Pennsylvania 1.0 Percent Requirement Compliance Plan Update - August 2025

Part I: Introduction

Since 2019, PDE has implemented a comprehensive plan to address 1% participation compliance. However, certain unique challenges have prevented the state from qualifying for a 1% waiver. Specifically, Pennsylvania has not met the federally required 95% participation rate for students with disabilities, a prerequisite for waiver eligibility. As a result, the state has been unable to apply for the 1% waiver since its introduction.

As outlined in the most recent compliance action plans submitted to the U.S. Department of Education (USDE), Pennsylvania has intensified its efforts to improve overall participation in statewide assessments for all students, including those with disabilities. Additionally, the state continues to focus on ensuring that only students with the most significant cognitive disabilities are assessed through the alternate assessment, in alignment with federal requirements. The original compliance action plan, along with all subsequent updates—including this current plan—can be found on the Bureau of Special Education’s (BSE) assessment webpage: ESSA 1.0 Percent Threshold Justification Requirements.

Part II: Pennsylvania Participation Data

At the time of this submission, 2025 testing data is preliminary.  

As outlined in the table below, Pennsylvania continues to exceed the 1.0 percent threshold for students who participate in the Pennsylvania Alternate System of Assessment through Dynamic Learning Maps (PASA DLM), the state’s AA-AAAS. The 2024–25 AA-AAAS participation data indicates that participation rates in ELA and math remained consistent with the previous year, while Science showed an improvement. Overall student participation increased marginally in ELA and math but decreased in science. For students with disabilities, participation rates declined across both the general and alternate assessments for all tested subjects compared to the prior year.

It is important to note that these overall percentages do not fully capture the progress being made, as enrollment patterns and other contributing factors continue to influence the data.

Table 1: State Participation in PASA by Content Area

*(SWD) – students with disabilities

Enrollment Trends

Overall, PASA DLM enrollment has shown a steady and meaningful decline over time. Since the implementation of Pennsylvania’s 1% compliance actions, there has been a significant reduction—more than 4,000 fewer students are now enrolled to take the AA-AAAS compared to the 2018–19 school year while the trend line for total students with disabilities in Pennsylvania continues to increase.

As shown in Table 2, enrollment in the AA-AAAS dropped from 21,707 students in 2018–19 to 17,503 in 2024–25, despite an increase in the identification of students with disabilities across the state during this time. This reflects ongoing statewide efforts to ensure appropriate identification and assessment participation, aligning with federal compliance expectations.

Table 2: PASA DLM Enrollment

Exit Analysis of AA-AAAS Enrollment: 'No Longer Qualifies'

BSE regularly analyzes data on students who are exited from the AA-AAAS enrollment system under the exit code “no longer qualifies.” This designation is used when an IEP team reconvenes to reassess a student’s eligibility for the PASA DLM, often as a result of updated training, guidance, or file review guidance.

In the 2024–25 school year, 798 students were exited from the PASA DLM enrollment system for this reason, reflecting increased alignment with eligibility criteria and the impact of ongoing oversight, training, and technical assistance provided to local education agencies (LEAs).

Contextual Trends in AA-AAAS Participation Rates

While data indicate that Pennsylvania is successfully transitioning students from the alternate assessment to the general assessment system, other concurrent trends continue to influence the state’s overall participation rate in the AA-AAAS.

Notably, Pennsylvania has experienced a steady increase in the percentage of students identified with disabilities. Since the 2013–14 school year, the proportion of students with disabilities in the state has risen by nearly 5 percentage points, growing from 15.4% to 20.1% by 2023–24, as shown in Table 3 below.

This upward trend in special education identification contributes to the overall increase in students eligible for alternate assessments, even as targeted efforts have reduced inappropriate AA-AAAS participation.

Table 3: PA Percentage of Students with Disabilities

Shifting Enrollment Trends and Their Impact on AA-AAAS Participation Rates

Although Pennsylvania has made progress in appropriately making  eligibility determinations for the AA-AAAS, broader demographic and enrollment trends continue to influence the overall participation rate.

While the percentage of students with disabilities continues to rise, the state is simultaneously experiencing a decline in total school enrollment. The combination of fewer total students and more students receiving special education services has moderated the anticipated decrease in AA-AAAS participation rates.

In addition, certain disability categories, such as Autism and Intellectual Disability, are increasing at a faster rate than others. Multiple Disabilities is also seeing a slight increase. Although Pennsylvania does not directly link disability category to AA-AAAS eligibility, it is reasonable to infer that growth in these specific categories may contribute to a higher number of students appropriately meeting criteria for participation in the alternate assessment. 

Table 4: Total Enrollment Decreases while Special Education Enrollment Increases

Grade Level Trends

BSE continues to monitor AA-AAAS participation by grade level to identify emerging patterns. In the 2024–25 school year, Grade 3 stood out with a notable increase in participation compared to the previous yearwhile all other grades experienced a decline compared to the previous year.

This increase in third grade participation aligns with statewide special education identification trends. Specifically, Grade 3 saw a 9.3% increase in students identified for special education between 2024 and 2025, and an 8.9% increase from 2022 to 2023. These trends suggest that the rise in AA-AAAS participation at this grade level is directly tied to the growing number of students newly qualifying for special education services.

The table below illustrates enrollment in the PASA DLM alternate assessment across grades, showing changes from year to year. The increase of 292 students in Grade 3 in 2024–25 is a significant outlier, especially when compared to consistent declines across other grade levels. BSE will place increased emphasis on students currently in or transitioning to third grade to support IEP teams in making appropriate PASA eligibility determinations.

Table 5: PASA DLM Enrollment by Grade

* change from previous year

Part III: Summary of Actions to Address Statewide Assessment Participation Compliance

Below is a summary of actions implemented by BSE during the 2024-25 school year in accordance with the state’s 1.0 Percent Compliance Plan of Action.

Intensive Training and File Reviews: In 2024–25, PDE collaborated with the U.S. Department of Education, the Office of Special Education Programs (OSEP), and the National Center on Educational Outcomes (NCEO) to design and implement a comprehensive training plan for LEAs identified as Tier 3 under the state’s 1% participation oversight and monitoring framework.

As part of this initiative, NCEO conducted two in-person training sessions across Pennsylvania in September 2024. A total of 47 LEAs were required by BSE to participate. Each LEA was mandated to send both a district-level assessment coordinator and a building administrator, resulting in 94 participants statewide.

The training was designed to foster data literacy and strategic planning. Specifically, participants were guided in analyzing their  assessment participation data and developing actionable plans to address both the 1% participation cap for alternate assessments and the 95% general assessment participation requirement.

In addition to the training, the 47 LEAs also underwent file reviews conducted by BSE staff.  These reviews evaluated whether there was evidence the IEP team reviewed the PASA Eligibility Criteria IEP Team Companion Tool (PDF) and documented data supporting how the student met all of Pennsylvania’s eligibility criteria to participate in the alternate assessment. In cases where documentation was found to be insufficient, BSE required IEP teams to reconvene and re-examine the assessment decision, ensuring all eligibility criteria were appropriately reviewed and documented.

Training and Resources for All LEAs

Each year, all LEAs receive training on 1% compliance requirements. The BSE conducts an annual "PASA Getting Ready" webinar, which provides an overview of PASA DLM eligibility criteria and the 1% participation requirement for LEAs.

Also, Pennsylvania provided a state specific module to be added to the RTAT (Required Test Administrator Training) through DLM entitled, “PASA DLM: Who Are the Students that Qualify?”. This online module was required to be completed by all PASA DLM assessment coordinators and assessors in 2024-25.

To further support understanding, BSE also released a concise training video focused on PASA eligibility considerations for IEP teams. This training is intended for all team members, including educators and parents—to ensure clear, data driven understanding of how to appropriately identify students as eligible for PASA. This training, along with additional resources on standards-aligned instruction and parent/family engagement, are available on the BSE Assessment webpage.

Another way BSE provided assessment and instructional support to administrators and teachers this year was through the use of two shareable, technology platforms known as Padlets. The PA DLM Instruction and Assessment Resources Padlet offers a comprehensive collection of instructional materials and detailed guidance on test administration procedures. Meanwhile, the  PA DLM Data Management for Assessment Coordinators (AC) Padlet outlines the essential steps PASA Assessment Coordinators must follow to accurately enroll and roster students for the PASA DLM. This process is critical to ensuring that all students are appropriately included in the state’s final accountability reporting.

In partnership with PaTTAN (Pennsylvania Training and Technical Assistance Network), BSE launched a new instructional training initiative titled "Building Capacity and Promoting Instruction through PASA DLM." This training is designed for teachers and administrators who work with students eligible for the AA-AAAS. This year, nearly 5,000 educators completed the training through their local Intermediate Units (IUs). Early outcomes are encouraging—survey data from participating teachers indicate a strengthened understanding of how to effectively instruct students who take the AA-AAAS. While the training does not specifically address AA-AAAS eligibility criteria or 1% compliance, its focused on ensuring educators understand the academic content for this targeted group of students. As a result, educators have an increased understanding of providing accessible instruction which can result in improved student outcomes. Improved performance may support the transition of students from the AA-AAAS to the general assessment in future years.

95 Percent Participation for Students with Disabilities: PDE recognizes the importance of the 95 percent participation requirement for all students, including students with disabilities, to participate in statewide assessment.

Pennsylvania's Consolidated State Plan stipulates schools with participation rates below 95 percent are required to develop and implement state approved compliance plans. LEAs with statewide assessment participation rates below 95 percent are required to submit an action plan to PDE.

 Additionally, beginning August 30, 2024, the three (3) LEAs with an all-student participation rate less than 70 percent began receiving Title I-A and Title I-A School Improvement funds on a reimbursement basis. 

1% Threshold- Tiered System of Oversight and Monitoring

A summary of the tiered system of oversight and monitoring can be accessed at ESSA 1.0 Percent Threshold Justification Requirements.

In 2024–25, BSE revised the criteria for identifying Tier 2 and Tier 3 LEAs to expand access to more intensive supports. The threshold for Tier 2 identification was lowered from 2% to over 1%. Tier 1 LEAs are still required to provide a basic assurance to BSE that they do not plan to exceed the threshold, while Tier 2 and Tier 3 LEAs must submit justification for exceeding the threshold.

Historically, Tier 3 LEAs were identified if they tested more than 4% of students in the previous testing cycle. For the 2024-25 school year, the threshold was lowered to 3.3% or higher in order to reach more LEAs with this intensive level of support. LEAs meeting this criterion were required to participate in the intensive in-person training with NCEO and the file review process described above.

Public Posting of 1% Justifications

BSE continues to require all LEAs to submit justification to the state if they exceed the 1% threshold by any amount. In accordance with 34 CFR §200.6(c)(3), a list of LEAs anticipating they will exceed the threshold is publicly posted on the PDE website. LEAs must also make this information publicly available at the local level, while ensuring no personally identifiable student information is disclosed. The 2024–25 list can be accessed here: ESSA 1 0 Percent Threshold Justification Requirements.

Part IV: Goals from Previous Plan Met

Part V: Continued Goals

As outlined above, PDE has met or exceeded the goals established in the previous plan to improve compliance with statewide assessment participation requirements. The mission moving forward remains twofold:

1. To ensure all students, including those with disabilities, participate in state assessments, and
2. To ensure students with disabilities are administered the appropriate assessment based on data-driven decisions made by IEP teams.

To support this mission, the following efforts will continue or be enhanced:

• Ongoing Data Monitoring: BSE will continue to analyze and monitor AA-AAAS enrollment and participation data to identify emerging trends and target areas requiring additional support.
• Three-Tiered Oversight and Monitoring System: The structured, tiered oversight model to address 1% participation compliance will remain in place, with continued intensified supports provided to LEAs identified in Tier 3.
• Participation Rate Monitoring: PDE/BSE will maintain close monitoring of the federally required 95% participation rate, with continued actions required of LEAs that do not meet this requirement.
• Transition to Online Assessments: The full transition to online general assessments will take place in Spring 2026 Additional training and resources will be provided to support students requiring accommodations.
• Ongoing Collaboration: PDE/BSE will continue to work closely with the U.S. Department of Education (USDE), the Office of Special Education Programs (OSEP), and the National Center on Educational Outcomes (NCEO) to ensure alignment with federal participation requirements and to access guidance and technical support for continued progress toward full compliance.