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We developed and refined a model for measuring implementation fidelity for an instructionally embedded assessment system for students with significant cognitive disabilities. A logic model describing intended use of the assessments was used to identify indicators based on data currently available in our assessment system. We established criteria for sufficient implementation based what we consider minimum requirements for intended use of the system, and practices that we believe support strong implementation. We conducted exploratory analyses using the indicators to iteratively refine the logic model and criteria. This research demonstrates one way to evaluate components of an assessment’s theory of action by contributing evidence on the extent to which it is implemented as intended to provide all students opportunity to learn.