UNITED STATES DEPARTMENT OF EDUCATION OFFICE OF ELEMENTARY AND SECONDARY EDUCATION FEB 1 1 201': The Honorable Christopher Cerf Commissioner of Education New Jersey Department of Education PO Box 500 Trenton, NJ 08625-0500 Dear Commissioner Cerf: Between July 23-25_, 2013, a team from the U. S. Department of Education's_ (ED) Office of Elementary and Secondary Education conducted Part monitoring of the New Jersey Department of Education's (NJ DOE) implementation of its approved ESEA flexibility request. Part monitoring aims to continue the collaborative relationship begun during the request approval process, provide ED with a deeper understanding of each State educational agency's (SEA) goals and approaches to implementing ESEA flexibility, and ensure that the SEA has the critical- elements of ESEA flexibility in place to continue implementation of its plan. The review focused on the following ESEA flexibility elements: I SEA Systems and Processes, including Monitoring, Technical Assistance, Data Collection and Use, and Family Community Engagement and Outreach Transitioning to and Implementing College-and Career-ready Standards Adopting English Language Proficiency Standards Developing and Administering High-Quality Assessments Developing and Administering Alternate Assessments Developing and Administering English Language Proficiency Assessments Armually Reporting College-going and College--credit Accumulation Rates Developing and Implementing a State-Based System of Differentiated Recognition, Accountability, and Support Reward, Priority, Focus, and Other Title I Schools State and Local Report Cards; and Teacher and Principal Evaluation and Support Systems. Enclosed is a report based upon this review. The report includes highlights of NJ DOE's implementation of ESEA flexibility and, for each indicator, a snapshot of NJDOE's progress in implementing ESEA flexibility. If appropriate, the report also includes "next steps" that were discussed with the SEA during an exit conference conducted on August 16, 2013 to ensure that NJ DOE implements flexibility consistent with its approved request and the timelines and principles of ESEA flexibility. NJDOE should respond to the "next steps" within 30 or 60 business days, as indicated, after receipt of this report. This report will be posted on the ESEA flexibility website. gov 400 MARYLAND AVE, SW, WASHINGTON, DC 20202 The Department of Education '5 mission is to promote student achievement and preparation for global competitiveness by fostering educational exce Hence and ensuring equal access. Additionally, in the coming months ED will issue a comprehensive summary of each SEA's implementation of ESEA flexibility that includes information gathered through the Part monitoring process and provides more detail about the innovative practices and common challenges that States are facing as they engage in the effective implementation of ESEA flexibility. I want to thank you and your staff for the hard work you have undertaken to implement ESEA flexibility. If you have any questions or there are ways that ED staff can provide you additional support as you move forward in implementing your ESEA flexibility request, please feel free to reach out to your SEA's ESEA flexibility contact. I look forward to continuing our work with you as you implement your ESEA flexibility request. "Thank you for your commitment to New ersey's children. Sincerely, Moni ue M. Chism, Director Student Achievement and School Accountability Programs Enclosure cc: Bari Erlichson James Palmer ESEA FLEXIBILITY PART MONITORING REPORT MONITORING VISIT INFORMATION - State Educational Agency (SEA) New jersey Department of Education (NJDOE) Request Approved February 9, 2012 Request Amended A ESEA Flex Monitoring Activity Part Desk Monitoring Monitoring Review Date(s) July 23-25, 2013 Exit Conference August 16, 2013 Interviews Conducted NJDOE Staff U.S. Department of Education (ED) Dave English, Francisco Lopez, and Renee Monitors Faulkner OVERVIEW OF ESEA FLEXIBILITY MONITORING The U.S. Department of Education (ED) is committed to supporting State educational agencies (SEAS) as they implement ambitious reform agendas" through their approved ESEA flexibility requests. Consistent with this commitment, ED has designed a monitoring process to assess an SEA's implementation of the principles of ESEA flexibility and the State-level systems and processes needed to support that implementation. Part Monitoring - In Part monitoring, SEA implementation of ESEA flexibility was reviewed across several key areas: State-level Systems and Processes, Principle 1, Principle 2, and Principle 3, as outlined in the ESEA .FZox7'oz'Zi{y Pom' Monitoring Protocol. In each broad area, ED identified key elements that are required under ESEA flexibility and are likely to lead to increased achievement for students. Through examination of documentation submitted by the SBA and interviews with SEA staff, ED assessed the effectiveness of implementation of ESEA flexibility by identifying the extent to which an SEA: 1. Is ensuring that implementation is occurring consistent with the SEA's approved request and the principles and timelines of ESEA flexibility. 2. Is continuing to review and make adjustments to support implementation. 3. Is establishing systems and processes to sustain implementation and improvements. The report contains the following sections: 0 Qfl/J6' SEA Imp!oz22em'o'z'z'oo. This section identifies key accomplishments in the SEA's implementation of ESEA flexibility. I Srotzzr ofI772}J/eozenrozioo ofE5E/l FZex2'oz'Zz'g/. This section indicates whether or not the SEA has met expectations for each element of ESEA flexibility. 0 Elements Reqzzirzag Next frgox. When appropriate, this section identifies any elements where the SEA is not meeting expectations and includes Next Steps that the SEA must taketo meet expectations. 0 Recooz772e7zdorz'o72.r to Imp/emem'oa'z'o7z. This section provides recommendations to support the SEA in continuing to meet the principles and timelines of ESEA flexibility and strengthening implementation. I /ldd2'z'z'o?2oZ Coozozmfi. When appropriate, this section includes any additional information related to the SEA's implementation of ESEA flexibility not included elsewhere. HIGHLIGHTS OF IMPLEMENTATION OF ESEA FLEXIBILITY The SEA's work includes the following key accomplishments relating to the implementation of ESEA flexibility and/ or efforts to engage in a process of continuous review and analysis, particularly for those elements receiving a comprehensive review: 0 NJDOE has established a model curriculum divided into 6- to 8~week learning units, aligned to college-- and career--ready standards and supported by formative assessments and monitoring in priority and focus schools, at the end of each learning unit. Systems are aligned to assess student performance data and school improvement implementation status data within these 6- to 8-week cycles. 0 NJDOE has enacted a regulation that closely reflects ESEA flexibility turnaround principles for priority schools. 0 NJDOE has delivered thoughtful, focused oversight of and capacity--building around the development and implementation of Student Growth Objectives, to measure student growth in non--tested grades and subjects, for all teachers beginning in the 2013-2014 school year. STATUS OF IMPLEMENTATION or ESEA FLEXIBILITY SEA Systems Processes -. I 1 3 . -- Monitoring (EDGAR 80.40 and 2(3) Not Meeting Expectations* Technical Assistance (2.G) Meeting Expectations Data Collection Use .. Meeting Expectations Family Community Engagement and Outreach Meeting Expectations (Implementation Letter) Principle 1 Transition to and. Implement" College-- and Meeting Expectations ready (CCR) Standards (1.B) Adopt English Language Proficiency Standards Meeting Expectations (Assurance 2) Develop and Administer High-Quality Meeting Expectations Assessments (Assurance 3) Develop and Administer Alternate Assessments Meeting Expectations (Assurance 3) Develop and Administer English Language Meeting Expectations Proficiency Assessments (Assurance 4) Annually Reports College-going and College- Meeting Expectations credit Accumulation Rates (Assurance 5) Principle 2 Elen-lent I I Develop and Implemientia State-Iiaised Meeting Expectaitionisi I Differentiated Recognition, Accountability, and Support (2.A) Reward Schools (2.C) Meeting Expectations Priority Schools (2.D) Not Meeting Expectations Focus Schools Not Meeting Expectations Other Title I Schools Not Meeting Expectations State and Local Report Cards (?l1l1 of the Meeting Expectations 2.B and Assurance 14) Principle 3 Eiemteeat - -.- .. Teacher Evaluation and Support Systems (3.B) Meeting Expectations Principal Evaluation and Support Systems (3.B) Meeting Expectations ELEMENTS REQUIRING NEXT STEPS its approved ESEA flexibility request and the principles and timelines outlined in the document titled and the Education Department General Administrative Regulations (EDGAR) 80.40. SEAS are required, for all ESEA flexibility principles, per EDGAR 80.40, to "monitor grant and subgrant supported activities to assure compliance with applicable Federal requirements and that performance goals are being achieved" including comparing "actual accomplishments to the objectives." Regional Achievement Centers (RAC) Hack implementation of interventions in all priority and focus schools (Principle 2) and take measures to improve implementation of selected interventions in those schools requiring assistance. NJDOE surveys all local educational agencies (LEA) regarding key implementation milestones for itnplementation of teacher and principal evaluation systems (Principle 3) and collaborates with LEAS to improve implementation in the case of deficiencies. Summary and Status of Implementation Whfle NDJOE has provided guidance, training and technical assistance to its LEAS to support the implementation of CCR standards by the 2013-2014 school year (Principle 1), NJDOE does not have a process in place to track the status of implementation of CCR standards during the 2013-2014 school year not to facilitate adjustments to local implementation based on the results of such status determinations. NJDOE will submit an amendment as part of its ESEA flexibility extension request that describes in detail its revised monitoring plan and process to (1) monitor the status of implementation of CCR standards in all LEAS and (2) support the implementation efforts of LEAs appropriately. Next Steps 3 The SEA has not demonstrated that this ele ent is carried out consistent with . 'FEE-l?iihent *Subsequent to the monitoring event, NJDOE provided ED with evidence of monitoring and support systems for ensuring implementation of CCR standards in classrooms beginning in the 2013-2014 school year. NJDOE provided documentation of its Quality Single Accountability Continuum (QSAC) LEA review process which includes the review and continuous improvement, on a three-year cycle, of LEA processes for ensuring that curricula and lesson plans are aligned with CCR standards and that instructors are teaching to CCR standards in classrooms. No further action is required. -- - Summary and Status of Implementation The SEA has not demonstrated that this element is carried out consistent with its approved ESEA flexibility request and the principles and timelines outlined in the document titled which states that snag must effect change in priority schools by "ensuring that each LEA with one or more of these schools implements, for three years, meaningful interventions aligned with the turnaround principles." Three years of concurrent implementation of all turnaround principles is required in priority schools regardless of when the school exits priority status. NJD OE committed to full implementation in all priority schools beginning in the 2012-2013 school year. RACS do have processes for ensuring that SIPS for non--SlG priority schools include planned improvement activities addressing each of the seven ESEA flexibility turnaround principles; however, (1) the "implementation progress goals" driving priority SIPS are framed in terms of total number of improvement activities completed, not the successful concurrent implementation of improvement activities across all turnaround principles and (2) monitoring reports do not describe completed improvement activities, nor provide feedback on necessary adjustments to support the concurrent implementation of all' ESEA flexibility turnaround principles. Thus NJDOE does not have sufficient mechanisms in place to make a determination of whether a priority school is implementing all ESEA turnaround principles concurrently. Additionally, NJDOE reported it would count the 2012-2013 school year as the first of three required years of implementation in all non--SlG priority schools re ardless of intervention irn lementation monitorin results. SEAS ma count, 8 8 towards a priority school's three years of implementation, only those years in which a school has implemented 52!! turnaround principles concurrently with sufficient fidelity. As such, NJDOE may not count schools that were not implementing all turnaround principals toward this requirement. Next Steps As part of its ESEA flexibility extension request, NJDOE will submit a high- quality plan for adjusting or augmenting its SIP and monitoring processes to facilitate the determination of whether its non--SIG priority schools are concurrently implementing all ESEA flexibility turnaround principles for the 4 2013-2014 school year and going forward, including steps to determine whether implementation with sufficient fidelity occurs for a total of three years. NJDOE should also include an analysis of 2012-2013 and 2013--2014 implementation status data for priority schools to determine which schools implemented all turnaround principles concurrently during the these school years. 5 . . . Summary and Status of Implementation The SEA has not demonstrated that it is ensuring that this element is carried out consistent with its approved ESEA flexibility request and the principles and timelines outlined in the document titled FXex7'bz'Zz't which states that SEAS must work to close achievement gaps by "ensuring that each LEA implements each of these [focus] schools based on reviews of the specific academic needs of the school and its students." LEAS are expected to identify those student groups which led to a focus school's identification and ensure that the selection and implementation of one or more interventions is based on data and other information on the academic and non--academic needs of those identified student subgroups, including English learners, students with disabilities and low--achieving students. - NJDOE committed to full implementation in all focus schools by the first semester of the 2012-2013 school year, per ESEA flexibility requirements. \lVhile RACS have a process for ensuring that LEAS plan improvementactivities targeting the two student groups whose performance led to the school being identified as a focus school (in the context of an overall "Quality School Review" that examines the performance results of all students and other indicators of school performance), (1) monitoring reports do not explicitly track implementation of these targeted improvement activities nor provide feedback to LEAS about adjustments to their implementation if needed, and (2) implementation goals embedded in SIPs do not explicitly address implementation of these targeted improvement activities (goals address percentage of all improvement activities implemented). Next Steps As part of its ESEA flexibility extension request, NJDOE will submit a high quality plan for adjusting or augmenting its SIP and monitoring processes to facilitate the determination of whether its focus schools are implementing, with sufficient fidelity, those interventions targeting performance of the two lowest-- performing subgroups, for the 2013~2014 school year and going forward, including (1) adjusting monitoring report templates to reflect the implementation status of those targeted improvement activities and (2) adjusting implementation goals to address implementation of those improvement activities. Summary and Status of Implementation The SEA has not demonstrated that this element is carried out consistent with the principles and timelines outlined in the document titled ESEA SEAS are required to provide incentives and supports to ensure continuous improvement in other Title I schools that, based on the SEA's new annual measurable objectives (AMO) for proficiency and graduation rate targets approved in its accountability workbook, are not making progress in improving student achievement and narrowing achievement gaps. In Part A Monitoring Report, a "next step" was included requiring the SEA to submit an amendment regarding how it would use accountability workbook graduation rate targets (7 5% graduation rate for the 2011-2012 school year and increasing by 3% every two years thereafter, with a goal of 90%) to identify and drive interventions in other Title I schools during the 2013-2014 school year. In March 2013, NJDOE proposed to identify those Title I schools for which any ESEA subgroup either (1) did not meet a proficiency AMO or (2) had a graduation rate less than 60%, based on previous school years' data. The Department determined, in October 2013, that proposal would not result in the SEA identifying a number of other Title I schools comparable to the number otherwise identified based on performance against accountability workbook graduation rate targets and notified NJDOE that it must use performance against accountability workbook graduation rate targets to identify and drive interventions in other Title I schools during the 2013-2014 school year. Due the timing of the Department's determination regarding proposal, NJDOE was not given ample opportunity to comply with this requirement prior to the Part monitoring event. Next Steps As part of its ESEA flexibility extension request, NJDOE will submit an amendment that describes how it will require its LEAS to implement appropriate interventions, during the 2013-2014 school year and going forward, in all other Title I schools with an ESEA subgroup that either (1) did not meet a proficiency AMO or (2) did not meet a graduation rate target, as approved in its accountability workbook, based on previous school years' data. RECOMMENDATIONS To STRENGTHEN IMPLEMENTATION The following recommendations are provided to support the SEA in continuing to meet the principles and timelines .of ESEA flexibility and strengthening implementation through continuous improvement and the establishment of systems and processes to sustain implementation and improvement. 0 NJDOE should prioritize and complete the scaffolding activities described in its approved ESEA flexibility request, to support the transition to college-- and career--ready standards for English learners and students with disabilities. NJDOE should prioritize the training for principals described in its approved ESEA flexibility request regarding evaluation of implementation of CCR standards at the classroom level by teachers. NJDOE should strengthen RAC capacity by: 0 providing training for RAC specialists regarding identification and implementation of appropriate interventions to meet the needs of students with disabilities, and 0 developing and implementing an electronic data system to automate the tracking and analysis, in the context of ESEA flexibility requirements, of intervention implementation status in priority and focus schools. NJDOE should update the "Progress Targets Report" templates to facilitate the identification of and approval of interventions in Title I high schools identified based on performance against accountability workbook graduation rates. NJDOE should prioritize policy--making and planning efforts around commitment, per its approved ESEA flexibility request, to prohibit the hiring of teachers rated "ineffective" or "partially effective" in priority schools following full implementation of its new teacher evaluation system in the 2013-2014 school year.