Montana South Central Administrators
October 31, 2003

Eugene W. Hickok, The Under Secretary
United States Department of Education
400 Maryland Ave., S.W.
Washington, D.C. 20202

Dear Mr. Eugene Hickok,

We are writing to you at this time to share issues that have arisen with the No Child Left Behind Criteria. The intent of the written legislation is commendable; however several concerns have emerged in the process of using the current measurement criteria for these expectations.

We are aware that you have accepted our Governor’s invitation to visit Montana in November to see for yourself some of the concerns facing our Montana schools with this process. Your commitment to hearing these realities first hand is very much appreciated by this administrative group. The South Central Group of Administrators includes approx. 36-38 administrators representing 32 districts and 3 three counties. The goal of our organization is to meet monthly to keep current on State and Federal legislation and to share best practice strategies for implementation. Our hope in sending this communication is for you to hear from our Administrative group directly about our district dilemmas and also to join the State efforts to prepare you for your visit. To succinctly summarize this information, we have listed briefly the following issues:

1. The small numbers in rural schools are statistically unreliable. Multiple or ongoing measures would be more realistic and statistically a more accurate picture of student progress.
2. Statistically can we group 4th, 8th, and 11th grade scores? Is this reliable and does the testing of these 3 grades determine the quality of education in the entire K-12 setting?
3. Statistically it takes more than significant improvement for low functioning students with achievement scores between the 5th percentile and the 45th percentile to impact gains for the school.
4. Students with low abilities (IQ’s) will have a difficult time moving out of the novice grouping. These students are found in Title I programs and Special Education.
5. The criteria are unrealistic for Special Education students whose disability impairs their learning and ability to take tests. The Special Education student already has set goals and plans. The criteria for NCLB undermine the IEP plan given these determinations that are outside the team decision. These expectations not only create a personal burden for the students but they demoralize the special education staff, making it even more difficult to keep these teachers in place.
6. One State test for the majority of students (glimpse in time) is not as accurate a measure as multiple measures such as curriculum probes.
7. The disaggregated category of 'free and reduced' isn’t helpful in planning interventions as there is no way to ethically isolate this group.
8. The school focus of NCLB doesn’t take into consideration the other variables in student’s lives that also influence their progress such as attendance, homework, patterns of learned attribution, personal self efficacy toward learning, ability, and parent refusal of Title I services.
9. The new licensure expectations for rural staff create a hardship for schools already facing difficulties in obtaining staff.
10. The attendance criteria for schools are great but the current law allows parents to excuse students for whatever.

Once again our issue is not with the written law. We are very committed to student learning. However, we are concerned about the new criteria that have limitations in measuring the true picture of student growth and welcome your reflections on this process as we all move forward to do what’s best for all students.

Sincerely,

The Montana South Central Administrators