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State: 53 LEAs must justify exceedance of federal 1% alternate-assessment cap; four face disproportionality review

December 01, 2025 | Utah State Board of Education, Utah Government Divisions, Utah Legislative Branch, Utah


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State: 53 LEAs must justify exceedance of federal 1% alternate-assessment cap; four face disproportionality review
Malia, a Utah State Board of Education (USBE) data staffer, told LEA data managers that the state exceeded the federal 1% cap on alternate assessments and that LEAs who exceed 1% must submit a formal justification letter by Jan. 5.

The justification must include current-year alternate-assessment projections — the count and percentage of students expected to complete alternate assessments in each subject — and supporting documentation uploaded to the Utah Program Improvement Planning System (UPIPs). “The justification letters are gonna be due by January 5,” Malia said.

Malia explained how to calculate the rate: the numerator is students expected to complete enough of the alternate assessment to receive a valid proficiency level, and the denominator is students expected to complete any of the state’s three summative assessments (DLM, RISE, or Utah Aspire Plus). Students known to be opted out are excluded from the denominator.

This year the state’s calculations show it went “over 1% in all 3 subject areas,” Malia said, triggering additional documentation requirements. The USBE has flagged 53 LEAs that must submit justification letters; of those, four LEAs are also identified for a required root-cause analysis to examine likely disproportionality by race/ethnicity, English-learner status, and low-income status.

To help LEAs replicate and review the state’s analysis, USBE uploaded a dataset and a three-tab tool to UPIPs: a disproportionality summary tab that flags groups, a methodology tab describing risk ratios and confidence-interval rules, and a three-year aggregation tab that contains the underlying data. Malia said the methodology follows guidance from the National Center on Educational Outcomes.

USBE asked data managers to assist special education directors by checking local calculations, providing breakdowns of students who qualify for alternate assessment by disability type, and helping assemble documentation. Malia offered one-on-one follow-up for any LEA that needs support.

Next steps: LEAs listed in USBE notices should prepare and submit their justification letters to UPIPs by Jan. 5 and be ready to provide subgroup breakdowns and the state-requested projections; LEAs flagged for disproportionality must also prepare the root-cause analysis described in the UPIPs materials.

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