Pennsylvania 1.0 Percent Requirement Compliance Plan Update August 31, 2026

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 continues 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 BSE’s assessment webpage: ESSA 1.0 Percent Threshold Justification Requirements.

Part II: Pennsylvania Participation Data

At the time of this submission, the 2025-2026 reading and math assessment participation data remain preliminary. The science assessment completed a standards-setting process during the summer of 2026; therefore, science participation data are not yet available.

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. PA also assesses below the required 95% of all students and the students with disabilities subgroup. This data continues to be monitored closely. It is important to note that these overall percentages do not fully capture the progress being made. 

Table 1: State Participation in PASA DLM 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 in students enrolled to take the AA-AAAS. While there was an increase of students enrolled this year due to an overall increase of students with significant cognitive disabilities, the overall trend still represents a decrease from original numbers at the inception of Pennsylvania’s compliance actions in 2018-19. Pennsylvania will continue to monitor this trend percentage and raw count data.

Table 2 reflects ongoing statewide efforts to ensure appropriate identification and assessment participation, aligning with federal compliance expectations. PDE will continue to monitor annual enrollment trend data. 

Table 2: PASA DLM Enrollment Trends

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

PDE 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 2025-26 school year, 695 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 continues 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 2018-19 school year, the proportion of students with disabilities in the state has risen by over 3 percentage points, growing from 17.85% to 21.36% 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.

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 continues to simultaneously experience a decline in total school enrollment. The combination of fewer total students and more students receiving special education services has impacted the overall AA-AAAS participation rates.

In addition, several disability categories commonly associated with AA-AAAS participation have experienced notable growth. For example, the number of students identified with autism has risen significantly—an increase of 23,061 students since 2018-19. Likewise, the number of students with a primary disability of intellectual disability increased by 1,831 and multiple disabilities by 152. While not all students in these disability categories qualify for the AA-AAAS, a substantial portion of this population does, making this trend particularly important to monitor.

Table 3: Total Enrollment Decreases while Special Education Enrollment Increases

Grade Level Trends

PDE continues to monitor AA-AAAS participation by grade level to identify emerging patterns. The table below illustrates participation in the PASA DLM alternate assessment across grades, showing changes over a 3-year span.   

A notable increase was seen last year in grade 3 and this year in grades 3 and 4. This increase is commensurate with the growing number of newly qualified students for special education.

Table 4: AA-AAAS Participation by Grade

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

Below is a summary of actions implemented by BSE during the 2025-26 school year in accordance with the state’s 1.0 Percent Compliance Plan of Action.

Training and Resources

Each year, all LEAs receive training on 1% compliance requirements. The BSE conducts an annual "PASA Getting Ready" webinar, which provides an overview of the PASA Eligibility Criteria: Decision Making Companion Tool  and the 1% participation requirement for LEAs.

Also, Pennsylvania provides a state specific module added to the RTAT (Required Test Administrator Training) through DLM that focuses on PASA DLM eligibility and ensuring only the students with the most significant cognitive disabilities who meet all six of the state’s criteria participate in the PASA DLM. This online module is required to be completed by PASA Assessment Coordinators and test administrators.

To further support understanding, BSE also provides 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.

BSE provides ongoing training and technical assistance to a wide range of stakeholders—including school administrators, teachers, parents, students, and agency personnel—to support a clear understanding of state assessment participation requirements. These efforts emphasize that only students with the most significant cognitive disabilities who meet state eligibility criteria should participate in the AA-AAAS.

During the 2025–26 school year, training on PASA eligibility IEP team decision making was provided to the following stakeholder groups:

• APS (Approved Private School) Alliance
• AT (Assistive Technology) Consultant Network
• PA Fellowship – new Special Education Administrators
• PAIU (Pennsylvania Association of Intermediate Units)
• SEAP (Special Education Advisory Panel) – parents and agencies who support students with disabilities

To assist with the goal of increasing student participation rates in state assessment, PDE continually analyzes and updates the allowable accommodations for the general assessment to ensure students with disabilities are best able to participate.  The annual Guidelines for Selection and Use of Accommodations on State Assessments (PDF) outlines allowable accommodations on the general state assessments with definitions and directions on how to appropriately implement.  Notably, PDE offered guidance for the 2026 transition to online assessments on how students who may need a print version of the test can be accommodated.   

In addition to the training and technical assistance PDE/BSE provides to LEAs, the state also continues to engage in national opportunities for training and resources on state assessment participation for students with disabilities. 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. The information and resources from this training continue to be shared with LEAs.

PDE continues to be an active participant in the bi-weekly NCEO 1% Community of Practice calls, where states come together to share information and resources on 1% compliance and related alternate assessment topics.  PDE also participates in the CCSSO (Council of Chief State School Officers) with participants in multiple topic strands.  BSE sends a representative to the ASES (Assessment, Standards, and Education for Students with Disabilities) convenings which also cover 1% compliance and state assessment participation topics. The information and resources gained in both of these groups is helpful for the state to keep informed on the best practices in statewide assessments for students with disabilities.

Another way BSE provided assessment and instructional support to administrators and teachers this year is through the AA-AAS vendor, Dynamic Learning Maps platform for resources. PA specific resources regarding the 1% threshold and eligibility are linked here Pennsylvania Resource Library

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. Any LEA with a participation rate below 70% is placed on reimbursement status for Title funds in addition to the required action plan and a high-risk designation for monitoring purposes.

During the 2025-26 school year, four (4) LEAs fell below the 70% threshold based upon their 2024-25 participation data. All were charter schools, including a cyber charter school, which is the second largest LEA by enrollment in the state. In fact, of the forty-four (44) LEAs with a participation rate under 90%, forty-one (41) are charter schools. The Department continues to work with our General Assembly to structure charter reform so that a relatively small number of underperformers do not drastically skew statewide participation efforts.  

1% Threshold- Tiered System of Oversight and Monitoring

Pennsylvania continues to implement a 3-tiered system of oversight and monitoring to address 1% compliance with LEAs. . A summary of the tiered system of oversight and monitoring can be accessed at ESSA 1.0 Percent Threshold Justification Requirements.

PDE updated its system in 2025–26 to collect the required 1% justification submissions from all LEAs. This enhanced system created a more streamlined and efficient process for LEAs to submit the necessary information. Each LEA received a data dashboard displaying its most recent testing data, including both 1% and 95% participation rates. Plans for the upcoming school year will be to transition this process into the state’s Integrated Monitoring System (IMS), which is the system LEAs use for all other special education monitoring tasks.  Once the process moves to IMS, regional advisors will have direct access to their assigned LEA submissions, providing another layer of oversight and support for all three tiers.

The Pennsylvania Alternate System of Assessment (PASA) and the 1% Threshold Justification: Tiered System of LEA Oversight and Monitoring (PDF) outlines the questions that all LEAs exceeding the 1% threshold are required to submit to PDE annually.

In an effort to strengthen focus on LEAs that  exceed the 1% threshold, especially those with higher percentages, BSE recently updated the Intensive Needs LEA Review (PDF) form.  The updates to this process will require all tier 3 LEAs to engage their special education administrator, a building administrator, and at least one teacher in a data dialogue to determine patterns and anomalies that may exist with their current PASA participation rates.  The process uses the District Dialogue Guide: Addressing the Percentage of Students Participating in the Alternate Assessment (NCEO Tool #4) (PDF) as a guide to help school teams better understand their data.  They will also be required to develop a plan of action based on the data they review.

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. Pursuant to 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 2025-26 list can be accessed here: ESSA 1 0 Percent Threshold Justification Requirements.

Part IV: Goals from Previous Plan Met

Part V: Continued Goals

PDE/BSE continues to implement and enhance efforts to strengthen compliance with state assessment participation requirements. For the 2026–27 school year, additional focus will be placed on the following initiatives:

• Transitioning the current three-tiered system of oversight and monitoring to the Integrated Monitoring System (IMS). This transition will streamline processes for LEAs and provide regional advisors with more direct access, increasing the number of state-level personnel who monitor and provide feedback across all three tiers.
• Implementing the updated Intensive Needs Review (INR) requirement for Tier 3 LEAs beginning in the 2026–27 school year. All Tier 3 LEAs will be required to submit the new INR in addition to completing the mandated student IEP file reviews.