First, national normative data –representative of all groups and regions– are required before a CBM can achieve status as a universally accepted and implemented accountability tool, because as such it will be used to formulate comparisons between states, districts, schools, and teachers about effectiveness of education programs. The authors suggest that normative data should: (a) provide information about typical performance level at each trimester of the school year for grades 1-6; (b) provide information about slopes at each grade for typically developing children as well as those with high-incidence disabilities; (c) systematically sample widely used reading programs; and (d) address reading and other basic skills where well developed CBM procedures are specified (Fuchs & Fuchs, 2002).

Second, Fuchs and Fuchs (2002) argue for the need to prevent unintended consequences. They recommend conducting studies that examine the effects of an outcomes-based accountability framework on the ambitiousness of learning goals, the quality of teachers’ instructional plans, and the extent of student learning. Such studies should also identify how aggregating data by teachers, service delivery arrangements, instructional methods, curriculum packages, and types of disabilities affects decision making at the school, district, state, and national levels.

Third, it is necessary to expand the focus not only to the acquisition of basic skills in reading, mathematics, spelling, and written expression at the elementary grades, but also to more complex skills and knowledge application in later grades (Fuchs & Fuchs, 2002). As Crouch (2005) indicates, the objectives of quality secondary education could be reflected in a national graduation certification exam. Again, norms and graduation criteria should be set in a way that they do not discriminate against already vulnerable groups.

Fourth, Fuchs and Fuchs (2002) suggest that is necessary to study the methods for aggregations of data at the classroom (teacher), school, district, and regional levels, so that important information is not lost in the process: information on the effectiveness of different classrooms or schools, of contrasting service delivery arrangements, of various instructional methods or curriculum packages, and for different types of educational needs. This information is helpful to administrators and policymakers in specifying and improving education practice, but when merged into, for example, district averages, it gets lost. Related to this point, Crouch (2005) recommends to establish standards for process, such as effective instructional time per year or teacher recruitment standards, as well as for user information, with a top-down accountability process through which local education management offices (UGELs) are accountable to the schools they serve, and schools are accountable to the communities they serve.

As pointed before, standards must be specific both to grade-level and curricular objectives. Regarding early reading skills, benchmarks must approximate for the cognitive development of children. A World Bank study in Peru (Crouch, Abadzi, Echegaray, Pasco, & Sampe, 2005) determined that a child should be able to read correctly, out loud, an average of 30 words per minute by the end of the first grade, 60 words per minute by the end of second grade, 90 by the end of third grade and 110 by the end of fourth grade, and continue to progress in the following grades.

These standards are below the benchmarks used in other countries. For instance, standards for fluency in connected text in the United States range from 40 to 60 words per minute by the end of first grade, 82 to 94 by the end of second grade, 100 to 114 by the end of third grade, 105 to 118 in fourth grade, and 118 to 128 in fifth grade (Hudson, Lane, & Pullen, 2005). Oral Reading Fluency norms fall within these parameters (Hasbrouck & Tindal, 2006). Suggested standards in Spanish-speaking countries are also higher than those recommended for second graders in Peru, 24