This report analyzes the validity issues that arise in the context of educational accountability systems. The report addresses validity from three interlocking perspectives. The first explores the theory of action underlying accountability provisions. It considers problems emerging from the distance between aspirations for accountability in educational reform and the actual strength of the research base supporting sets of policies and procedures. A second component of the analysis concentrates on the role of testing in accountability systems, as it defines the characteristics and potential of many systems. The discussion is grounded strongly in the Standards for Educational and Psychological Testing (American Educational Research Association, American Psychological Association, and the National Council on Measurement in Education; 1999). The third perspective results in suggestions about an approach to improve the validity of accountability systems. (Contains 30 references.) (Author/SLD)