of
improvement and to implement section 1116 of Title I for the 2003-04
school year, including arranging for public school choice and
supplemental educational services. If, over time, DCPS makes changes to
the accountability plan that you have presented for approval, you must
submit information about those changes to the Department for approval,
as required by section 1111(f)(2) of Title I.

Approval of DCPS accountability plan is not also an approval of DCPS'
standards and assessment system. As DCPS completes the tasks in its
compliance agreement to meet IASA standards and assessments requirements
as well as to meet NCLB requirements, DCPS must submit information about
its final assessment system to the Department for peer review through
the standards and assessment process.

Please also be aware that approval of DCPS' accountability plan for
Title I does not indicate that the plan complies with Federal civil
rights requirements, including Title VI of the Civil Rights Act of 1964,
Title IX of the Education Amendments of 1972, Section 504 of the
Rehabilitation Act of 1973, Title II of the Americans with Disabilities
Act, and requirements under the Individuals with Disabilities Education
Act.

I am confident that DCPS will continue to advance its efforts to hold
schools and school districts accountable for the achievement of all
students. I wish you well in your efforts to leave no child behind.

Sincerely,

/s/

Eugene W. Hickok

Enclosure

cc: Mayor Anthony Williams

Enclosure: District of Columbia

In its final consolidated application workbook plan, DCPS indicated that
the following needed final regulatory policies. Final approval of DCPS'
accountability plan is contingent upon these policies being adopted as
described in the accountability plan.

-   Accountability system includes all schools and the district and
    holds all schools to the same criteria (Elements 1.1 and 1.2)

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-   Accountability system provides AYP determinations and decisions
    about school and district identification for improvement before the
    beginning of the next school year (Element 1.4)

-   Accountability system includes report cards (Element 1.5)

-   Accountability system includes a system of rewards and sanctions
    (Element 1.6)

-   Accountability system includes all students (Element 2.1)

-   Accountability system expects all student subgroups and public
    schools to reach proficiency by 2013-2014 and has a method of
    determining whether student subgroups and public schools make AYP
    (Elements 3.1-3.2)

-   Accountability system determines annually the progress of schools
    and the district (Element 4.1)

-   Accountability system includes all the required student subgroups
    and holds schools and the district accountable for the progress of
    student subgroups (Elements 5.1 and 5.2)

-   Accountability system includes graduation rate for high schools
    (Element 7.1)

-   Accountability system includes attendance rate as the additional
    academic indicator for elementary and middle schools (Element 7.2)