We recommend that the Assistant Secretary for OESE ensures that SSA develops, finalizes, and implements written guidance and review procedures for staff involved in reviewing and approving alternate assessment waiver and waiver extension requests, to include Steps for SSA staff to verify assessment participation rates (even if this would need to occur after requests are approved) and actions to be taken if discrepancies are noted; expectations for how staff should document communication with States during the review process; expectations for how staff should document their review and analysis of requirements in the internal memo to clearly show how a State met or did not meet requirements, especially in areas where professional judgment is exercised; and clear guidance related to areas that may lend themselves to subjectivity, to include what constitutes substantial progress and what is an acceptable response to State assurances of LEA verifications.