EVERY STUDENT 

SUCCEEDS ACT

Early Observations on 

State Changes to 

Accountability 

Systems

Report to Congressional Requesters

July 2017

GAO-17-660

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-660, a report to 

congressional requesters.

July 2017

EVERY STUDENT SUCCEEDS ACT

Early Observations on State Changes to 

Accountability Systems

What GAO Found

According to most of the nine education stakeholder groups GAO interviewed

and officials in the two states GAO visited, the Every Student Succeeds Act 

(ESSA) strikes a good balance between flexibility to meet state needs and ESSA 

requirements. Accountability systems measure student and school performance 

to identify and assist low-performers. States are currently developing plans for 

accountability systems under ESSA. According to stakeholders, some states are 

using ESSA’s flexibilities to significantly change their accountability systems 

while others are making more limited changes. Changes stakeholders discussed 

pertained mostly to four key components (see figure). GAO visited California and 

Ohio and these two states reported using ESSA’s flexibilities to distinguish 

between levels of school performance, among other things. For example, Ohio 

plans to assign letter grades to schools on each of six performance indicators. 

Under Ohio’s proposal, schools will also receive overall letter grades beginning 

in 2018. California plans to distinguish performance with grades for performance 

on each of six state indicators. Their proposed system will not provide overall 

scores for schools. California officials said reporting on individual indicators will 

allow them to show key distinctions in performance that an overall score could 

mask.

Four Key Components of Accountability Systems Under the Every Student Succeeds Act

Note: This figure is intended to provide a high-level summary of selected components of state accountability 

systems as required by ESSA. For additional information on these components, see 20 U.S.C. § 6311(c) and (d). 

ESSA’s provisions related to state accountability systems do not become effective until school year 2017-2018.

Education officials said next steps in implementing ESSA are the review and 

approval of ESSA-required state plans, and to continue to provide technical 

assistance to states. Officials also said that they are developing monitoring 

protocols for in-depth reviews of states’ ESSA-related activities and will pilot 

them in early 2018. ESSA also includes certain reporting and review 

requirements, for example, (1) annual state reports to Education on student and 

school performance; (2) annual Education reports to Congress on state reported 

data; and (3) approval by the Secretary of Education of significant changes to 

state plans. 

View GAO-17-660. For more information, 

contact Jacqueline Nowicki at (617) 788-0580

or nowickij@gao.gov.

Why GAO Did This Study

Federal, state, and local governments 

spent about $640 billion in 2015 to 

educate nearly 50 million public school 

children in the United States. ESSA, 

enacted in December 2015, 

reauthorized the Elementary and 

Secondary Education Act of 1965. To 

receive federal education funds for

school districts with high 

concentrations of students from lowincome families, ESSA requires states 

to have accountability systems that 

meet certain requirements, but gives 

states flexibility in how they design 

their systems. 

GAO was asked to review states’ early 

experiences with ESSA. This report 

examines (1) selected stakeholders’ 

and states’ views of ESSA’s flexibilities 

as states redesign accountability 

systems, and (2) Education’s next 

steps in implementing ESSA.

GAO interviewed representatives of 

nine prominent national education 

stakeholder groups, selected for their

knowledge about state accountability 

systems; met with education officials in

California and Ohio—states that were 

among those stakeholders cited as

offering differing approaches to 

developing their systems; interviewed 

Department of Education officials; 

reviewed relevant federal laws and 

guidance; and reviewed accountability 

system guidance from California and 

Ohio and these states’ draft state 

plans.

GAO is not making recommendations 

in this report. The Department of 

Education provided technical 

comments on a draft of this report, 

which we incorporated as appropriate.
Page i GAO-17-660 Every Student Succeeds Act

Letter 1

Background 3

Stakeholders and Selected States View ESSA’s Accountability 

Provisions as Flexible 5

Developing and Implementing State Monitoring Plans Is a Key 

Next Step for Education in ESSA Implementation 12

Agency Comments and Our Evaluation 15

Appendix I National and State Stakeholder Groups With 

Whom GAO Spoke 16

Appendix II GAO Contact and Staff Acknowledgments 17

Figure

Figure 1: Four Key Components of Accountability Systems Under 

the Every Student Succeeds Act (ESSA) 3

Contents
Page ii GAO-17-660 Every Student Succeeds Act

Abbreviations

ESSA Every Student Succeeds Act

Education U.S. Department of Education

NCLBA No Child Left Behind Act of 2001

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Page 1 GAO-17-660 Every Student Succeeds Act

441 G St. N.W.

Washington, DC 20548

July 13, 2017

The Honorable Virginia Foxx

Chairwoman

Committee on Education and the Workforce

House of Representatives

The Honorable Todd Rokita

Chairman

Subcommittee on Early Childhood, Elementary, and Secondary 

Education

Committee on Education and the Workforce

House of Representatives

Federal, state, and local governments spent about $640 billion in 2015 to 

educate nearly 50 million public school children in the United States. 

Ensuring that all students have access to a high quality education is a 

widely shared goal. Accountability systems help foster this goal by 

measuring student and school performance and providing information on 

that performance to key stakeholders—parents, teachers, government 

officials, and taxpayers. The Every Student Succeeds Act (ESSA) 

requires all states to have accountability systems that meet certain 

requirements, but gives states flexibility in how they design their 

systems.1 In general, ESSA requires states to measure the performance 

of their schools and use those measures to identify underperforming 

schools and student subgroups for additional assistance.

 1

ESSA, enacted on December 10, 2015, reauthorized the Elementary and Secondary 

Education Act of 1965 (ESEA). Pub. L. No. 89-10, 79 Stat. 27 (1965), as amended by 

Pub. L. No. 114-95, 129 Stat. 1802 (2015). The previous reauthorization of ESEA was the 

No Child Left Behind Act of 2001 (NCLBA). Pub. L. No. 107-110, 115 Stat. 1425 (2002). 

States are required to have accountability systems, in addition to complying with various 

other requirements, as a condition of receiving federal funds authorized under Title I, Part 

A of ESEA (Title I). Title I provides formula grants to states for their school districts to 

improve educational programs in schools with high concentrations of students from lowincome families. See 20 U.S.C. § 6311 et seq. Accountability systems were also required 

under NCLBA. ESSA’s provisions regarding accountability systems generally take effect 

beginning with school year 2017-2018. Pub. L. No. 114-95, § 5(e)(1)(B), 129 Stat. 1802, 

1806-07. Under the Consolidated Appropriations Act, 2016, the ESEA noncompetitive 

formula grant programs, including Title I, are to be administered in accordance with 

NCLBA for academic year 2016-2017. Pub. L. No. 114-113, § 312, 129 Stat. 2242, 2638 

(2015).

Letter
Page 2 GAO-17-660 Every Student Succeeds Act

You asked us to report on states’ early efforts implementing ESSA. This 

report focuses on (1) selected stakeholders’ and states’ views of ESSA’s 

flexibilities as states redesign their accountability systems, and (2) U.S. 

Department of Education’s (Education) next steps in implementing ESSA.

For this work, we interviewed representatives of nine prominent national 

education stakeholder groups knowledgeable about accountability 

systems, six of which worked directly with states as they revised their 

accountability systems in response to ESSA. We also visited state 

educational agencies, school districts, and a total of four state 

stakeholder groups in California and Ohio. (See appendix I for a list of the 

national and state stakeholder groups with whom we met.) We selected 

California and Ohio because they were among the states that national 

stakeholder groups cited as being illustrative of different state approaches 

to developing their proposed accountability systems. In each state, we 

visited three school districts that had schools in each grade span—

elementary, middle, and high schools—and varied in size and geographic 

location. These states provide illustrative examples of how two states are 

revising their accountability systems in response to ESSA, and are not 

generalizable to the 50 states. We also interviewed Education officials,

and reviewed relevant federal laws and Education guidance pertaining to 

ESSA accountability provisions. Lastly, we reviewed accountability 

system guidance from California and Ohio as well as relevant portions of 

their draft state plans which describe how they will comply with ESSA 

accountability requirements.2

In this report, we focused on four components of state accountability 

systems under ESSA that we identified during our early interviews with 

stakeholder groups as being key components of these systems, and as 

areas in which states are making changes to their systems.3 We refer to 

these four components as: (1) determine long-term goals, (2) develop 

 2

For Ohio’s draft state plan see https://education.ohio.gov/Topics/Every-StudentSucceeds-Act-ESSA and for California’s see 

http://www.cde.ca.gov/re/es/draftplantoolkit.asp. 

3

In addition, other provisions in ESSA related to state accountability systems include a 

requirement that states provide assurance that they have adopted challenging academic 

content and aligned achievement standards in at minimum, mathematics, reading or 

language arts, and science; and a requirement that states implement a set of high-quality 

student academic assessments in these subjects, which are to be administered in each of 

grades 3 through 8 and at least once in grades 9 through 12 for math and reading or 

language arts, and at least once in grades 3 through 5, once in grades 6 through 9, and 

once in grades 10 through 12 for science. See 20 U.S.C. § 6311(b).
Page 3 GAO-17-660 Every Student Succeeds Act

performance indicators, (3) differentiate schools (referred to in this report 

as distinguishing between levels of school performance), and (4) identify 

and assist low-performers.4

We conducted this performance audit from December 2016 to July 2017 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

State accountability systems under ESSA include four key components: 

1) determine long-term goals, 2) develop performance indicators, 3) 

differentiate schools, and 4) identify and assist low-performers (see fig. 

1).

Figure 1: Four Key Components of Accountability Systems Under the Every Student Succeeds Act (ESSA)

Note: This figure is intended to provide a high-level summary of selected components of state 

accountability systems as required by ESSA. For additional information on these components, see 20 

U.S.C. § 6311(c) and (d). ESSA’s provisions related to state accountability systems do not become 

effective until school year 2017-2018.

a

Student subgroups include economically disadvantaged students, students from major racial ethnic 

groups, children with disabilities, and English learners.

 4

For the specific ESSA requirements related to these components, see 20 U.S.C. § 

6311(c) and (d). 

Background
Page 4 GAO-17-660 Every Student Succeeds Act

ESSA requires states to submit state plans to the Secretary of Education 

to receive Title I funds. These funds support schools and districts with 

high concentrations of students from low-income families. ESSA requires 

that states develop these plans with “timely and meaningful consultation”

with a variety of stakeholders, and also coordinate the plans with certain 

other federal programs.

5 Education has developed a state plan template 

that states can use when formulating their consolidated state plans and 

procedures for submitting these plans.6 ESSA requires that state plans be 

peer reviewed and that the Secretary of Education approve them if they 

meet the requirements in the law.7

As of May 2017, 16 states and the District of Columbia had submitted 

their plans to Education for review; the remaining plans are due by 

 5

20 U.S.C. § 6311(a)(1). Specifically, ESSA requires the state educational agency 

responsible for developing the state plan to consult with “the Governor, members of the 

State legislature and State board of education (if the State has a State board of 

education), local educational agencies (including those located in rural areas), 

representatives of Indian tribes located in the State, teachers, principals, other school 

leaders, charter school leaders (if the State has charter schools), specialized instructional 

support personnel, paraprofessionals, administrators, other staff, and parents.” ESSA also 

requires that state plans be coordinated with other programs under ESSA, the Individuals 

with Disabilities Education Act, the Head Start Act, and the McKinney-Vento Homeless 

Assistance Act, among others. Each state is also required to make the state plan publicly 

available for public comment for a period of not less than 30 days, prior to submission to 

the Secretary of Education for approval. 20 U.S.C. § 6311(a)(8).

6

States may submit consolidated plans that address multiple ESSA programs in addition 

to Title I. ESSA requires the Secretary of Education to establish procedures and criteria 

for submitting consolidated state plans and establish the information, assurances, and 

other material required to be included in them. In establishing these criteria, procedures, 

and other requirements, Education “shall collaborate with State educational agencies and, 

as appropriate, with other State agencies, local educational agencies, public and private 

agencies, organizations, and institutions, private schools, and representatives of parents, 

students, and teachers” and require only descriptions, information, assurances, and other 

materials “that are absolutely necessary for the consideration of” the consolidated state 

plan. 20 U.S.C. § 7842.

7

20 U.S.C. § 6311(a)(4). Only those portions of a state’s consolidated state plan that 

relate to ESSA Title I, Part A, ESSA Title III, Part A, and the McKinney-Vento Homeless 

Assistance Act, Title VII, Subpart B are required to be peer reviewed.
Page 5 GAO-17-660 Every Student Succeeds Act

September 18, 2017, according to Education’s guidance.8 Both states we 

visited as part of our review intend to submit their plans by the September 

deadline.

Representatives of all nine national stakeholder groups we spoke with 

saw ESSA’s accountability provisions as somewhat flexible, with most 

indicating that ESSA strikes a good balance between flexibility and 

requirements.9 One stakeholder said, for example, that ESSA “threads 

the needle very well” between giving states flexibility in designing their 

accountability systems and placing requirements on states to help ensure 

that all children have an opportunity to get a good education. Most 

stakeholders also mentioned ESSA provisions related to developing 

performance indicators as an example of flexibility. One stakeholder, for 

example, saw, these provisions as flexible because they allow states to 

define the exact indicators they will use, including indicators that measure 

student growth in addition to student proficiency when assessing 

academic performance.

 8

In November 2016, Education issued a final rule implementing the accountability and 

state plan portions of ESSA, among other things. Elementary and Secondary Education 

Act of 1965, as Amended by the Every Student Succeeds Act—Accountability and State 

Plans, 81 Fed. Reg. 86,076 (Nov. 29, 2016). At the same time, Education also issued 

guidance for states, including a consolidated state plan template. In accordance with a 

January 20, 2017 memorandum from the Assistant to the President and Chief of Staff, 

titled “Regulatory Freeze Pending Review,” published in the Federal Register on January 

24, 2017, Education delayed the effective date of the final rule until March 21, 2017. 82 

Fed. Reg. 8669 (Jan. 30, 2017). On March 9, 2017, Congress passed a joint resolution of 

disapproval with respect to the final rule, pursuant to procedures set forth in the 

Congressional Review Act. Education released a revised template for consolidated state 

plans on March 13, 2017. On March 27, 2017, the President signed the joint resolution of 

disapproval, invalidating the final rule. Pub. L. No. 115-13, 131 Stat. 77 (2017).

9

Throughout this report, we use “most national stakeholder groups” to describe comments 

made by representatives of 5 to 8 of the 9 stakeholder groups with whom we spoke. 

Stakeholders and 

Selected States View 

ESSA’s Accountability 

Provisions as Flexible

Stakeholders See ESSA 

as Flexible and Said Some 

States Are Making More 

Changes to Their 

Accountability Systems 

Than Others
Page 6 GAO-17-660 Every Student Succeeds Act

Representatives of four national stakeholder groups that have worked 

directly with states to help them develop and revise their accountability 

systems told us that the extent to which states are revising their 

accountability systems varies because some states are satisfied with their 

current systems and others are using the flexibilities in the law to make 

significant overhauls. According to representatives of one stakeholder

group, for example, many states already began revising their 

accountability systems as a result of waivers Education granted under the 

previous reauthorization, the No Child Left Behind Act of 2001 (NCLBA).10

They further said that ESSA is generally flexible enough for states to 

continue down the path they started in implementing their NCLBA 

waivers. In addition, representatives of several stakeholder groups 

mentioned that for states that see their current accountability systems as 

lacking in some way, or because consultation with state stakeholders has 

pointed to the need for significant change, ESSA provides room for them 

to consider innovative revisions.11

 10In September 2011, in response to states’ requests for relief from certain provisions 

contained in the NCLBA, Education invited states to request waivers that would grant 

them flexibility in meeting certain requirements in the law in effect at that time. As part of 

this “ESEA flexibility” initiative, states agreed to address certain principles identified by 

Education, including, among other things, district and school recognition, accountability, 

and support systems. In response, almost every state applied for ESEA flexibility and 

Education ultimately approved waivers for 43 states, including Ohio, and the District of 

Columbia and Puerto Rico. Under ESSA, all waivers granted through the ESEA flexibility 

initiative terminated on August 1, 2016. Pub. L. No. 114-95, § 4(c), 129 Stat. 1802, 1806. 

For the purposes of this report, we refer to these waivers as “NCLBA waivers.” For more 

information on these waivers, see K-12 Education: Education’s Experiences with Flexibility 

Waivers Could Inform Efforts to Assist States with New Requirements, GAO-16-650

(Washington, D.C.: July 7, 2016).

11By several, we mean representatives of 3 or 4 of the 9 national stakeholder groups with 

whom we spoke.
Page 7 GAO-17-660 Every Student Succeeds Act

Ohio and California, the two states we visited, illustrate how different 

states are using the flexibilities in ESSA to develop accountability 

systems that are tailored to meet state needs as well as ESSA 

requirements for each of the four key components of state accountability 

systems: determine long-term goals, develop performance indicators, 

differentiate schools, and identify and assist low performers.12 (See 

sidebars for summaries of ESSA requirements for these components.)

 12In this report we describe proposals for state plans as described to us by officials or in 

the draft plans themselves. GAO does not have a role in determining whether state plans 

meet the requirements under ESSA. 

Ohio’s and California’s 

Approaches to 

Incorporating ESSA 

Provisions into Their 

Accountability Systems
Page 8 GAO-17-660 Every Student Succeeds Act

Determine Long-Term Goals

Ohio officials told us that they chose a 10-year timeline for meeting their 

long-term goals to help address stakeholder concerns about providing 

schools and districts sufficient time to meet the new goals. For example, 

one of Ohio’s proposed goals is that at least 80 percent of students score 

proficient or higher on Ohio’s statewide assessments in English 

Language Arts and math within 10 years. Meeting this goal may be easier 

for some schools and groups of students than others, as some are further 

away from the goal than others. To close this “achievement gap,” the 

state plans to set its proficiency goals for each student subgroup such 

that those groups furthest behind will be expected to make greater annual 

gains in an effort to catch up over the 10-year period.

13 Further, in an 

effort to make the 10-year long-term goals achievable for lowerperforming groups, the state’s draft plan proposes to set the 10-year 

proficiency goals for them lower than the 10-year goals for higherperforming subgroups. Ohio state officials and stakeholders told us that 

some stakeholders were concerned about having different goals for 

different subgroups: Some find the annual or long-term goals for low 

performing subgroups too ambitious and others find it problematic that 

certain students would be held to different standards than others. State 

officials said to meet the ESSA requirement of having ambitious long-term 

goals, they designed their approach to significantly close the achievement 

gap over 10 years. At the time of our work, Ohio was still working on its 

final approach to address this issue.

According to California’s draft plan, California plans to achieve its goals 

within 5 to 7 years—a timeframe that coincides with regularly scheduled 

reviews of the performance indicators used in its accountability system. 

Unlike Ohio, California is proposing that schools and districts propose 

their own interim goals to close achievement gaps and that the same 

timeline for long-term goals (5 to 7 years) apply to all student subgroups.

State officials mentioned that district interim goals must take into account 

the current performance of student subgroups and how far this 

performance is from the state’s long-term goals.

 13Achievement gaps occur when one group of students consistently performs better 

academically than another group. Achievement gaps can exist, for example, between 

white students and other racial minority groups or between students from higher-income 

and lower-income households. 

Highlights of Selected ESSA 

Requirements: Long-Term Goals

ESSA requires states to design and establish 

ambitious long-term goals, including 

measurements of interim progress toward 

meeting them. For example, states are to set 

goals for all students, and separately for each 

subgroup of students, for improved academic 

achievement and high school graduation 

rates, among other things.

Student subgroups include economically 

disadvantaged students, students from major 

racial and ethnic groups, children with 

disabilities, and English learners.

Source: See 20 U.S.C. § 6311(c)(4)(A).
Page 9 GAO-17-660 Every Student Succeeds Act

Develop Performance Indicators

Ohio officials told us that they plan to use their current indicators as the 

foundation for meeting ESSA’s requirements for academic indicators, and 

make some revisions or refinements as needed. With regard to ESSA’s 

required indicator of school quality or student success, state officials said 

they plan to include chronic absenteeism because studies show that 

school attendance is strongly correlated with successful student 

performance. Because the state already collects attendance data, the 

indicator also reduces the need for additional data collection. Ohio

officials and stakeholders said that ESSA has prompted many substantive 

conversations about what to use for the school quality or student success 

indicator. For example, Ohio stakeholders and a school district official told 

us that they have concerns about using chronic absenteeism as a 

measure because schools and districts cannot control whether students 

come to school and that other indicators might be beneficial measures. 

State officials mentioned that in response to these concerns, Ohio’s draft 

plan now includes a commitment to pilot a school climate survey for 

potential inclusion as an indicator of school quality or student success in 

future years.

Although California’s draft plan proposes using its existing indicators to 

meet ESSA’s requirements for academic indicators, the state also plans 

to develop some new ones. For example, as an additional academic 

indicator, the state proposes to use chronic absenteeism. According to its 

draft plan, there is a strong correlation between strong academic 

performance and school attendance. For the school quality or student 

success indicator, California chose suspensions, with high rates 

indicating poor quality and failure, and low rates indicating success. State 

officials said that ESSA flexibilities allowed them to differentiate what was 

considered high and low rates of suspension by grade level (i.e., 

elementary, middle, and high school). They explained that this is 

important because it allows them to tailor the indicator for each level.

Highlights of Selected ESSA 

Requirements: Indicators

States are required to annually measure, for 

all students and for student subgroups, four 

“academic” indicators. These indicators 

include academic achievement for all public 

schools, as measured by proficiency on the 

annual state assessments, and the four-year 

adjusted cohort graduation rate for public high 

schools, among other things.

In addition, states are also required to have, 

for all public schools, at least one statewide 

indicator of school quality or student success 

that meets certain criteria. This indicator may 

include measures of student and educator 

engagement, student access to and 

completion of advanced coursework, 

postsecondary readiness, school climate and 

safety, or any other indicator the state 

chooses that meets the requirements in the 

law.

Source: See 20 U.S.C. § 6311(c)(4)(B).
Page 10 GAO-17-660 Every Student Succeeds Act

Differentiate Schools (distinguishing between levels of performance) 

Ohio officials told us that they propose to continue to use the state’s 

current system of six indicators, with modifications, to assess school and 

student performance. Under the proposal, schools would receive a letter 

grade on each indicator. Some of the indicators, such as academic 

achievement, would measure current performance while other indicators, 

such as academic progress, would measure growth. Ohio state officials 

told us that they also intend to roll up indicator scores into an overall letter 

grade for schools in 2018. They said that reporting a letter grade on each 

indicator provides detailed information, while an overall letter grade

provides an easily understandable overview of performance. Ohio 

stakeholders and school district officials expressed concerns about both 

the use of letter grades and rolling up grades on each indicator into an 

overall score. They explained that words, such as meets or exceeds 

expectations, could more accurately communicate performance than 

letter grades.

California officials said they plan to distinguish performance of schools 

and student subgroups by using a dashboard in which school and student 

subgroup performance would be color-coded based on each of six state 

indicators. These officials said that each indicator measures current 

student performance as well as changes in performance over time. Unlike 

Ohio, California does not plan to aggregate the indicators into overall 

scores for schools and student subgroups. California officials told us that 

they chose their approach for two reasons. First, aggregating scores on 

indicators into an overall score can mask individual areas where a school 

may be struggling. In contrast, reporting individual indicators allows key 

distinctions to be maintained in performance across a variety of factors. 

Second, officials said that measuring performance in both the current 

year and over time on each indicator provides a more complete picture of 

performance.

Highlights of Selected ESSA 

Requirements: Annual Meaningful 

Differentiation:

ESSA requires each state to establish a 

system of meaningfully differentiating all its 

public schools, on an annual basis. This 

system must, among other things:

• be based on all indicators in the state’s 

accountability system, including the four 

academic indicators, for all students and 

for each subgroup of students; and

• include differentiation of any school in 

which any subgroup of students is

determined by the state to be consistently 

under-performing.

Source: See 20 U.S.C. § 6311(c)(4)(C).
Page 11 GAO-17-660 Every Student Succeeds Act

Identify and Assist Low Performers

Ohio state officials told us that their processes for identifying low 

performing schools (known in Ohio as priority schools) and schools with 

underperforming subgroups (known in Ohio as focus schools) will be 

similar to the process they used under their NCLBA waiver and will 

include new indicators, such as chronic absenteeism as one indicator of 

school quality or student success.14 Furthermore, Ohio officials in one 

district discussed a requirement in ESSA that they believe will improve 

Ohio’s system of intervening in low-performing schools and subgroups—

that states establish criteria for how schools can exit certain ESSA 

improvement categories. As part of meeting this requirement, these 

officials said that Ohio is developing benchmarks for graduation rates and 

student growth indicators, which they said should make it clear to districts 

when they can release schools from improvement categories.

California’s draft state plan proposes to identify low-performing schools 

and student subgroups based on where they fall on its dashboard of 

color-coded performance indicators, and lists three options for how the 

state may do this. Regarding assisting low-performing schools and 

student subgroups, California state officials said they plan to give districts 

the authority to develop interventions. California officials in one district 

said that ESSA provides flexibility to reconsider how they provide school 

interventions. They said, for example, that they can now provide an 

intervention such as tutoring when they feel it will be most effective—

before, during, or after the school day—and that this was partly because 

of ESSA.

 14Ohio’s NCLBA waiver made changes to the state’s accountability system in part by 

introducing new goals (1) to reduce achievement gaps, and (2) increase the number of 

high school students who graduate and are college and career ready.

Highlights of Selected ESSA 

Requirements: School Identification for 

Comprehensive or Targeted Support and 

Improvement:

• Comprehensive support and 

improvement: Based on the system of 

meaningful differentiation, each state is to 

establish a methodology to periodically 

identify a statewide category of schools 

for comprehensive support and 

improvement. This category must include 

schools that meet certain criteria, such as 

the lowest-performing 5 percent of all 

schools in the state receiving Title I 

funding.

• Targeted support and improvement: In 

addition, states are to notify each school 

district about schools in which any 

subgroup of students is consistently 

underperforming, and ensure the district 

provides notification to these schools.

For each school identified, the school or 

district is to develop and implement, in 

partnership with stakeholders, either a 

comprehensive support and improvement 

plan or a targeted support and improvement 

plan, as applicable, to improve student 

outcomes. These plans must be informed by 

all state indicators and include evidencebased interventions.

States are to, among other things, establish 

statewide exit criteria for schools identified for 

comprehensive support and improvement and 

additional targeted support.

Source: See 20 U.S.C. § 6311(c)(4)(D), (d).
Page 12 GAO-17-660 Every Student Succeeds Act

Given current timelines, Education officials said that the department is 

currently focused on the review and approval process for state plans and 

providing assistance to states in developing their plans. Under ESSA, the 

Secretary of Education is responsible for establishing a peer-review 

process to assist in the review of state plans, and for approving state 

plans that meet the requirements of ESSA.15 Education officials told us 

that the peer reviewers will consider the technical, educational, and 

overall quality of specific portions of state plans when making their 

recommendations to the Secretary. According to guidance Education 

provided to peer reviewers, another goal is for reviewers to provide states 

with objective feedback on the technical, educational, and overall quality 

of their plans.

Education officials told us that they are developing monitoring protocols 

that they will pilot with eight or nine states in early 2018. These protocols 

are intended to guide in-depth reviews of state activities related to ESSA 

implementation. The officials noted that they are piloting the protocols to 

ensure that they have an appropriate monitoring tool to obtain information 

on how states are implementing ESSA requirements. Officials told us that 

Education used similar in-depth state reviews when developing past 

monitoring protocols, reviewing a select number of states each year with 

the goal of reviewing all states within a 3- to 4-year cycle. Given that 

some states have submitted their state plans earlier than others for 

approval, officials also noted that they will pilot the monitoring protocol in 

states that progressed enough to warrant monitoring. To complement the

in-depth monitoring, Education officials said they also plan to continue 

their past practice of maintaining regular contact with all states.

Education officials also told us they are determining whether there is a 

need for additional guidance to states on aspects of ESSA 

implementation. Education has provided assistance to states in a number 

of ways. For example, the department hosted webinars on the state plan 

template that states may choose to use, and on the peer review process. 

Education has also implemented a technical assistance initiative called 

the State Support Network to support state and district school 

 1520 U.S.C. § 6311(a)(4). Education is required to establish multi-disciplinary peer review 

teams that include, among other members, representatives of educators and researchers. 

Only those portions of a state’s consolidated state plan that relate to ESSA Title I, Part A, 

ESSA Title III, Part A, and the McKinney-Vento Homeless Assistance Act, Title VII, 

Subpart B are required to be peer reviewed. 

Developing and 

Implementing State 

Monitoring Plans Is a 

Key Next Step for 

Education in ESSA 

Implementation
Page 13 GAO-17-660 Every Student Succeeds Act

improvement efforts under ESSA. This network aims to connect states 

and districts with technical assistance providers and subject matter 

experts to develop strategies for supporting schools. According to the 

network’s website, it aims to help states and districts learn from prior 

school improvement efforts, assess needs and assets to inform 

strategies, and build sustainable systems to support continuous 

improvement.16 During our review, representatives of most national 

stakeholder groups with whom we spoke told us that states could use 

guidance on a number of issues. One example of guidance that they told 

us states might consider useful is identification of appropriate evidencebased interventions.17 As part of its ongoing assistance to states, 

Education has addressed this topic in a number of ways, including nonregulatory guidance, resources via the State Support Network, and case 

studies.18

 16See https://statesupportnetwork.ed.gov.

17GAO has reported that using data—such as information collected by performance 

measures and findings from program evaluations and research studies—to drive decision 

making can help improve program implementation, identify and correct problems, and 

make other management decisions. See http://www.gao.gov/key_issues/datadriven_decision_making/issue_summary#t=0. 

18See U.S. Department of Education, Non-regulatory Guidance: Using Evidence to 

Strengthen Education Investments, accessed June 26, 2017, 

https://www2.ed.gov/policy/elsec/leg/essa/guidanceuseseinvestment.pdf), State Support 

Network resources at https://statesupportnetwork.ed.gov/resources, and case studies and 

other materials related to evidence-based interventions at 

https://www2.ed.gov/about/offices/list/oese/oss/technicalassistance/index.html.
Page 14 GAO-17-660 Every Student Succeeds Act

ESSA requires states and Education to report annually on specific 

aspects of ESSA implementation and states to submit significant changes 

to their plans to Education for review (see sidebar for a summary of these 

requirements).

Under Education’s current reporting procedures, states submit 

information for each school year the following fall.19 Education officials 

said that they plan to continue this practice, so state submissions in fall 

2018 would be the first to include information based on ESSA 

requirements, i.e., for school year 2017-2018.

 19The Department of Education currently collects K-12 education performance data via the 

Consolidated State Performance Report. Data currently collected includes, among other 

items, information related to state activities and outcomes and information used to assess 

program performance and monitor program requirements. For more information see 

https://www2.ed.gov/admins/lead/account/consolidated/index.html.

Summary of Selected ESSA Reporting and 

Reviewing Requirements

• Annual state reports: ESSA requires 

states to submit annual reports to the 

Secretary of Education. These annual 

reports must include information on 

student achievement based on the annual 

state assessments, including 

disaggregated results for student 

subgroups. The reports must also include 

certain information on English learners, 

schools identified for support and 

improvement, and teacher qualifications, 

among other things. 

• Annual report to Congress: ESSA also 

requires the Secretary of Education to 

submit an annual report to specified 

congressional committees that provides 

both national and state-level data on the 

information collected from the states’ 

reports.

• Changes to state plans: ESSA provides 

that once a state plan is approved it 

remains in effect for the duration of the 

state’s participation in Title I, though it 

also directs states to periodically review 

and revise plans as necessary to reflect 

any changes in state strategies or 

programs. If a state makes any significant 

changes to its state plan, such as 

adopting new academic assessments, the 

state must submit a revised plan or 

amendment to Education for review. 

Source: See 20 U.S.C. § 6311(h)(5) and 20 U.S.C. § 

6311(a)(6).
Page 15 GAO-17-660 Every Student Succeeds Act

On June 16, 2017 we provided a draft of this report to Education for 

comment. That same day, Education issued additional guidance for 

states on developing their state plans, including some guidance related to 

accountability systems.20 Education provided technical comments on our 

draft, which we incorporated as appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the U.S. 

Secretary of Education. In addition, the report will be available at no 

charge on the GAO website at http://gao.gov.

If you or your staff have any questions about this report, please contact 

me at (617) 788-0580 or nowickij@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff who made key contributions to this report 

are listed in appendix II.

Sincerely yours,

Jacqueline M. Nowicki

Director

Education, Workforce, and

Income Security Issues

 20U.S. Department of Education, Every Student Succeeds Act Consolidated State Plan 

Frequently Asked Questions (June 16, 2017), accessed June 30, 2017, 

https://www2.ed.gov/policy/elsec/leg/essa/index.html. 

Agency Comments

and Our Evaluation
Appendix I: National and State Stakeholder 

Groups With Whom GAO Spoke

Page 16 GAO-17-660 Every Student Succeeds Act

AASA, The School Superintendents Association 

California Teachers Association

Chiefs for Change

Council of Chief State School Officers

Council of the Great City Schools

Education Commission of the States

National Conference of State Legislators

National Governors Association

Ohio Association of Elementary School Administrators

Ohio Association of Secondary School Administrators

Ohio Federation of Teachers

The Education Trust

Thomas B. Fordham Institute

Appendix I: National and State Stakeholder 

Groups With Whom GAO Spoke 
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 17 GAO-17-660 Every Student Succeeds Act

Jacqueline M. Nowicki, (617) 788-0580, nowickij@gao.gov

In addition to the contact named above, Bill Keller (Assistant Director), 

Nancy Cosentino (Analyst-in-Charge), James Bennett, Deborah Bland, 

Mindy Bowman, Sarah Cornetto, Randolfo DeLeon, Anna Duncan, Holly 

Dye, Brian Egger, Sheila R. McCoy, and Monica Savoy made key 

contributions to this report.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(101300)
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