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UNITED STATES DEPARTMENT OF EDUCATION
THEUNDER SECRETARY
July 1, 2003The Honorable Theodore SergiCommissioner Connecticut State Department of Education165 Capital AvenueHartford, CT 06145Dear Commissioner Sergi:I am writing to follow up on Secretary Paige’s letter of June 10, 2003, in which heapproved the basic elements of Connecticut’s state accountability plan under Title I of theElementary and Secondary Education Act (ESEA), as amended by the No Child LeftBehind Act of 2001 (NCLB). I join Secretary Paige in congratulating you onConnecticut’s commitment to holding schools and districts accountable for theachievement of 
all 
students. I appreciate Connecticut’s efforts to meet the Title Irequirements and your responsiveness to making changes as a result of the external peer review of Connecticut’s accountability plan. In consideration of these changes,Connecticut’s plan is fully approved.With regard to some issues in Connecticut’s accountability plan, the Secretary hasexercised his authority to permit the orderly transition from requirements under theImproving America’s Schools Act (IASA) to NCLB.
Connecticut proposed to include students with the most significant cognitivedisabilities in its accountability system based on their performance on an alternateassessment that would hold those students to different achievement standards fromthose all other students are expected to meet. All students with disabilities must beincluded in a State’s accountability system. Moreover, §200.1 of the final Title Iregulations requires that all students be held to the same grade level achievementstandards. In addition, §200.6(a)(2)(ii) of those regulations states that “[a]lternateassessments must yield results for the grade in which the student is enrolled.”
We have issued new proposed regulations that would permit a State to use alternateachievement standards to measure the achievement of students with the most significantcognitive disabilities (refer to the Federal Register notice of March 20, 2003). For this
 
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transition year only, while these proposed regulations are being finalized, Connecticut mayuse alternate achievement standards for students with the most significant cognitivedisabilities who take an alternate assessment to calculate adequate yearly progress (AYP) for schools and districts. Those alternate achievement standards must be aligned withConnecticut’s academic content standards and reflect professional judgment of the highestlearning standards possible for those students. Moreover, the percentage of students held toalternate achievement standards at district and State levels may not exceed 1.0 percent of allstudents in the grades assessed.
We note that this transition policy is not intended to preempt the rulemaking processor the standards and assessment peer review process, and that the final regulationsmay reflect a different policy and/or different percentage.
Connecticut plans, consistent with §200.19 of the Title I regulations, to use adefinition of graduation rate that follows a cohort of students from entry in ninthgrade through graduation in four years. To do so, however, Connecticut must havefour years of data, which will not be available until the 2005-06 school year when itsnew public information system will become operational. In the transition, Connecticutmay calculate graduation rate under its current system.Without this information system, Connecticut cannot currently compute or report atthe State level graduation rate and attendance rate data for 
all 
the required subgroups(i.e., limited English proficient students and students eligible for free or reduced priced lunch) consistent with §200.19(d)(2) of the Title I regulations. Connecticutmust submit evidence of these data for all the required subgroups being incorporatedinto the State’s report card as soon as they are available following the 2005-06 schoolyear. Additionally, during the transition, Connecticut must report at the State levelgraduation rate and attendance rate data for all the subgroups for which it currentlyhas data.As required by section 1111(b)(2) of Title I, Connecticut must implement itsaccountability plan during this school year to identify schools and school districts in needof 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, Connecticut makes changes to the accountability plan that you have presentedfor 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 Connecticut’s accountability system is not also an approval of Connecticut’sstandards and assessment system. As Connecticut makes changes in its standards andassessments to meet NCLB requirements, Connecticut must submit information aboutthose changes to the Department for peer review through the standards and assessment process.Please also be aware that approval of Connecticut’s accountability plan for Title I doesnot indicate that the plan complies with Federal civil rights requirements, including TitleVI of the Civil Rights Act of 1964, Title IX of the Education Amendments of 1972,
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