October 11, 2006

Dear Chief State School Officer:

I am writing to remind you of the opportunity to participate in the Department's growth model pilot for the 2006-07 school year. As you know, last year I invited States to submit proposals for the pilot project for the 2005-06 school year. The purpose of this pilot is to determine whether measuring individual student growth over time would be another appropriate way to determine adequate yearly progress (AYP) under the Title I program.

Following a rigorous review process, which included a Department review to determine whether the proposals we received met the seven core principles at the heart of NCLB and a peer review by outside experts knowledgeable about measuring progress, the Department approved growth model proposals submitted by North Carolina and Tennessee. We look forward to working with each of these States to analyze how the growth model affected the State's accountability determinations; the Office of Planning, Evaluation and Policy Development will initiate an evaluation in the near future.

The States whose proposals were reviewed by the peers but were not recommended for approval by the Department, Alaska, Arkansas, Delaware, Florida, and Oregon, have been invited to submit revised proposals that will be peer reviewed in mid-October. In addition, we are opening up the process to all States for the 2006-07 school year and are asking that any interested State submit a proposal to the Department by November 1. The growth model pilot remains capped at 10 participants (including North Carolina and Tennessee); this will require placing a priority on innovation during our review of newly submitted proposals.

Please note that we will continue to insist that new proposals meet the seven core principles that I laid out last November. Namely, each growth model must:

- Ensure that all students are proficient by 2014 and set annual goals to ensure that the achievement gap is closing for all groups of students;
- Set expectations for annual achievement based upon meeting grade-level proficiency, not based on student background or school characteristics;
- Hold schools accountable for student achievement in reading/language arts and mathematics separately;
- Ensure that all students in tested grades are included in the assessment and accountability system, hold schools and districts accountable for the performance of each student subgroup, and include all schools and districts;
- Include assessments that produce comparable results from grade to grade and year to year in each of grades three through eight and high school in both reading/language arts and mathematics, that have been operational for more than one year, and that have an assessment system that receives *Full Approval* or *Full Approval with Recommendations* before the State determines AYP based on 2006-07 assessment results;
- Track student progress as part of the State data system; and
- Include student participation rates and student achievement on a separate academic indicator in the State accountability system.

In addition to these core principles, it is important that each State is making progress on raising overall achievement and closing the achievement gap; ensuring that information is accessible and timely and that parents have options; and improving teacher quality, including by providing parents and the public with accurate information on the quality of their local teaching force.

We learned a great deal in reviewing the first round of growth model proposals, and the Department will be taking into account feedback from the peers when reviewing new proposals. For instance, the peers felt that very wide confidence intervals were inappropriate in measuring individual student growth, concluding that confidence intervals should not exceed one standard deviation (68 percent) and that a strong rationale would be necessary for the use of any confidence interval. The peers were also concerned with proposals that reset targets each year and those that did not use all available years of data to create a growth trajectory. Other issues raised included how the growth of proficient students would be included in the growth model and the difficulties in accounting for growth as students move between schools. Finally, the peers raised concerns with models that aggregate growth to determine AYP, as opposed to those models that count individual students' growth to determine AYP. I recommend that all applicants review the peers' document, which can be found on the Department's Web site at: http://www.ed.gov/admins/lead/account/growthmodel/cc.doc.

While the peers' guidance will inform our decision-making process, we are interested in testing a broad array of models and, thus, are looking for innovation and experimentation. While I would not recommend ignoring the peers' guidance, a sound proposal that diverges from that advice may win approval if it provides sufficient justification for a different, innovative approach to creating an accurate, growth-based measure of accountability.

Our review process will be similar to the process used last year. As I noted above, all proposals will be due to the Department on November 1. We will conduct an initial review of each proposal to ensure that it meets the seven core principles and that the State is making progress in the areas laid out above (for further information go to the following page on the Department's Web site: http://www.ed.gov/admins/lead/account/growthmodel/index.html). If we have any questions regarding a State's proposal, we will contact the State and provide a written list of those questions by December 15, and we ask that each State respond to any Department questions by January 19. Those proposals that have met the requirements will be forwarded to a group of peer reviewers who will meet in late February. I anticipate that a final decision will be reached in early March. We will provide you with additional details in the coming weeks.

Growth models are another commonsense approach to implementing NCLB. My hope is that, by approving a variety of models in this pilot, we can determine the effect of growth models on ensuring that schools and districts are held accountable in a meaningful and reliable way for the achievement of their children. Thank you for all your efforts on behalf of our nation's children.

| | Sincerely,        
| | ------------------
| | /s/               
| | Margaret Spellings

cc: Governors

|Last Modified: 10/11/2006
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