December 7, 2007

Dear Chief State School Officers:

I am writing to update you on the Department's growth model pilot.  For the past two years, I have invited States to submit proposals for the pilot.  To date, we have approved growth model proposals from nine States.  As we continue to work toward reauthorization of the Elementary and Secondary Education Act of 1965 (ESEA), as amended by the No Child Left Behind Act of 2001 (NCLB), I would like to offer States an opportunity to submit proposals that incorporate growth models into their current accountability system.  This advance work will help us coordinate with the reauthorization discussions and plan for the possibility of implementing growth models.  Consequently, I encourage any eligible State to submit an innovative model for our growth model pilot.

As I have consistently stated in our reauthorization discussions, I believe that growth models promote two important goals.  First, growth models allow States another effective way of measuring adequate yearly progress (AYP) by measuring individual student growth over time.  Second, these models continue to expand the flexibility available to States under NCLB.

Accordingly, we encourage States to submit a proposal that meets the following criteria, which are the same as those I laid out each of the last two years:

- A growth model proposal must meet the following seven core principles:
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 identified in the statute.
Set expectations for annual achievement based on meeting grade-level proficiency, not based on student background or 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 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 received *Full Approval* or *Full Approval with Recommendations* before the State determines AYP based on 2007–08 assessment results.
Track student progress as part of the State data system.
Include student participation rates and student achievement on a separate academic indicator in the State accountability system.
- 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 identified in the statute.
- Set expectations for annual achievement based on meeting grade-level proficiency, not based on student background or 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 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 received *Full Approval* or *Full Approval with Recommendations* before the State determines AYP based on 2007–08 assessment results.
- Track student progress as part of the State data system.
- Include student participation rates and student achievement on a separate academic indicator in the State accountability system.
- The State must be making progress in the following areas: 
Raising overall achievement and closing the achievement gap.
Ensuring that information is accessible and timely and that parents have options.
Improving teacher quality, including providing parents and the public with accurate information on the quality of the local teaching force.
- Raising overall achievement and closing the achievement gap.
- Ensuring that information is accessible and timely and that parents have options.
- Improving teacher quality, including providing parents and the public with accurate information on the quality of the local teaching force.

As in the past two years, I encourage interested States to review the Department's peer review guidance for the growth model pilot and previous State proposals, all of which can be found on our Web site at http://www.ed.gov/admins/lead/account/growthmodel/index.html.  We have learned a great deal from the prior rounds of growth model peer reviews, both from the peer reviewers' feedback and from States' experiences in the field.  We urge you to take these lessons into account in developing your proposals.  For example, based on the peers' comments and concerns, we have concluded that wide confidence intervals are inappropriate in measuring individual student growth.  To date, we have not approved the use of any confidence intervals in the growth model pilot.  We also believe that a State should incorporate all available years of existing data in creating its growth trajectory.  Additionally, we do not look favorably on models that reset targets each year, aggregate growth to determine AYP rather than relying on individual student growth, do not have growth trajectories for proficient students, and do not consider the impact of changes in school configurations on student growth trajectories.  For more detailed information on crosscutting issues identified by the peer reviewers, I recommend that you consult the peer reviewers' summary of their April 2006 review of growth model proposals, which is available at http://www.ed.gov/admins/lead/account/growthmodel/cc.doc.  In addition, please be aware that we will consider a State's growth model proposal in the context of the State's full accountability system.  In particular, we will seek to ensure that adding growth to a State's accountability system does not present too many ways to make AYP and thus dilute accountability.  For example, a State that already uses status, safe harbor, and a performance index in making AYP determinations may not add a growth model to its accountability system unless it can provide evidence that doing so does not weaken the State accountability system.

Our review process will be similar to the process that we have used for the past two years.  All proposals are due to the Department by February 1.  We will conduct an initial review of each proposal to ensure that the growth model meets the seven core principles, and that the State is making progress in the areas described above.  If we have any questions about a State's proposal, we will contact the State by February 15, and ask the State to respond to our questions by March 14.  Then, those proposals that we have determined meet the requirements set forth above will be forwarded to a group of peer reviewers who will meet during the week of April 14-18.  I anticipate reaching a final decision on the States selected to participate in the growth model pilot by the middle of May.

We view growth models as a key component of our commonsense approach to implementing NCLB.  Growth models give States greater flexibility in tracking individual students' progress, creating a more nuanced accountability system while still adhering to the goal of 100 percent proficiency by 2013-14.  My hope is that, by continuing to consider a variety of models, we can ensure that growth models contribute to State accountability systems in a meaningful and reliable way.

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

cc: Governors

|Last Modified: 12/07/2007
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