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June 24, 2011

Dear Chief State School Officer:

Educators rely on accurate,  reliable, and timely information to improve instruction and help all students  to reach and maintain high levels of achievement.  Indeed, the availability of valid, reliable,  and timely data on student performance is essential for meaningful  accountability and implementation of effective education reforms.

For these reasons, I am writing  to urge you to do everything you can to ensure the integrity of the data used  to measure student achievement and ensure meaningful educational accountability  in your State.  As I’m sure you know,  even the hint of testing irregularities and misconduct in the test  administration process could call into question school reform efforts and undermine  the State accountability systems that you have painstakingly built over the  past decade.

In addition, the Elementary and  Secondary Education Act requires that States establish and maintain an  assessment system that is valid, reliable, and consistent with professional and  technical standards (Section 1111(b)(3)(C)(iii)).  The successful implementation of Title I and other  key programs administered by the U.S. Department of Education (Department) relies  heavily on using data that are valid, reliable, and consistent with  professional and technical standards.  Test  security and data quality are essential elements of an assessment system.  The Department and each State and locality have  a role to play in ensuring the integrity of the test data.

Under Title I, the Department is  required by law to review and approve each State’s assessment system, and  accordingly examines evidence compiled and submitted by each State regarding  its process for monitoring and improving the technical quality of its  system.  During the review of State  assessment systems, the Department specifically examines evidence of procedures  and policies for test security and data quality, including training and  monitoring of staff, to ensure the security of the assessments.  Ensuring effective implementation of security  and data-quality procedures also is an important part of our Title I monitoring  visits, as well as our monitoring of other Federal education programs in which  data play a significant role.

State and local officials share responsibility  for defending against security breaches and threats to data quality.  States have a long history in stewardship of  academic assessments, and most States have made great efforts to ensure that  their assessments and other data collection instruments are properly  administered and that data security requirements are clearly specified and  followed.  But with the nation’s interest  in improving education and our shared concern in protecting the integrity of  our profession, as well as our investments and the public trust, ensuring the  security of State assessment systems is a national interest as well.

Therefore, I urge you to make  assessment security a high priority by reviewing and, if necessary, strengthening  your efforts to protect assessment and accountability data, ensure the quality  of those data, and enforce test security.   Among the steps that you can take are:

- Conducting  a risk analysis of district- and school-level capacity to implement test  security and data-quality procedures.

- Ensuring  that assessment development contracts include support for activities related to  monitoring test security, including forensic analyses.

- Conducting  unannounced, on-site visits during test administration to review compliance  with professional standards on test security.

- Seeking  support to enact strict and meaningful sanctions against individuals who transgress  the law or compromise professional standards of conduct.

As you may know, a State may use  Section 6111 funds to ensure the continued validity and reliability of its  assessment system, and the Student Achievement and School Accountability (SASA)  staff at the Department is ready and willing to help you in such efforts.  Please do not hesitate to have your staff  contact Carlos Martinez of SASA at 202-260-0826 or carlos.martinez@ed.gov.

Additionally, if you find  irregularities or other problems with the integrity of data used for Federal  education programs, please contact Carlos Martinez.  In cases involving fraud, potential criminal behavior, or significant  irregularities, you should  report this to the Department’s Office of Inspector General (OIG) Hotline at oig.hotline@ed.gov or  1-800-MISUSED.  There are more details  about contacting the OIG Hotline at the following Web address:  http://www2.ed.gov/about/offices/list/oig/hotline.html.



| | Sincerely, 
| | -----------
| | /s/        
| | Arne Duncan