CAST: Universal Design for Learning

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What approaches exist for enabling students with low-incidence disabilities to participate in state- and district-level assessment systems?

• The Role of Assessment in Standards-Based Reform
• Broad-Scale Assessment Systems
• Standards-Based Assessment and Students with Disabilities
• Participation of Students with Disabilities in Assessment and Accountability Systems
• Changes in Assessment Systems for Students with Disabilities
• Alternate Assessment Systems

In order to form a basis for answering this very complex question, some background information is required. Standards-based reform has been well underway since the enactment of the Improving America's Schools Act of 1994. Some basic discussion must be undertaken before considering how participation in assessment systems can increase access to the general curriculum for students with low-incidence disabilities.

The Role of Assessment in Standards-Based Reform

Following over two decades of education reform in the U.S., nearly all states have established a framework for guiding local school authorities with the process of curriculum development aimed at bringing about standards-based reform. As part of this effort to ensure that schools and school districts organize and employ their resources appropriately to address state standards in core content areas, states have developed broad-scale assessment systems to measure the extent to which students are progressing and achieving proficiency in core subjects. These assessment systems are intended not only to determine individual student achievement but also to hold states and schools accountable for public investments in education reform.

Broad-scale assessment systems are summative to the extent that they purport to measure attainment of specific standards following certain multi-year instructional periods—initially at the end of grades 4, 8, and 10. While these assessments provide data which can be used to target resources and promote policy that will improve results for all students, many state assessment systems also carry high stakes for individual students. For example, grade advancement and high school graduation may be contingent upon reaching certain levels of proficiency, as measured solely by one specific test. Ideally, these tests provide schools with valuable information about the effectiveness of their instructional practices and curriculum resources. Summative information about student progress, however, is insufficient for providing local authorities with data needed to inform instruction at optimal times, since it takes place after a period of learning is complete, and cannot identify and correct problems until failure has occurred. To address this shortcoming, school districts frequently develop local assessment systems in content areas based on nationally and locally generated norms. For example, using curriculum-based assessment and evaluation techniques, school systems can develop local standards of mastery and local norms that more directly and immediately inform decisions about curriculum and instruction. Schools may also develop or adopt local assessment practices at the classroom level that monitor student progress. These multiple sources of assessment data are increasingly available in schools. Together, they inform teacher decisions about their focus of instruction, alignment of curriculum with state and local standards, and the need for targeted intervention for students not making effective progress.

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Broad-Scale Assessment Systems

Assessment systems yield information about individual student progress, instructional effectiveness, and alignment of curriculum with standards. Seemingly limitless comparisons among student test scores can be made, simply by aggregating the data in multiple ways. Comparisons can be made between individual classrooms, schools, or school systems, as well as between students from different racial, cultural, linguistic, and disability groups. In this fashion, assessment systems can be used to attempt to answer questions of how well our schools are doing in general, as well as detecting inequities in achievement between different student groups. Because stakeholders deserve (and at times demand) answers to such questions, assessments of this type are intended to provide a measure of accountability.

Assessment systems can be built and implemented in many different ways. States and local school authorities can design their own systems, purchase commercial systems, or adapt systems in use by other entities. The frequency of test administration and the number of core subject areas examined may be determined legislatively and then augmented according to state and/or local prerogative. The depth, elaborateness, and authenticity of tests may vary according to costs associated with development, administration, and maintenance of a chosen assessment system. Because assessment systems rely on tests as samples of student academic behavior, they may serve some criterion of efficiency and cost effectiveness. While accountability systems that attach high stakes to single tests that sample limited domains of curriculum may be viewed as "efficient," they reveal only a narrow perspective on the intended outcomes of such a complex enterprise as education.

Assessment systems in general attempt to answer the following questions:

1. What have students learned?
2. How well were they taught?
3. How effective is a school?
4. How effective is a school district?
5. How effective is a state in supporting local reform efforts?

Other concerns can be addressed through assessment, but critical questions in standards-based reform come down to an examination of what students have gained from their educational experience and how the public has benefited from its investment in its schools.

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Standards-Based Assessment and Students with Disabilities

Since the passage of IDEA '97, these critical questions must be asked on behalf of students with disabilities as well. Modern assessments should reveal what students with disabilities gain from their experience in school and how society benefits from its investment in the futures of these students. Students with disabilities should have the opportunity to gain what all other students can gain. They should have access—in a flexible and responsive manner—to the same curriculum that is intended for all non-disabled students. They should be able to participate in the curriculum. Thus, IDEA '97's mandate to include students with disabilities in state- and district-wide assessment systems can, at least in principle, reveal the level of content mastery and the relative standings of these students in their classrooms and schools.

The 2001 reauthorization of the Elementary and Secondary Education Act, now called the No Child Left Behind Act (NCLB), represents Congress' desire to align all reform initiatives with the mandate to improve results for all students, including those with disabilities. The historically dual worlds of general and special education, with their respective separate accountability systems, are now legally merged into one education enterprise for all students with shared mechanisms for accountability. To accomplish reform for all students, assessment systems must both identify individual students operating below acceptable proficiency levels and uncover schools that are low-performing overall. The results of these assessment systems can then be used to direct federal funding and concentrate resources in schools and communities that have demonstrated the greatest need for assistance and improvement. In order to accurately reflect any real gains brought about in response to reform, these assessments must be fair and unbiased, must yield reliable measurements, and must align with standards.

Accountability for the education of students with disabilities has suffered from documented problems arising from the existence of separate special education accountability systems and historically low participation rates for students with disabilities within general education. An urgent concern exists to improve the accountability of schools for the education of these students. As a partial answer to this concern, IDEA '97 requires states and districts to include students with disabilities in their state- and district-wide assessment programs. The assumption is that if schools are to consider the needs of students with disabilities deliberately and proactively in reform and improvement activities, outcomes for students with disabilities must be represented in public accountability systems (M^cDonnell, M^cLaughlin, & Morrison, l997).

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Participation of Students with Disabilities in Assessment and Accountability Systems

To understand how participation of students with disabilities in assessment systems is managed, some background information is required. Assessment refers to the process employed by state departments of education and by local education agencies to systematically collect data on students. The current assessment vehicle for obtaining this data is the test, and tests can do no more than sample domains of what students are supposed to know and be able to do. They can provide no exhaustive measure of every capability a student possesses. Thus, the accuracy and predictability of tests will always fall short of certainty for any given purpose.

For students with low-incidence disabilities, participation in a fair and feasible assessment system will, in the long run, prove to be a costly undertaking. The provision of special education and related services to students with disabilities has been disproportionately expensive since the original 1975 enactment of IDEA. Federal, state, and local revenues currently absorb excess costs associated with educating students with disabilities. Since these resources are not limitless, they are distributed only to students who qualify as disabled and demonstrate a need for specially-designed instruction. It is, therefore, not unreasonable to expect that costs associated with fair and appropriate assessment for students with disabilities would also be disproportionately high, but again limited only to those who qualify for them.

Several studies have documented that, historically, participation of students with disabilities in statewide assessments has been minimal, with extensive state-to-state variation (Erickson, Thurlow, & Thor, 1995; M^cGrew, Thurlow, Shriner, & Spiegel, 1992; Shriner & Thurlow, 1992). This low participation rate of students with disabilities has been documented despite the difficulty of calculating comparable figures across locations and the tendency of states to calculate participation rates in ways that inflate estimates (Erickson, Thurlow, & Ysseldyke, 1996). IDEA '97 and NCLB prohibit states and local education authorities from excluding students with disabilities from participation in both state and local assessment systems. While, in the past, participation has been minimal, the notion of a zero-reject is unprecedented (Thurlow & Johnson, 2000).

In the past, several defensible reasons for limiting participation in assessment systems have been offered. Foremost, students with disabilities have been given limited opportunity to participate in the general curriculum. It would make little sense to examine students on material with which they have had limited exposure. Additionally, assessment instruments may have contained item stimuli inaccessible to some students. Furthermore, test administration procedures may have required behaviors beyond the response repertoire of some students. Clearly, participation in assessment systems under these circumstances would seriously disadvantage students with disabilities. Moreover, the use of such unreliable and largely inaccurate data generated by these accountability systems would misrepresent the capabilities of students with disabilities and lead to flawed educational decisions.

On the other hand, state and local policies for excluding students with disabilities from participation reinforce a cycle of low expectations and altered or absent standards. Exclusion helped to maintain the world of special education as a separate place with its own isolated system of standards and accountability. Without participation, there was no means of determining the extent to which students with disabilities received an equal opportunity to learn and succeed.

Special education services and supports are comparatively expensive to operate and maintain. Eligibility is thus limited to those who qualify on the bases of age, disability status, and extent of assessed need. This presents the questions, What do students with disabilities derive from a costly special education? What does the public gain from this entitlement? As with standards-based reform in general education, special education programs raise these and other accountability questions. Because IDEA '97 and NCLB prohibit exclusion from state and local assessment systems for all students with disabilities—even students with the most intensive disability-related needs—the challenge for state and local authorities is to design assessment instruments and procedures that accurately sample and measure student performance in a fair and meaningful manner. It would not be fair, for example, to assess abstract reasoning using pictures with a blind student or using verbally presented sentences with a deaf student.

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Changes in Assessment Systems for Students with Disabilities

To insure that all students with disabilities can access and participate in the general curriculum, as first mandated by IDEA '97, no student—regardless of severity of disability—can be excluded from participation in state- and district-level assessment systems intended to measure progress. A student' IEP team (on which a general educator must now serve) determines the nature and extent of instructional accommodations and curriculum modifications necessary for that student to access the general education curriculum and to demonstrate progress by participation in state- and district-level assessments. A student's IEP team makes a determination of each student's need for assessment accommodations (e.g., Braille as opposed to print) or an alternate form of assessment (e.g., portfolio documentation of student accomplishments).

The National Center on Educational Outcomes at the University of Minnesota has been tracking state policies and practices on statewide testing for over a decade. As with the issue of classroom inclusion, the issue of changes in testing and measurement practices has been rife with controversy. Thurlow, Quenemoen, Thompson, and Lehr (2001) propose six core principles for states to follow in developing inclusive assessment and accountability systems (see Appendix E):

Building upon these principles, Lehr and Thurlow (2003) have identified five essential components of an inclusive assessment system:

1. Student participation in assessments
2. Testing accommodations
3. Alternate assessments
4. Reporting results
5. Accountability

Student participation means that no one is excluded. Testing accommodations ensure that students are fairly assessed. Alternate assessments means that students are appropriately tested. Reporting results refers to informing the public as well as the participants of test results, and accountability refers to the application of consequences regarding those results. Lehr and Thurlow assert that states must address all five components if students with disabilities are to benefit from standards-based reform.

Lehr and Thurlow also state that students with disabilities can participate in assessments in three ways:

• in the same way as other students,
• with accommodations,
• with alternate assessments (developed for students who cannot participate in general assessments even with accommodations).

Generally, test changes are grouped into two types: accommodations and modifications. Accommodations are changes in the way a test is given or taken but do not alter the central construct measured by the test. In contrast, modifications are substantial changes in the way the test is given or taken and definitely alter the construct measured by the test.

Accommodations

Accommodations are changes in standardized assessment conditions introduced to 'level the playing field' for students by removing the construct-irrelevant variance created by their disabilities (Tindal & Fuchs, 2000). According to Ysseldyke, Thurlow, M^cGrew, and Shriner (1994), accommodations can be grouped into the following four categories:

• Presentation adaptations, in which stimuli (materials) presented to students are modified;
• Response changes, in which students are allowed to use a different manner of responding;
• Setting adaptations, in which variations are made in the context of where tests are administered and who administers a test;
• Timing and scheduling adaptations, in which changes are made in length and quantity of how many sessions a test is administered.

Valid accommodations produce scores for students with disabilities that measure the same attributes as standard assessments measure in non-disabled students. On the one hand, disallowing valid accommodations prevents students with disabilities from demonstrating their abilities. On the other hand, overly permissive accommodation policies inflate scores and inadvertently reduce pressure on schools to increase expectations and outcomes for students with disabilities (M^cDonnell, et al., l997).

Broad-scale assessment systems are designed to accommodate the attention span, frustration tolerance, freedom from distractibility, sensory acuity, response capability, and developmental level of "typical" students. Students with low-incidence disabilities can be placed at a disadvantage by participating in such systems because of the artifacts of tests and testing situations. Both standard and, in some states, non-standard accommodations are specified to allow fair participation. For example, if a student is instructed in how to compose an essay using a talking word processor, then that student must be allowed to demonstrate competence in composition using a talking word processor. The key to understanding testing accommodations is knowing that a student must independently demonstrate his or her attainment of standards. This means that scribes, translators, or test administrators cannot coach, paraphrase, or revise student products either during or after test administration.

Modifications

For students whose instruction and curriculum is substantially modified, accommodated assessment systems are inappropriate. Such students will require an alternate assessment. Alternate assessments should be administered to students with disabilities who, for a variety of reasons, cannot reasonably be expected to score at an acceptable level of proficiency on accommodated assessment systems. An alternate assessment should measure the extent to which a student has progressed against benchmarks delineated in their IEP. Goals and objectives contained in a student's IEP should address disability-specific needs but also be aimed at or embedded in a school district's general curriculum language (and also aligned with state standards). Thus, an alternate as well as an accommodated assessment must measure progress in the general curriculum, regardless of a student's extent of disability and point of entry in the general curriculum. An alternate assessment should be constructed in such a way that it is sensitive to a student's ways of knowing and doing and sufficiently robust to measure their attainment of state standards. Obviously, alternate assessment is a costly and time-consuming endeavor because it is ultimately more authentic and is tailored to an examinee.

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Alternate Assessment Systems

Alternate assessments are intended to measure the proficiency of students who are unable to participate in broad-scale state assessments, either with or without accommodations. An alternate assessment establishes a mechanism for including students with significant cognitive disabilities as well as other students who may be difficult to assess in accountability systems. Typically, a very small percentage (approximately 1%) of students may require an alternate assessment. Substantial modifications to academic content standards at grade level and the need for intensive, individualized instruction in order to acquire and generalize knowledge greatly influence a decision to include a student in an alternate assessment. Children with significant cognitive disabilities have historically been excluded from participation in state-mandated and district-wide assessments because these students are not able to take the pencil-and-paper assessments ordinarily given to the rest of the school population. While there has been a considerable amount of research done in the field of general education to help identify what skills a student labeled as proficient must possess, moves have only recently begun for "research-based evidence where quality curriculum outcomes are definable and measurable for students with significant disabilities" (Quenemoen, Rigney, & Thurlow, 2002).

State-level alternate assessments were first required as an assessment option by IDEA '97. NCLB regulations also address alternate assessment by requiring that each state, district, and school be held accountable for the achievement of all students, including those participating in alternate assessment(s). While states have differed markedly in their approach to alternate assessment since its inception, the intention is to align alternate assessments to academic content standards and to make it possible to include all students with disabilities in state and district assessments and accountability systems. States' approaches to alternate assessment differ substantially from those that states use in their general assessment system. The table below is adapted from Quenemoen, Thompson, and Thurlow (2003) have summarized five separate approaches in use by states (see Appendix F).

Quenemoen et al.'s work reveals that alternate assessment in some states consists of just a modified paper-and-pencil version of an original assessment given to the general education population. Alternate assessments of other states are made up of a checklist of developmental skills. In a majority of states, alternate assessments are comprised of "a body of evidence collected by educators, parents, and the student to demonstrate and document the student's skills and growth toward the state standards; sometimes the alternate assessments also incorporate characteristics of educational supports that the student receives" (Quenemoen, et al., 2002). These types of assessments are usually gathered in portfolio form and take into account the complexity of student disabilities.

Initially, alternate assessments for students with significant cognitive disabilities focused on measuring only functional skills (Kleinert & Kearns, 1999). More recently, alternate assessments have been created to measure student achievement of state academic standards (Thompson & Thurlow, 2001). Current standards-based alternate assessment approaches have emerged in most states as a result of federal regulations and policy guidance. For example, according to NCLB regulations, states may set alternate achievement standards for alternate assessments for students with significant cognitive disabilities, but only for a maximum of 1% of the total student population in a school district. These alternate achievement standards must identify appropriate levels of proficiency within the content domains of English/Language Arts, Mathematics and, eventually, Science. Thus, alternate assessment is clearly intended to lie at one end of a continuum within each state's large-scale assessment system.

To be sure, some states have been successful in creating high-quality alternate assessments. Educators and parents in these states can truly understand what students with significant cognitive disabilities should know and be able to do as a result of their educational opportunity. From an examination of high-quality alternate assessments from separate states, Quenemoen (et al., 2002) describe five best-practice steps for states to follow in creating alternate assessments. (See Appendix G for a full explanation of these steps.)

With particular concern for students with significant cognitive disabilities, Ford, Davern, and Schnorr (2001) offer five principles to consider when developing and applying standards for the purpose of alternate assessment:

1. Every student should receive priority attention to the development of foundational skills.
2. Individualization is at the core of a good education.
3. Educational priorities should be pursued through schedules and locations that are respectful of a student's membership in a learning community.
4. Students should have an opportunity to experience a sense of mastery or accomplishment over tasks they undertake.
5. Being attentive to the quality of a student's immediate experience is as important as concern for their future.

These five principles emphasize the importance of retaining ethical, person-centered gains made on behalf of students with severe disabilities, while moving forward in the current climate of standards-based reform.

Massachusetts Alternate Assessment

Massachusetts uses a portfolio approach to alternate assessment. Since Massachusetts' development and subsequent refinement of the portfolio approach has drawn considerable national attention (Wiener, 2002), it is described here in some detail as an exemplary practice. Massachusetts' alternate assessment is designed to assess proficiency in the same grade-level learning standards as does the Massachusetts Comprehensive Assessment System (MCAS) for non-disabled students. An examination of the testing schedule for the MCAS alternate assessment (MCAS-Alt) below reveals its comparability with MCAS. Note that content domains assessed in Massachusetts exceed what is currently required by NCLB.

¹Science & Technology/Engineering portfolios must include evidence in three strands, preferably from a current school year. However, when this is not possible because the student has received Science instruction in fewer than three strands during a current year, it is permissible to include three strands spanning both a current and one previous school year (for this subject only).

Eligibility for MCAS-Alt is determined by IEP teams after consideration of MCAS with either standard or non-standard accommodations. That is, a team must find that MCAS is inappropriate for fairly and adequately testing the student in question. Note that the above table presumes that content areas, strands within areas, and grade-level learning standards are assessed by MCAS-Alt. If a student is enrolled in an un-graded program, that student will be assessed at the grade-level corresponding to that student's chronological age.

In Massachusetts, an alternate assessment portfolio is compiled through a highly formal procedure in which evidence of proficiency is collected and documented in separate packages for each content-area strand for a grade level being tested. An MCAS-Alt portfolio consists of a year-long collection of work samples, corroborative evidence, and required instructional data documenting a student's knowledge of concepts, skills, and content outlined in the Massachusetts Curriculum Frameworks learning standards. Not all grade-level content-area strands are required to be assessed for each grade, and exceptions are permitted for students whose programs are addressing below-grade-level content-area strands when progress can be documented.

Massachusetts has developed a procedure for reviewing, evaluating, and scoring all student portfolios. The MCAS-Alt Rubric for Scoring Portfolio Strands is presented below. (Much of the information described pertaining to MCAS-Alt can be found at http://www.doe.mass.edu/mcas/alt.)

Scorers examine each portfolio strand using the following criteria and generate a score for each area of the rubric based on evidence found in a portfolio (see scoring rubric):

• Completeness of all portfolio materials
• Level of complexity at which a student addresses learning standards found in the Massachusetts Curriculum Frameworks for the subject being assessed
• Accuracy of a student's response and/or performance
• Level of independence demonstrated by a student in performance of each task or activity
• Self-evaluation (reflection, self-correcting, goal-setting) during or after a task or activity
• Number of instructional contexts in which a student demonstrates knowledge or performs a task or activity (generalization)

A numerical score based on the Rubric for Scoring Portfolio Strands is generated for each rubric area for each portfolio strand: Level of Complexity (1–5), Demonstration of Skills and Concepts (1–4), and Independence (1–4). A combined score for an entire content area is generated for Self-Evaluation (1–4) and Generalized Performance (1–4). A score of "M" means there was insufficient evidence or information to generate a numerical score for a rubric area.

For each student whose classroom teacher submits an MCAS-Alt, one of the following performance levels is reported for each content area of their portfolio:

• Incomplete—The portfolio contains insufficient evidence and information to permit determination of a performance level in the content area.
• Awareness—Students at this level demonstrate very little understanding of learning standards and core knowledge topics contained in the Massachusetts Curriculum Frameworks in the content area. Students require extensive prompting and assistance, and their performance is primarily inaccurate.
• Emerging—Students at this level demonstrate a simple understanding of a limited number of learning standards and core knowledge topics contained in the Massachusetts Curriculum Frameworks in the content area, below grade-level expectations. Students require frequent prompting and assistance, and their performance is limited and inconsistent.
• Progressing—Students at this level demonstrate a partial understanding of some learning standards and core knowledge topics contained in the Massachusetts Curriculum Frameworks in the content area, below grade-level expectations. Students appear to be receiving challenging instruction, and are steadily learning new skills, concepts, and content. Students require minimal prompting and assistance, and their performance is fundamentally accurate.
• Needs Improvement—Students at this level demonstrate a partial understanding of subject matter contained in the Massachusetts Curriculum Frameworks in the content area and solve some simple problems at grade-level expectations.
• Proficient—Students at this level demonstrate a solid understanding of challenging subject matter contained in the Massachusetts Curriculum Frameworks in the content area and solve a wide variety of problems at grade-level expectations.
• Advanced—Students at this level demonstrate a comprehensive and in-depth understanding of subject matter contained in the Massachusetts Curriculum Frameworks in the content area and provide sophisticated solutions to complex problems at grade-level expectations.

In order to qualify for a high school diploma in Massachusetts, students submitting an MCAS-Alt must complete it at a performance level of Needs Improvement, Proficient, or Advanced for grade 10 assessments in English/Language Arts and Mathematics. The review of a grade 10 MCAS-Alt entails a "competency determination" or an endorsement by the state of Massachusetts for high school graduation. Local school districts have additional criteria for graduation, which may or may not prevent a student from receiving a diploma. It is noteworthy that, while alternate assessment is intended for students who function presumably at lower entry points to the general curriculum, the rubric does allow students to score at an advanced level by revealing a comprehensive and in-depth understanding of grade 10 learning standards.

In addition to providing a method for summative evaluation of a student's achievement in core curriculum areas, the MCAS-Alt scoring rubric is also intended to guide and assist local authorities with planning and implementing high-quality instructional services. The Massachusetts IEP form appropriately begins with identifying each student's present level of educational performance (PLEP) in each area of the general curriculum impacted by a student's disability. PLEPs for each grade-level subject area may be above, at, or below grade level. A student's team must determine an entry point for each content-area strand in order to specially-design instruction. The Massachusetts Department of Education web site provides both online and downloadable documentation of policies and procedures for team members to use to enable students to participate in standards-based instruction. For example, once specific learning standards are identified as a student's entry points to the curriculum, guidance is provided for their IEP team to capture the "essence of the standard" by breaking it down from more to less complex. This enables a student's IEP team to plan instruction aligned with standards above, at, or below grade-level expectations or in terms of "access skills" required to approach the standard. Essential access skills may lie in more traditional domains such as social, motor, and/or communication area(s).

Additional guidance is provided around "instructional ideas" or suggestions about how to specify instructional targets once entry points have been identified. A portfolio must contain an analysis of data collected during instruction. Templates for a variety of data recording and reporting are provided by the Massachusetts Department of Education to assist with this process. Instructional ideas also contain suggestions for implementing systematic instruction using cueing, prompting, and fading systems in addition to progress monitoring techniques. Finally, instructional ideas help teams embed instructional targets in classroom routines. These approaches require refined collaborative arrangements between special and general education teachers.

NCLB permits schools to alter standards for up to 1% of all students participating in MCAS. The table below reveals the comparability between MCAS and MCAS-Alt ratings. It shows how students participating in the MCAS-Alt assessment are evaluated against modified standards.

Allowance for altered standards at the 1% student population level limits the extent to which schools can be "punished" for the inability of students with significant cognitive disabilities to achieve grade-level academic standards.

Issues Remaining with Alternate Assessment

NCLB requires that all students attending public schools across America will reach or exceed their state's standards of academic proficiency in English/Language Arts, Mathematics, and Science by 2014. Toward that ambitious goal, schools and school districts must compute their "adequate yearly progress" (AYP) and adjust their improvement plans accordingly. Strict sanctions are in place for schools that do not progress according to projections based on the difference between a school's initial performance rating and students' expected performance by 2014. With the exception of some "safe harbor" provisions for schools that start out with a seriously under-performing student body, all schools are expected either to make effective progress or to lose vital resources and accreditation. NCLB empowers parents to obtain compensatory services or alternative placements when schools repeatedly fail to make adequate yearly progress. Local authorities are permitted to aggregate percentages of funds from historically separate reform initiatives to concentrate resources toward achieving higher proficiency levels for low-proficiency students. Principals are required to inform parents within strict time frames if their child is being taught by an unqualified teacher. Special education personnel who teach academic subjects are required to obtain content-area licensure. These are all provisions contained in NCLB that gradually take effect to increase accountability, local autonomy, and parent choice in order to improve America's schools so that no child, including a child with a disability, will be left behind.

With IDEA '97 and NCLB, students with disabilities are fully included in assessment and accountability systems for schools, districts, and states. Many students with low-incidence disabilities, such as students who are blind, deaf, or hard-of-hearing will participate with accommodations (such as those described above). IEP teams will have to take great care to ensure that students are being neither over- nor under-accommodated. Moreover, IEP teams will have to make sure that whatever accommodations are in place for fair testing, those accommodations will also be made in the context of instruction. State assessment personnel and their designated experts will also have to ensure that constructs used to measure progress in alternate assessment systems are relevant to standards being measured.

The greatest challenge for assessment and accountability appears to lie with the alternate assessment. The very idea of including students with significant cognitive disabilities in a standards-based, state accountability system is an important innovation and step forward. The original mandate for a free, appropriate public education (FAPE) for all students with disabilities was passed in 1975. The zero-reject principle at work at that time presumed that all children can learn and that public education is a fundamental right. However, what was then considered "appropriate" was an education geared to meet the unique needs of an individual child with a disability. What then accrued was a special education entitlement in which students with disabilities were given the opportunity to earn their way into the mainstream general education classroom.

Following two decades of unimpressive outcomes for special education students in terms of moving into the mainstream and making a successful transition into the world of work and daily life, Congress has now shifted its focus to the need for access to the general education curriculum and inclusion in standards-based reform through full participation in wide-scale assessment systems. The theory of action at work is to compel state and local authorities to take greater responsibility for, and ownership of, the learning outcomes of students with disabilities. However, learning outcomes for students with significant cognitive disabilities can not be assessed strictly in terms of levels of academic proficiency. There must be accountability for time and effort spent on addressing unique or disability-specific needs. Components of alternate assessment that document progress toward annual goals designated to reduce disability-specific need may, indeed, provide that accountability. On the one hand, an accessible general curriculum represents equal opportunity, and on the other hand, a carefully targeted special curriculum represents attention focused on human need. Here lies the essence of the dilemma. How can our one education for all children represent equal opportunity and attention to crucial needs at the same time?

A study by Browder (et al., 2004) helps to elucidate this very issue. Browder and her colleagues examined alignment of content on alternate assessments to both academic standards (Math and English/Language Arts) and functional life domains in 31 states. They first set the context for their study by reviewing the historical literature on serving students with severe disabilities. From their review, they were able to isolate three distinct shifts in curriculum focus: from a developmental skills emphasis to a functional life skills emphasis and then to a general curriculum emphasis. The shift from developmental skills to functional life skills was described as transformative—a paradigm shift. In analyzing separate states' approaches to alternate assessment(s), they hoped to learn if the shift from a functional skills curriculum to access to the general curriculum could be characterized as transformative, additive, or merely cosmetic.

Experts in Language Arts, Math, Education, and in severe disabilities, along with a group of teachers and administrators representing stakeholders, examined performance indicators on the selected 31 states' alternate assessments in terms of their alignment to national standards and curricula. Both stakeholders and experts found states that had alternate assessment performance indicators that were closely aligned to Language Arts or Math and those that did not. A smaller, sub-group of participants also considered the functionality of the indicators. Features of performance indicators that exemplified alignment with general or functional curricula were discovered by experts and stakeholders through a series of discussions. Results indicate that many states' current alternate assessments have a strong focus on academic skills, but results also suggested an additive curricular approach linking academic and functional skills. Researchers had hypothesized that curriculum transformation would be evident if performance indicators were closely aligned with the standards of the National Council of Teachers of English (NCTE) and the National Council of Teachers of Mathematics (NCTM) and were acceptable to stakeholders as reflective of Math and Language Arts curricula. On the other hand, if studied examples reflected not only Math and Language Arts standards but also continued to represent functional-curriculum and chronological-age appropriateness, the impact on curriculum would be additive. Alternatively, a cosmetic change would be evident in listings of functional skills under the headings of Math or Language Arts that did not align with NCTE and NCTM standards and were not credible to stakeholders as reflecting these content areas.

Individual and group analyses by both experts and stakeholders determined that performance indicators of only three states were in alignment with Math and Language Arts standards. Colorado began with state standards and extended them; Connecticut began with a functional curriculum and linked back to academic standards; and Arizona did both. Experts and stakeholders alike concluded that, regardless of the approach, all three of these states established performance indicators that were reflective of good access to the general curriculum. The overall findings of the Browder study reveal that experts and stakeholders will accept performance indicators that blend functional and general curriculum—indicating a trend toward merging these two types of curricula for students with severe disabilities. Clearly, this blend has not been achieved by the majority of states. Moreover, the performance indicators confirmed by the study are not necessarily relevant for all students.

While not merely cosmetic, the addition of general curriculum standards to functional life skills has a long way to go. Guidance does exist for blending the functional with the academic components of quality programs, but accountability seems to rest more heavily on the attainment of competency in core subject standards than on fulfillment of critical needs for students with low-incidence disabilities. As states move forward in this endeavor, it will prove increasingly important not to lose sight of program components that address disability.

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