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Early Implementation of State Differentiated Accountability 

Plans Under the No Child Left Behind Act

Karen Charles

Larry Bernstein

Terri Dempsey

Courtney Burns

Elizabeth Parish

Jordan Hudson

RTI International

Prepared for:

U.S. Department of Education

Office of Planning, Evaluation and Policy Development

Policy and Program Studies Service

2012
This report was prepared for the U.S. Department of Education under Contract No. ED-04-CO0036/0002. The project monitor was Erica Lee in the Policy and Program Studies Service. The views 

expressed herein are those of the contractor. No official endorsement by the U.S. Department of 

Education is intended or should be inferred. The mention of trade names, commercial products or 

organizations in this report does not imply endorsements by the U.S. government. This publication also 

contains URLs for information created and maintained by private organizations. This information is 

provided for the reader’s convenience. The U.S. Department of Education is not responsible for 

controlling or guaranteeing the accuracy, relevance, timeliness or completeness of this information. 

Further, the inclusion of information or URL does not reflect the importance of the organization, nor is it 

intended to endorse any views expressed, or products or services offered.

U.S. Department of Education

Arne Duncan

Secretary

Office of Planning, Evaluation and Policy Development

Carmel Martin

Assistant Secretary

Policy and Program Studies Service

Stuart Kerachsky

Director

March 2012

This report is in the public domain, except for the photograph on the front cover, which is used with 

permission and copyright, 2012, Fotolia. Authorization to reproduce the report in whole or in part is 

granted. While permission to reprint this publication is not necessary, the suggested citation is: U.S. 

Department of Education, Office of Planning, Evaluation and Policy Development, Policy and Program 

Studies Service, Early Implementation of State Differentiated Accountability Plans Under the No Child 

Left Behind Act, Washington, D.C., 2012. 

This report is available on the Department’s website at 

http://www.ed.gov/about/offices/list/opepd/ppss/reports.html. 

On request, this publication is available in alternative formats, such as Braille, large print, or CD. For more 

information, please contact the Department’s Alternate Format Center at 202-260-0852 or 202-260-0818.

Content Contact

Erica Lee

202-260-1463

erica.lee@ed.gov
Contents iii

Contents

List of Exhibits ................................................................................................................................ v

Executive Summary ...................................................................................................................... vii

Introduction ..................................................................................................................................... 1

Early Implementation of Differentiated Accountability Across the Nine States ............................ 5

Challenges and Lessons Learned .................................................................................................. 21

Conclusions ................................................................................................................................... 25

References ..................................................................................................................................... 27

Appendix A: State Differentiated Accountability Models............................................................ 29

Appendix B: State and Local Respondents Interviewed in the Nine Pilot States ......................... 57

Appendix C: Summary of Methods States Used to Distinguish Tiers in Pilot Differentiated 

Accountability Models .................................................................................................................. 59
Contents iv

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Exhibits v 

Exhibits

1 Criteria for measures of differentiated accountability tiers, by states in pilot 

program ............................................................................................................................... 7

2 Arkansas differentiated accountability model categories, by Title I designation ............... 8

3 Number of Title I schools in Indiana’s differentiated accountability tiers (Focused 

vs. Comprehensive), by school improvement year ............................................................. 9

4 Percentages of schools in New York’s differentiated accountability categories, as 

compared to percentages in previous school improvement categories ............................. 10

5 Louisiana differentiated accountability model categories, by Title I designation ............ 11

6 Changes to availability of supplemental educational services (SES) in nine pilot 

states .................................................................................................................................. 14

7 Selected support services newly established or coordinated to support 

implementation of differentiated accountability, by state ................................................. 17

A.1 Arkansas differentiated accountability model categories, by Title I designation ............. 30

A.2 Arkansas differentiated accountability categories, by determination and 

corresponding intervention(s) ........................................................................................... 31

A.3 Florida differentiated accountability model categories, by Title I designation ................ 33

A.4a Percentage of Florida schools, by select student subgroups that did not make AYP 

in reading .......................................................................................................................... 34

A.4b Percentage of Florida schools, by select student subgroups that did not make AYP 

in math .............................................................................................................................. 34

A.5 Florida school, district, and state support roles, by differentiated accountability 

categories .......................................................................................................................... 36

A.6 Georgia differentiated accountability model categories, by Title I designation ............... 37

A.7 Illinois differentiated accountability model categories, by Title I designation ................ 39

A.8 Indiana differentiated accountability model categories, by Title I designation ................ 41

A.9 Indiana differentiated accountability interventions for Focused and 

Comprehensive schools .................................................................................................... 43

A.10 Louisiana school performance score ranges, by corresponding labels ............................. 44

A.11 Louisiana differentiated accountability model categories, by Title I designation ............ 44

A.12 Louisiana state menu of interventions from which schools could create school 

improvement plans ............................................................................................................ 45

A.13 Maryland differentiated accountability model categories, by Title I designation ............ 47

A.14 Maryland state menu of interventions from which schools could create school 

improvement plan ............................................................................................................. 49

A.15 Number of schools and percentage of subgroups not making AYP, by Maryland 

differentiated accountability improvement categories: School year 2008–09 .................. 50
Exhibits vi 

A.16 New York differentiated accountability model categories, by Title I designation ........... 51

A.17 New York required diagnostic, implementation, and oversight interventions under 

differentiated accountability, by school improvement categories: School year 

2008–09............................................................................................................................. 52

A.18 Ohio differentiated accountability model categories, by Title I designation .................... 53

B.1 Interview subjects, by the nine pilot states ....................................................................... 57 
Executive Summary vii 

Executive Summary

In 2008, the U.S. Department of Education (the Department) launched a differentiated 

accountability pilot to allow states to distinguish between those schools identified for 

improvement in need of substantial help and those closer to meeting achievement goals. 

Differentiated accountability is intended to allow states to vary the intensity and types of 

interventions to better match the academic reasons leading to a school’s identification and to 

target resources and assistance to those schools most in need of intensive interventions and 

significant reform. Under Title I, Part A, of the Elementary and Secondary Education Act of 

1965 (ESEA), states have been required to set targets for school and district performance leading 

to the goal of all students achieving proficiency on state reading and mathematics assessments by 

the 2013–14 school year. Schools and districts not making adequate yearly progress (AYP) 

toward this goal for two or more consecutive years are identified as in need of improvement and 

are subject to increasing levels of interventions designed to improve their performance. 

In July 2008 and January 2009, the Department approved waivers to give nine states the 

flexibility to implement differentiated accountability pilot plans creating more nuanced systems 

for identifying and assisting Title I schools identified for Improvement, Corrective Action, or 

Restructuring. Under this pilot, participating states could change the structure of the school 

improvement categories used for schools that have missed AYP based on the lengths of time and 

reasons for missing AYP. In addition, each state was expected to clearly define its system of 

interventions to be applied to schools in each category or stage of school improvement, including 

interventions for the lowest-performing schools in the state. The Department approved waivers 

through the 2011–12 school year for Florida, Georgia, Illinois, Indiana, Maryland, and Ohio in 

July 2008, and through the 2012–13 school year for Arkansas, Louisiana, and New York in 

January 2009. 

This report describes the early implementation of differentiated accountability in the nine pilot 

states, based on interviews at the state and local levels and on review of extant documents. The 

study was designed to address three central issues:

• How have states used their waivers to change their school improvement categories?

• How have states responded to their waivers in terms of proposed plans for school 

interventions? 

• What challenges are states, districts, schools, and school support providers experiencing 

in implementing differentiated accountability?

Study Design and Limitations 

This report examines how the pilot states planned and began to implement differentiated 

accountability, both in terms of changing the school improvement categories and in terms of 

changing states’ strategies for helping improve performance in targeted schools. This study 

gathered information on the implementation of the differentiated accountability pilot through 

interviews at the state and local levels and through review of extant documents, such as states’ 

differentiated accountability plans, and other public documents. Staff interviewed in each state 
Executive Summary viii

included the state Title I director, a state support provider, a district Title I director, and an 

elementary or middle school principal.

1

The study reflects an early stage of implementation of states’ differentiated accountability plans: 

18 months at most (and, in some cases, much less). This report is based on interviews with a 

small number of purposively selected individuals in the pilot states (four per state). Many of the 

findings are based on self-reports from the state agency staff responsible for implementing the 

differentiated accountability plans, and there was often little supporting documentation for the 

information they reported (aside from the plans themselves). Although the study also conducted 

interviews with local educators in districts and schools that were affected by the differentiated 

accountability plans, in many cases the plans were in a relatively early stage of implementation, 

and local educators had limited experience with the new approaches being implemented under 

differentiated accountability. In addition, local educators often did not have a clear understanding 

of what state actions and changes were part of the state’s differentiated accountability plan, 

particularly because these plans often sought to coordinate with and use resources from other 

programs. 

Key Findings 

Key findings of this short-term study include the following: 

• Under the differentiated accountability pilot, eight of the nine participating states 

determined school improvement status based on both the percentage of AYP indicators 

the school had met and the number of years the school had been under an 

improvement plan. Under ESEA, each Title I district is required to identify for school 

improvement any Title I school not making AYP for two consecutive years, based on 

missing any of a number of indicators. Most of the pilot states added tiers within school 

improvement levels to distinguish between schools missing few AYP indicators and 

those missing many indicators. 

• Although most changes enacted were allowable prior to the waiver, state respondents 

reported that the differentiated accountability pilot provided an impetus for their states 

to implement strategies intended to better coordinate, target, and expand their technical 

assistance services. State respondents said that the waiver provided an opportunity to 

rethink and improve their approaches to supporting Schools in Need of Improvement. 

Strategies that states reported implementing under differentiated accountability included 

aligning technical assistance services with newly designated improvement tiers, 

expanding leadership institutes, designing more professional development regarding the 

use of data, and increasing on-site assistance for schools from state, regional, and district 

service providers. States with regional service centers reported taking steps to coordinate 

state education agency and regional service center support activities in order to avoid 

overlap, and one state created a new regional support system to assist the state in 

delivering support services. 

 

1 In a number of cases, however, school principals were at their schools for less than a year, making it difficult for 

them to make pre-post comparisons.
Executive Summary ix

• Implementation of the differentiated accountability plans varied across the pilot states. 

Most pilot states reported that they had implemented differentiated accountability as 

scheduled and proposed in their plans. A few reported a variety of circumstances, ranging 

from short implementation time lines to shifting priorities to changes in leadership, as 

reasons to modify or delay the implementation of their differentiated accountability plans. 
Executive Summary x 

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Introduction 1 

Introduction

In 2008, the U.S. Department of Education (the Department) launched a differentiated 

accountability pilot to allow states to distinguish between those schools identified for 

improvement that were in need of substantial help and those schools that were closer to meeting 

achievement goals. Differentiated accountability is intended to allow states to vary the intensity 

and types of interventions to better match the academic reasons leading to a school’s 

identification and to target resources and assistance to those schools most in need of intensive 

interventions and significant reform. 

Under Title I, Part A, of the Elementary and Secondary Education Act of 1965 (ESEA), as 

reauthorized under the No Child Left Behind Act of 2001 (NCLB), states must annually determine 

whether schools and districts are making adequate yearly progress (AYP) toward the goal of all 

students reaching the proficient level on state reading and mathematics assessments by 2014. To 

make AYP, each school and district must meet annual measureable objectives (AMOs) for each 

key student subgroup—including students from low-income families, major racial and ethnic 

subgroups, students with disabilities, and limited English proficient (LEP) students—as well as 

for the school or district as a whole. Schools and districts that do not make AYP for two or more 

consecutive years are identified as needing improvement and are subject to increasing levels of 

interventions designed to improve their performance and to provide students with additional 

options. In Title I schools identified for improvement, districts must offer students the option to 

transfer to another school. If an identified school misses AYP for a third year, low-income 

students in the school must be offered the option to receive supplemental educational services 

(SES) from a state-approved provider. If an identified school misses AYP for a fourth year, the 

district must take one of a set of Corrective Actions specified in the law, and if the school misses 

AYP for a fifth and sixth year, the district must develop and then implement a plan for 

Restructuring the governance of the school. 

Under the differentiated accountability pilot, participating states received waivers permitting 

them to change the structure of the school improvement categories used for schools that have 

missed AYP, based on the lengths of time that schools missed AYP and the numbers or types of 

AYP targets that were missed. Pilot states were required to maintain their current practice for 

determining AYP and identifying schools as in need of improvement. In addition, they were 

required to clearly identify their proposed process for categorizing schools, system of 

interventions, and interventions to be used in the lowest-performing schools. 

In July 2008 and January 2009, using the authority in section 9401 of the ESEA, the Department 

approved applications for waivers from nine states to implement differentiated accountability 

pilot plans (see Appendix A) that allowed them to vary the intensity and type of interventions 

provided in Title I schools identified for improvement. The Department approved waivers for 

Florida, Georgia, Illinois, Indiana, Maryland, and Ohio in July 2008 and for Arkansas, Louisiana, 

and New York in January 2009. Each participating state implemented differentiated 

accountability through a flexibility agreement between the Department and the state education 

agency (SEA), permitting the state to include its differentiated accountability model as part of its 

state system of interventions under section 1116 of the ESEA for up to four years, unless the 
Introduction 2 

upcoming reauthorization of the ESEA changes the requirements on which the state model is 

based.

This report describes the early implementation of differentiated accountability in the nine pilot 

states, based on interviews at the state and local levels and review of extant documents. The 

study was designed to examine three central issues:

• How have states used their waivers to change their school improvement categories?

• What school interventions did states plan to use in low-performing schools under their 

differentiated accountability plan? 

• What challenges are states, districts, schools, and school support providers experiencing 

in implementing differentiated accountability?

In addition to the summary findings presented in the main body of this report, more detailed 

information on each pilot state’s differentiated accountability plan is provided in Appendix A.

Previous Research

Although there has been little research conducted to date on the implementation of the 

Differentiated Accountability Pilot program, a set of reports produced by the Center on 

Education Policy (CEP) has described lessons learned based on four of the pilot states: Georgia, 

Maryland, New York, and Ohio. Although the findings across the four states were mixed, a set of 

common themes emerged from CEP’s review of these states’ efforts. CEP reported that all four 

states developed accountability plans that differed from their original NCLB accountability 

systems. These states also reported the adopting of new labels for struggling schools, with three 

of the states (Georgia, Maryland, and New York) also developing a set of secondary labels 

within each category to differentiate schools based on their severity of need and supports 

required. In addition, the four states all reported the need for decisions on school improvement to 

be made based on state-developed needs assessment tools (CEP 2009b).

Study Methods

This report synthesizes information gathered from public documents, state websites, and 

interviews over a seven-week period from November 2009 to January 2010. Staff interviewed in 

each state included the state Title I director; a state department representative responsible for 

providing support services to schools and districts; a district Title I director; and an elementary 

or middle school principal (see Appendix B).

Each state superintendent and Title I director in the nine pilot states received an information 

packet requesting an interview for the purposes of this evaluation. During follow-up contacts via 

phone and email, the state Title I directors identified state service providers and district Title I 

directors to be interviewed, and the district directors selected the principals. Separate interview 

protocols were developed for each of the four categories of interviewees, based on their roles as 

providers or recipients of support services. 
Introduction 3 

Study Limitations 

The study reflects an early stage of implementation of states’ differentiated accountability plans: 

18 months at most—and, in some cases, much less. Three of the pilot states received their 

waivers in January 2009, six months after the initial group of pilot states was approved in July 

2008, and thus had had less time to implement their differentiated accountability plans at the 

time this study’s data collection was conducted (November 2009–January 2010). One of these 

three states (New York) indicated that it was in the preliminary stages of implementation at the 

time the study interviews were conducted and that changes had not yet been implemented in the 

affected schools. In addition, one of the states approved in the first cohort used the 2008–09 

school year to plan for implementation of its differentiated accountability model (Illinois) and so 

had less experience with actual implementation than the other five states in the first cohort.

This report is based on interviews with a small number of purposively selected individuals in the 

pilot states (four per state). Many of the findings are based on self-reports from the state agency 

staff responsible for implementing the differentiated accountability plans, and there was often 

little supporting documentation for the information they reported (aside from the plans 

themselves). Although the study also conducted interviews with local educators in districts and 

schools that were affected by the differentiated accountability plans, in many cases the plans 

were in a relatively early stage of implementation, and local educators had limited experience 

with the new approaches being implemented under differentiated accountability. In addition, 

local educators often did not have a clear understanding of what state actions and changes were 

part of the state’s differentiated accountability plan, particularly because these plans often sought 

to coordinate with and use resources from other programs. 
Introduction 4 

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Early Implementation 5 

Early Implementation of Differentiated Accountability

Across the Nine States

The nine states participating in the Department’s differentiated accountability pilot and in this 

study described a variety of ways in which they modified their accountability systems to better 

distinguish interventions for schools that missed targets for a few student subgroups versus for 

schools that have more systemic problems with low achievement. Participating states also 

reported that the pilot provided an impetus for them to develop and implement plans to expand 

and better coordinate the support systems that they use to improve instruction and achievement 

in low-performing schools and to realign resources in order to implement earlier interventions 

and more comprehensive services for the schools most in need of assistance. It should be noted 

that many of these changes were allowable prior to the waiver; however, the waiver provided 

states an impetus to modify accountability systems. 

States differed in the extent to which they implemented their proposed differentiated 

accountability plans. However, although the three states that received waivers through the 

Department’s differentiated accountability pilot in January 2009 have implemented differentiated 

accountability for a shorter period of time, the findings based on their representatives’ responses 

did not differ greatly from those in states that received the waiver in July 2008. Therefore, this 

report presents the following findings from the aggregated responses from all state and district 

representatives.

Modified School Improvement Categories 

Title I of ESEA requires each state to have an accountability system that is effective in ensuring

that all schools and districts make AYP toward the goal of 100 percent proficiency in at least

reading and mathematics by 2014. To make AYP, a school or district must meet the AMOs set 

by the state; annual targets representing the percentage of students (overall and for specified 

subgroups) that must perform at the state’s proficient level or above on state reading and 

mathematics assessments. The AMOs are measured not only for each school and district as a 

whole but for each of certain specified subgroups—including students from major racial and 

ethnic groups, economically disadvantaged students, English Learners (ELs), and students with 

disabilities (i.e., for each group that meets the state’s minimum “n size” or minimum number of 

students sufficient to yield statistically reliable information). Each school and district, and each 

subgroup within each school and district, must meet all of its AMOs in both reading and 

mathematics in order to make AYP. In addition to meeting its AMOs, to make AYP, a school or 

district, and each of its subgroups, also must meet the 95 percent participation rate requirement 

on state assessments and meet the state’s other academic indicator, which is graduation rate at 

the high school level and some other indicator at the elementary and middle school level (e.g., 

attendance rate). Under section 1111 of the ESEA, for a school to make AYP, each subgroup of 

students in the school must meet all of these indicators (in total, as many as 40 or more indicators 

per school). 

Under ESEA, each Title I district must identify for school improvement any Title I school that 

does not make AYP for two consecutive years. A school that continues not to make AYP 

progresses along the school improvement continuum of categories, as described in the statute: 
Early Implementation 6 

School Improvement (schools missing AYP for two and three consecutive years); Corrective 

Action (schools missing AYP for four and five consecutive years); and Restructuring (schools 

missing AYP for six years or more). A school must implement increasingly rigorous 

interventions for each additional year the school remains in improvement status. Examples of 

early interventions include increased professional development or assistance from content 

coaches, while interventions in the later stages of improvement include the replacement of the 

teaching staff or the principal. For the 2008–09 school year, the percentage of Title I schools in 

each school improvement category varied across the nine pilot states due, in part, to differences 

in how individual states defined their AMOs and differences in testing instruments and 

procedures. 

The Department notified the first six pilot states that their differentiated accountability 

applications had been approved in July 2008 and notified an additional three states in January 

2009. In the first step of implementation of their plans, state leaders categorized schools with 

their new labels and passed that information on to school district Title I directors and principals, 

who were, in turn, expected to inform teachers about any changes in school improvement status 

as a result of differentiated accountability. District Title I directors and principals noted that a 

change in improvement status often required modifications to a school’s improvement plan, 

professional development schedule, or planned interventions. 

Most pilot states (eight of the nine states) reported that they added tiers 

within school improvement levels to differentiate schools based on the 

number of AYP indicators not successfully met.

Through their differentiated accountability models, states added tiers within the school 

improvement categories required under the NCLB statute in order to distinguish between schools 

needing more focused, targeted improvement due to missing AYP based on the performance of a 

limited number of subgroups and those schools needing more comprehensive, schoolwide 

improvement based on the performance of most or all subgroups. Rather than basing school 

improvement status solely on the number of years a school had been in improvement, pilot states 

developed models that considered both the percentage of AYP indicators a school met and the 

number of years the school has been in improvement. Eight of the nine pilot states developed 

additional categories or tiers of school improvement status, but they varied in the specific 

categories that were added and the rules that they defined to determine which category a specific 

school would fall under (see Appendix C). Consistent with that aspect of differentiated 

accountability implementation, CEP found that all four states in its study of restructuring under 

NCLB decided that additional secondary labels within the original Title I restructuring categories 

were needed to effectively differentiate schools based on the severity of their needs and the 

supports required to address them (CEP 2009a). 

Exhibit 1 provides a summary of the various approaches taken by states to develop their 

differentiated accountability tiers, using AYP indicators, performance on AMOs, a combination 

of both, or neither. The structure of each of the pilot states’ differentiated accountability plans is 

explained in detail in the individual state sections of this report.
Early Implementation 7 

Exhibit 1 

Criteria for measures of differentiated accountability tiers, by states in pilot program

Criteria ARa FLb GAb ILb INb LAa MDb NYa OHb

Percentage of AYP indicators missed No Yes No Yes No No No Yes Yes

Performance on AMOs Yes No Yes No No No Yes No No

Index using both AYP and AMO No No No No Yes No No No No

No additional tiers proposed Yes No No No No Yes No No No

Exhibit reads: Florida, Illinois, New York, and Ohio developed tiers in their differentiated accountability plans based 

on a school’s achievement of its AYP indicators.

a ED approved states’ differentiated accountability plans in January 2009.

b ED approved states’ differentiated accountability plans in July 2008.

NOTE: AMO = annual measurable objective; AYP = adequate yearly progress.

SOURCE: State differentiated accountability applications submitted to ED in 2008.

With the exception of Louisiana, the pilot states opted to define tiers within the Title I 

improvement categories to distinguish among their low-performing schools. States used terms 

such as “targeted” or “focused” for schools that missed AYP based on the performance of a 

small number of subgroups and words like “comprehensive” for schools with more widespread 

problems. Each state’s differentiated accountability plan, with a complete discussion of the new 

categories, the criteria for each category, and the related interventions for each pilot state, is 

found in the state section of this report (see Appendix A), but several examples are presented 

below.

Four states used an approach based on AYP indicators. Two states used the percentage of AYP 

indicators missed as the basis for establishing new school improvement categories. Both Florida 

and Ohio separated schools in improvement that met 80 percent of their AYP indicators from 

schools that did not. In Florida, schools meeting 80 percent of their AYP indicators were 

classified as Category I schools, and those meeting less than 80 percent were labeled Category II 

and were considered the more severe cases. The Florida state Title I director commented that the 

new system allowed the state to “differentiate the support and strategies based on the needs of 

the school, specifically based on the reasons the school did not make AYP.” In Ohio, schools 

missing less than 20 percent of their AYP indicators were labeled Low Support and were 

considered in need of fewer interventions than schools missing higher percentages. As a 

modified approach, Illinois and New York used AYP to create Focused and Comprehensive 

school improvement tiers, based on whether schools met or missed AYP in the All Students 

category.

In contrast, Arkansas, Georgia, and Maryland used AMOs to develop their tiers, each using a 

different approach. AMOs are performance targets set by each state that represent the percentage 

of students that must reach the proficient or advanced levels each year for a school, the district, 

and the state to make AYP. A school has to meet the AMOs set by the state for every grade and 

subject in all of the student subgroups for a school to make AYP. Arkansas developed tiers based 

on both the number and percentage of subgroups that missed their AMOs and how long a school 

had been in improvement. Georgia defined three tiers within ESEA’s Corrective Action category, 

based on how far a school was from reaching its AMOs, while Maryland based its tiers solely on 

how many student subgroups missed the AMOs in reading or mathematics. 
Early Implementation 8 

The Arkansas differentiated accountability model (see Exhibit 2) is representative of the tiered 

approach used by eight pilot states. Arkansas created four school improvement categories: 

Targeted Improvement, Intensive Targeted Improvement, Whole-School Improvement, and 

Intensive Whole-School Improvement. The table illustrates how the Title I categories map onto 

the new categories designated in the Arkansas differentiated accountability model. With the 

addition of these new tiers, an Arkansas school in the first year of improvement can now be 

further identified as needing Targeted Improvement, Intensive Targeted Improvement, or WholeSchool Improvement, and services can be based on needs. 

Exhibit 2

Arkansas differentiated accountability model categories, by Title I designation

State differentiated 

accountability 

categories

Title I 

designation: 

missed AYP 

zero or 

one year

Title I 

designation: 

Improvement, 

Year 1 

(SINI 1)

Title I 

designation: 

Improvement, 

Year 2 

(SINI 2)

Title I 

designation: 

Corrective 

Action 

(SINI 3)

Title I 

designation: 

Restructuring, 

Planning 

(SINI 4)

Title I 

designation: 

Restructuring, 

Implementation 

(SINI 5+)

Achieving Schools • 

Targeted 

Improvement • • • 

Intensive Targeted 

Improvement • • • 

Whole-School 

Improvement • • • 

Intensive WholeSchool 

Improvement

 • • •

Exhibit reads: In Arkansas, Schools in Need of Improvement, Year 1 (SINI 1), under Title I are now labeled Targeted 

Improvement, Intensive Targeted Improvement, or Whole-School Improvement.

NOTE: AYP = adequate yearly progress. ED approved Arkansas’ differentiated accountability plan in January 2009; Appendix C 

contains explanations of differentiated accountability categories.

SOURCE: Arkansas differentiated accountability application submitted to ED in 2008, December 2009 and January 2010 interviews, 

and state website (http://arkansased.org/smart_accountability.html).

In a combined approach, Indiana developed a formula-driven indexed rating system based on a 

combination of number and percentage of subgroups missing any AYP indicators and the 

distance from AMOs in language arts and mathematics. With differentiated accountability, 

Indiana added two tiers within each year of school improvement to distinguish between schools 

with an index rating below 60.95 (Focused) and those with a rating ranging from 60.95 to 149.70 

(Comprehensive). Focused schools missed AYP based on the performance of a few subgroups, 

and Comprehensive schools missed AYP based on the performance of many. For the 82 schools 

in Indiana in Year 1 of improvement in school year 2008–09, the state used a combination of 

school AYP and AMO data to identify 68 schools needing Focused services and 14 schools 

needing Comprehensive services (see Exhibit 3). Schools remained in their ESEA category but 

were further subdivided into Focused and Comprehensive tiers. Schools in Year 4 (i.e., 

restructuring) and beyond were further distinguished as Focused Intensive and Comprehensive 

Intensive.
Early Implementation 9 

Exhibit 3

Number of Title I schools in Indiana’s differentiated accountability tiers (Focused vs. 

Comprehensive), by school improvement year

Improvement 

year 

Title I 

system

Differentiated accountability 

system: Focused

Differentiated accountability 

system: Comprehensive

Year 1 82 68 14

Year 2 69 62 7

Year 3 38 24 14

Year 4 17 13 4

Year 5+ 14 3 11

Exhibit reads: Of the 82 Indiana schools in Year 1 of improvement status, 68 schools are labeled Focused, and 

14 schools are labeled Comprehensive.

NOTE: ED approved Indiana’s differentiated accountability plan in July 2008.

SOURCE: Indiana differentiated accountability application submitted to ED in 2008.

Five of these eight states added tiers within selected years on the ESEA continuum. Georgia 

added tiers in the Corrective Action years—Schools in Need of Improvement, Years 3 and 4 

(SINI 3 and SINI 4), while Florida added two tiers in the first three years of improvement and 

three tiers in Years 4–6. Illinois and Indiana added two tiers, Focused and Comprehensive, in 

every ESEA category, and Ohio added three—Low Support, Medium Support and High Support. 

The Illinois state Title I director summed up the rationale for developing tiers within the ESEA

categories by explaining that “differentiated accountability acknowledged what we in the field 

intuitively were seeing, that there is a difference between a school that had the all group not 

meeting AYP and a [school with] one subgroup, maybe even a small subgroup, not meeting 

AYP.” 

With differentiated accountability, New York reduced the number of school improvement 

categories to four by consolidating some of the Title I categories. For example, a school initially 

labeled as a Corrective Action school under Title I became an Improvement school under 

differentiated accountability (see Exhibit 4). In the New York state accountability system, a 

school can be labeled as a School Under Registration Review (SURR) in any year of 

improvement. The label is not dependent on the number of years a school has been in 

improvement but on the severity of performance issues at the school. 
Early Implementation 10 

Exhibit 4

Percentages of schools in New York’s differentiated accountability categories, 

as compared to percentages in previous school improvement categories

Differentiated 

accountability categories % of schools Previous school improvement categories

Improvement 41% SINI 1 (22%)

SINI 2 (11%)

Corrective Action (10%)

Corrective Action 22% Restructuring Planning (8%)

Restructuring Years 1–2 (13%)

Restructuring 28% Restructuring Years 3–4 (14%)

Schools Requiring Academic Progress Years 1–3 (12%)

Schools Under Registration 

Review (SURR)

9% Schools Requiring Academic Progress Years 4–7 (10%)

Exhibit reads: New York combined the first three years of school improvement status (formerly SINI 1, SINI 2, and 

Corrective Action) into a single category labeled as Improvement under Differentiated Accountability.

a Schools Requiring Academic Progress (SRAP) was a non–Title I designation that New York had used to indicate schools farthest 

from reaching state standards and most in need of improvement.

NOTE: SINI = Schools in Need of Improvement. Percentages were rounded, so totals in each differentiated accountability category 

may not match sum of Title I categories. ED approved New York’s differentiated accountability plan in January 2009; Appendix C 

contains explanations of differentiated accountability categories.

SOURCE: New York differentiated accountability application submitted to ED in 2008.

Unlike the other eight pilot states, Louisiana did not include tiers for identifying schools in its 

differentiated accountability model (see Exhibit 5). The state opted to rename the ESEA

categories (e.g., renaming schools in the second year of school improvement as Secondary 

Support schools) but did not differentiate further within the ESEA categories. Louisiana did, 

however, make use of the waiver it received from the Department in other ways. For example, it 

created tiers for interventions within categories based on what percentage of the total school 

enrollment the subgroup(s) missing one or more AYP indicators represented. In addition, 

Louisiana used the flexibility provided by differentiated accountability to retain its state system 

of accountability as defined by school performance scores (SPS). SPS is calculated via a formula 

using assessment scores, attendance, drop-out, and graduation data, and the state continued to 

assign schools with performance and growth labels. (For further details, see state discussion in 

Appendix A.)
Early Implementation 11 

Exhibit 5

Louisiana differentiated accountability model categories, by Title I designation

State 

differentiated 

accountability 

categories

Title I 

designation: 

missed AYP 

zero or 

one year

Title I 

designation: 

Improvement, 

Year 1 

(SINI 1)

Title I 

designation: 

Improvement, 

Year 2 

(SINI 2)

Title I 

designation: 

Corrective 

Action 

(SINI 3)

Title I 

designation: 

Restructuring, 

Planning 

(SINI 4)

Title I 

designation: 

Restructuring, 

Implementation 

(SINI 5+)

Pre-Identification •

Initial Support •

Secondary 

Support • 

Continued 

Support 1 • 

Continued 

Support 2 • 

Vital Support 1 •

Vital Support 2 •

Exhibit reads: Schools in Need of Improvement, Year 1 (SINI 1), under Title I are now labeled Initial Support.

NOTE: AYP = adequate yearly progress. ED approved Louisiana’s differentiated accountability plan in January 2009; Appendix C 

contains explanations of differentiated accountability categories.

SOURCE: Louisiana differentiated accountability application submitted to ED in 2008, November 2009–January 2010 interviews, 

and state website (http://www.louisianaschools.net/topics/understanding_acct.html).

Two pilot states added a Pre-Identification category for schools missing 

AYP for the first time.

Schools that have not missed AYP or have missed it only one year are not in school 

improvement, and states are not required by federal law to provide support to these schools 

through their accountability systems. With differentiated accountability, however, two states 

included a Pre-Identification category for schools missing AYP for the first time. The state 

Title I directors from Louisiana and Maryland provided similar explanations about their 

respective state’s decision to include this category. 

Louisiana added a Pre-Identification category, and Maryland added an Achieving Schools 

designation in order to provide early interventions and hopefully prevent schools from sliding 

into Year 1 of improvement. Each state included a set of early intervention strategies to assist 

schools that were in danger of entering improvement in identifying their weaknesses and develop 

their school improvement plans to address their specific needs. The state directors felt that 

providing this type of support early would help schools use their student performance data to 

plan targeted interventions. 

Coordinated Services 

By creating new school improvement categories or defining tiers within categories, states 

intended to reposition schools for support services and interventions that were more aligned with 

their specific needs. Such efforts also were possible under ESEA before differentiated 

accountability, and, yet, the availability of differentiated accountability waivers appears to have 

encouraged pilot states to implement school improvement strategies that state leaders had been 

considering for some time. 
Early Implementation 12 

To provide schools and districts with more customized services focused on needs and to 

coordinate the efforts of statewide agencies, states reported that they aligned a variety of 

technical assistance services with their newly designated tiers. States sought to reduce overlap of 

services by defining roles and responsibilities with other service providers and filled voids by 

working with the providers to expand leadership institutes, design more professional 

development opportunities, and increase on-site assistance for schools from state, regional, and 

district service providers. With the flexibility to include more targeted levels of improvement in 

their differentiated accountability models, the pilot states redirected services based on 

distinctions between schools with fewer problem areas and those with more widespread issues. 

State respondents reported that the differentiated accountability pilot 

provided an impetus for their states to implement strategies intended to 

better coordinate, target, and expand their technical assistance services.

Prior to implementing differentiated accountability, districts and schools in the pilot states had 

access to a variety of service providers, including regional service centers, private companies and 

consultants, and state departments of education personnel. The array of services available 

included content and leadership academies, on-site mentoring and coaching, workshops and 

professional development opportunities targeting specific student needs, and training on the use 

of diagnostic tools to facilitate data analysis. State Title I directors felt that the process of 

developing their differentiated accountability applications provided an opportunity to examine 

these available services and consider options to better coordinate these efforts and decrease the 

duplication of services.

Some states coordinated existing services by assigning specific stages or tiers of school 

improvement status to specific service providers in order to reduce duplication of services. Statelevel Title I directors and support providers in the pilot states reported that they had access to 

existing state services that were either well established or newly emerging and that they felt they 

could develop a coherent range of services for their differentiated accountability plans by 

coordinating these services with the state agency. For example, five states had regional service 

centers that provided an array of services to area schools that were not always coordinated with 

state services. In Georgia and New York, the state departments redirected the departments’ direct 

services to the lowest-performing schools and used the regional centers to provide technical 

assistance to less-needy schools; state respondents believed that this strategic division of labor 

resulted in a reduced duplication of services and clarified for schools and districts the 

responsibilities of the various service providers so that they would have a clearer understanding 

of which agency to contact for specific services. In Ohio, a design team from the state 

department coordinated professional development for regional providers to improve consistency 

in the services provided to districts. 

Generally speaking, under differentiated accountability, schools missing AYP based on the 

performance of only one subgroup were offered targeted support, while those missing most of 

their AYP indicators were provided with more intensive, comprehensive support. For example, 

Indiana provided a broader menu of supports and interventions for its Comprehensive schools in 

each stage of improvement. For schools in Year 1 of improvement, for example, Comprehensive 

schools were offered a number of additional interventions, such as whole-school use of state 

reading and mathematics diagnostic assessments (Wireless Generation and Acuity); a full-time, 
Early Implementation 13 

on-site literacy or mathematics coach; and expanded SES for non-proficient students from lowincome families (including open enrollment, on-site services, and transportation home). 

Georgia’s differentiated accountability model collapsed the Corrective Action and Restructuring 

Planning years under Title I into one category and then added tiers within this new Corrective 

Action category using a formula to distinguish the top-performing quintile (Tier 1), the middle 

three quintiles (Tier 2), and the lowest-performing quintile (Tier 3). Schools in Tier 2 were then 

required to select and implement an additional intervention from the Title I list, and schools in 

Tier 3 were required to implement an additional intervention to be selected by the state. Under 

differentiated accountability, Georgia expanded the roles of the 16 Regional Education Service 

Agencies (RESAs). Prior to differentiated accountability, the RESAs served schools in Years 1 

and 2 of improvement; now, with the addition of state-funded school improvement specialists to 

the RESA staff, RESAs also serve all schools in the newly designated Corrective Action tiers, 

made possible by additional federal funds for school improvement appropriated under section 

1003(g) of Title I law. The state also has provided coordinated professional development for all 

RESA-based school improvement specialists to ensure that services are consistent across districts 

and schools. The CEP report similarly documents a more intensive and uniform intervention for 

schools in the Restructuring Implementation phase (CEP 2009a).

In Arkansas, the state Title I director explained that, prior to differentiated accountability, 

Arkansas contracted with America’s Choice, an external service provider, to implement the 

provider’s comprehensive turnaround model of school reform in the state’s lowest-performing 

schools, while the state department of education provided assistance to all other schools in 

school improvement status. To support the implementation of differentiated accountability, the 

state opened the service provider’s trainings to schools in the earlier stages of improvement but 

focused more intensive services on schools in Year 3 of improvement and beyond. These 

services ranged from more intensive use of state support teams and professional development to 

offering technical assistance to schools in writing up their school improvement plans. The state 

support provider also reported that her office expanded its services to include training for school 

leadership teams and assistance to schools in implementing instructional coaching models, 

conducting classroom observations, and analyzing classroom walk-through data.2 The state 

department and external service provider worked together to provide support to schools in 

Years 1 and 2 of improvement through such options as the Leadership Academy and America’s 

Choice workshops. 

Arkansas also expanded the role of its regional education service centers, using them to provide 

professional development directly aligned with the interventions available under the state’s 

differentiated accountability model. Before implementing differentiated accountability, the 

statewide system of support included state support teams comprising math, literacy, science, 

special education, and English Learner (EL) specialists, but under differentiated accountability, 

the state integrated the support teams into its new service model to expand and coordinate their 

services to reach more schools while still targeting more intensive services to the subset of 

schools most in need. Arkansas also increased the capacity of its Leadership Academy, a statefunded program that trains superintendents, principals, and teachers to build capacity at the local 

 

2 In the practice of classroom walk-throughs, principals and other instructional leaders spend only minutes observing 

classroom practices to form opinions about the quality of teaching and learning occurring.
Early Implementation 14 

level, by adding a regional training facility that provides leadership training to build capacity at 

the school level. 

Maryland expanded its existing menu of intervention tools and resources and made some 

options—such as comprehensive planning; curriculum, instruction, assessment, and professional 

development with accountability; leadership; organizational structure and resources; and school 

culture and climate—more easily accessible by offering them through the newly created 

Breakthrough Center. This center assisted schools in the most-intense level of improvement with 

training modules and professional development focused on co-teaching strategies for special 

education students in regular classrooms. 

Most pilot states shifted some interventions to earlier school improvement 

status.

In their waiver applications, seven states proposed to provide SES to students earlier than Year 2 

of improvement, as is required by ESEA, either by shifting the option to Year 1 or by reversing

the order of SES and public school choice, a Year 1 requirement in ESEA that allows students to 

transfer to a school that is not identified for improvement. ESEA requires that after a school 

misses AYP for three years, a district must offer eligible students in the school SES, such as 

tutoring and other supplemental academic enrichment activities, in addition to instruction 

provided during the regular school day. A state approves SES providers and monitors their 

services, and a district must cover the costs of both SES and transportation for public school 

choice, up to an amount equal to 20 percent of its Title I, Part A, allocation. The seven pilot 

states that proposed to offer SES one year earlier than required under Title I have not 

implemented this flexibility uniformly: five states mandated that districts offer SES one year 

earlier, while the other two allowed districts the option of offering SES earlier (see Exhibit 6).

Exhibit 6 

Changes to availability of supplemental educational services (SES) in nine pilot states

State

State reversed order of 

SES and school choice

State offered SES one 

year earlier

Mandatory or optional for 

districts to offer SES earlier

Arkansasa No Yes Mandatory

Floridab Yes No Mandatory

Georgiab Yes No Optional

Illinoisb Yes No Optional

Indianab No Yes Mandatory

Louisianaa Yes No Mandatory

Marylandb No No †

New Yorka Yes No Mandatory

Ohiob No No †

Exhibit reads: Arkansas made SES available to students in schools identified for improvement one year earlier than 

required under Title I and made this change mandatory for its districts.

† Not applicable.

a ED approved states’ differentiated accountability plans in January 2009.

b ED approved states’ differentiated accountability plans in July 2008.

SOURCE: State differentiated accountability applications submitted to ED in 2008; November 2009–January 2010 interviews.
Early Implementation 15 

States receiving approval of their differentiated accountability plans in July 2008 submitted SES 

participation data to the Department comparing SES participation in school year 2007–08 with 

participation in school year 2008–09. Of the six states in this first cohort, Florida and Indiana 

mandated that SES be offered one year earlier, and Georgia and Illinois left the option to districts 

with newly-designated schools entering improvement status in school year 2008–09. In Illinois, 

only three out of 102 districts elected to offer SES one year earlier to their students, and only 21 

out of 50 districts in Georgia exercised this option in school year 2008–09. Maryland and Ohio 

chose not to offer SES earlier than required by ESEA. With the exception of Ohio, the states in 

the first cohort reported increased student participation in SES. State Title I directors in the five 

states that reported an increase felt that offering SES earlier contributed to increased 

participation in SES. Additionally, Indiana’s state Title I director thought that offering SES at 

school buildings, implementing ongoing enrollment, and providing transportation home also 

contributed to the increase in participation rates. 

Under Georgia’s differentiated accountability model, schools entered the contract monitoring 

stage of restructuring in Year 5, which was two years earlier than they would have under Title I, 

with the receipt of direct, on-site support daily from a school-based state director. Illinois and 

Indiana opted to begin Corrective Action interventions one year earlier than is required under 

ESEA. By adding a Pre-Improvement category to identify schools missing AYP for the first time, 

Louisiana and Maryland provided support services to schools the first time they missed AYP 

rather than waiting until schools entered ESEA improvement status after missing AYP for two 

consecutive years. Services offered to Maryland and Louisiana schools in the Pre-Improvement 

category under differentiated accountability included training on the use of data analysis tools; 

the completion of data analysis of AYP results and school performance data for each school; and 

the support of a district assistance team, which helped schools with developing their school 

improvement plans and conducted classroom observations to provide feedback on the 

implementation of those plans. Maryland also shifted reforms used in Years 5 and 6 of 

improvement to Year 4 to provide support to schools earlier in the improvement process, such as 

adopting a new curriculum, extending the length of the school year or school day, replacing 

school staff, decreasing school-level management authority, appointing an outside expert to 

advise the school, and restructuring the school’s internal organization. The findings from CEP 

dovetail with the findings reported here, especially in terms of states accelerating the process 

through which consequences and supports are applied and extended to schools struggling to 

make their AYP targets (CEP 2009b).

Some states used federal funds, such as Title I or School Improvement 

Grants, or state funding to establish new positions and additional services 

to support the implementation of differentiated accountability.

In addition to federal funding provided to Title I schools under section 1003(a) of the ESEA, the 

Department provides additional funds called School Improvement Grants (SIGs; ESEA section 

1003(g)) for Title I schools in Improvement, Corrective Action, or Restructuring. States receive 

funding from the Department based on a formula. At the time the differentiated accountability 

pilot began, states had discretion as to whether they awarded SIG funds to their districts based on 

a formula or competition. Since the publication of final requirements for the SIG program in 

December 2009, however, states have been required to award SIG funds through a competition. 
Early Implementation 16 

States that are awarded SIG funds may retain 5 percent of the funds for administrative needs and 

technical assistance.

With its differentiated accountability model, Georgia reported using 1003(g) funds to place a 

state director in all SINI 5 and above schools (43 schools as of December 2009). State directors 

provided daily, on-site technical assistance, assisting with mentoring and coaching, data 

collection and analysis, and the ongoing implementation of interventions. State directors were 

directly involved in all school improvement and restructuring processes, including the replacing 

of staff and providing classroom support for teachers and administrative guidance to the 

principal. The state Title I director explained that the goal with the Georgia Assessment of 

Performance on School Standards (GAPSS) review was to ensure that a school would have in 

place the elements necessary for sustaining its improvement once it exited improvement status. 

GAPSS is a system of online surveys, classroom observations of teachers, and on-site interviews 

by which schools can determine their performance on school standards, such as curriculum; 

instruction; assessment; planning and organization; student, family, and community support; 

professional learning; leadership; and school culture. 

Florida used differentiated accountability to create new regional support centers to house teams 

of specialists who worked in the lowest-performing schools conducting instructional reviews and 

reviewing school improvement plans and district intervention assistance plans. The regional 

support teams provided technical assistance to all schools in improvement status on data 

collection and targeted professional development addressing academic areas and subgroup needs. 

The director of support services at the state department of education explained that the staff from 

the five regional support centers provided direct support to schools in the Intervene category and 

to the lowest-performing Category II schools (i.e., schools meeting 80 percent of their AYP 

indicators) and that the state supported the centers through Title I funding and Individuals with 

Disabilities Education Act (IDEA) funds. Schools designated for less intensive interventions—

Prevent I and Correct I schools (i.e., schools meeting less than 80 percent of their AYP 

indicators)—also received services, though the support from the regional centers was indirect. 

One district Title I director stated that her district also used its Title I and IDEA funds to support 

the addition of math, science, and reading coaches at all Correct I and II schools (full-time 

employees at each school) and Prevent I and II schools (shared among schools). 

Similar to Florida and Georgia, Arkansas established new types of positions to work directly in 

schools providing classroom support and monitoring compliance. To support its differentiated 

accountability plan, the state used 1003(a) funds to create three new types of positions to 

intensify support services for schools in improvement: instructional facilitators to provide 

classroom support; school improvement specialists to provide building-level support by 

monitoring compliance, coordinating school improvement strategies, and facilitating researchbased instructional practices; and school improvement directors (provided by the state or district) 

to work with state-directed schools. 

Maryland created its Breakthrough Center in 2008 specifically to support its differentiated 

accountability model. According to the state service provider’s director, the newly established 

Breakthrough Center was created in anticipation of approval of the state’s differentiated 

accountability waiver. Officials wanted to have a mechanism in place to begin providing services 

in July and August 2008 to support the start of the 2008–09 school year and the implementation 
Early Implementation 17 

of differentiated accountability. In addition to offering direct services to schools and districts in 

the areas of strategic planning, curriculum alignment, and leadership development, the center 

functions as a broker of services. The center assists districts in integrating available public and 

private services by maintaining a network of specialized service providers that can develop 

customized services for schools. In collaboration with school districts, the center develops 

partnership agreements to support low-performing schools in various ways, including the 

targeting of professional development for teachers in reading/English language arts and the 

alignment of curriculum, instruction, and assessment in schools and at the district level. 

Maryland initially funded the Breakthrough Center with Title I and Title II funds and State 

School Improvement Grants (SSIGs), funded by the Maryland General Assembly.3 Budget cuts 

reduced this funding, but the state used a grant from the National Governors’ Association to 

direct additional funds to the center. The state legislature also approved the use of Qualified 

Zone Academy Bonds—a program of the Department providing funding for renovating school 

buildings, purchasing equipment, developing curricula, and training school personnel—for the 

development of the center. The center was also eligible for special education funds because it 

provided professional development and support services to teachers of students with disabilities. 

With the support of additional federal and state funding, states proposed an array of services in 

their differentiated accountability applications and incorporated or expanded a number of 

services already in place in their statewide accountability systems to support low-performing 

schools. They also outlined ideas for new services to enhance those already in place; where 

services were modified or improved, respondents found it difficult to separate with certainty new 

services from enhanced services. Exhibit 7 summarizes the data reviewed from state applications 

and interviews, specifying, by state, the various state support services that were either newly 

established or coordinated with existing services to support the implementation of differentiated 

accountability.

Exhibit 7

Selected support services newly established or coordinated

to support implementation of differentiated accountability, by state

Selected support services ARa FLb GAb ILb INb LAa MDb NYa OHb

Regional/state service centers — N C C — C N C C

Statewide leadership academies C — C — N — — — —

Statewide curriculum academies — — — — N — — — —

On-site support positions N N N — — — — C —

State/regional/district support teams C N N — C C — — C

Exhibit reads: Florida and Maryland created new service centers, while Georgia, Illinois, Louisiana, New York, and 

Ohio coordinated the services of existing service centers.

— Not applicable.

a ED approved states’ differentiated accountability plans in January 2009.

b ED approved states’ differentiated accountability plans in July 2008.

NOTE: C = coordinated services; N = newly established services.

SOURCE: State differentiated accountability applications submitted to ED in 2008; November 2009–January 2010 interviews.

 

3 Title II contains funding for teacher and principal training and recruitment efforts at the state and local level, as 

well as teacher training at institutions of higher education.
Early Implementation 18 

Changes in Implementation of Differentiated Accountability Plans 

State respondents reported that although they tried to adhere to the differentiated accountability 

plans laid out in their state’s original proposal, a variety of circumstances led them to deviate 

from these plans. This section summarizes these changes and the reported reasons behind the 

changes.

Implementation of the differentiated accountability plans varied across the 

pilot states.

Some states reported a variety of circumstances—including short implementation time lines, 

shifting priorities and budget issues, and changes in leadership—as reasons to modify or delay 

the implementation of their differentiated accountability plans. For example, two states, Illinois 

and New York, had delayed full implementation of differentiated accountability while they 

reconsidered their models and the states’ capacity for providing direct support. State officials in 

Illinois cited budget issues as the reason for delays with fully implementing differentiated 

accountability, explaining that they have the new school improvement categories in place, but 

little else. One state support provider in New York explained that the state had not fully initiated 

differentiated accountability at the time of this study but that his office has conducted school 

quality reviews for schools in Improvement Years 1 and 2 and was assisting with curriculum 

audits for schools in Corrective Action. 

The New York state Title I director reported that technical assistance services had not been 

maximized and that support services had not expanded much in the past year due to the state’s 

fiscal crisis. The regional centers were in the final year of their contract, and the state was 

concerned that, facing uncertainty, many regional center staff had begun to look for work 

elsewhere. Financial concerns limited the state’s efforts to move forward with full 

implementation of its plan to get school districts engaged in differentiated accountability. The 

Title I director agreed, however, with one state service provider, who expressed satisfaction that 

differentiated accountability was driving the way schools and districts are identified and guiding 

service efforts. He recommended the tiered approach because, by knowing whether a school 

needs “focused, basic, or comprehensive triage for one specific [subpopulation] or . . . the entire 

school,” his staff can determine how to target their efforts.

Illinois state officials also reported that, because of funding cuts, plans to integrate differentiated 

accountability into school improvement plans had been put on hold. The only differentiated 

accountability modifications in place thus far were the renaming of the school improvement 

categories and the switching of SES and school choice, which only a small number of districts 

had opted to do. Illinois officials also mentioned that shifting state priorities required less 

emphasis on differentiated accountability. Since submitting its differentiated accountability

application, Illinois turned its attention to its participation in the Partnership Zone, a publicprivate partnership with five other states (including Louisiana and New York) to develop longterm reform strategies for their lowest-performing schools, such as placing turnaround leaders 

directly in the schools. 

In Indiana, the implementation of differentiated accountability coincided with a change of 

leadership in the state superintendent’s office. The new state leadership was tasked with 
Early Implementation 19 

developing and implementing a theory of action aligned with Indiana’s differentiated 

accountability plan. In response, the Office of Title I Academic Support in the Indiana 

Department of Education developed a theory of action model on transforming high-poverty 

districts to high-performing districts based on seven research-based components, culled from a 

review of the research on school turnaround efforts (AIR 2005; Barr and Parrett 2007; U.S. 

Department of Education 2008; Mass Insight Education and Research Institute 2007; Resnick 

and Glennan 2002). These components are high expectations, leadership, instruction, curriculum, 

formative assessments, professional development, and community partnerships. 

The state Title I director in Indiana indicated that the goal of her staff was to offer supporting 

activities for schools corresponding to the seven components. The state Title I staff provides 

training to district representatives on implementing these components in their district plans; for 

example, the office has hosted a summer conference and created online modules focused on 

subgroup performance (that a district facilitator can lead), developed diagnostic tools and trained 

local data coaches on the use of the tools, and helped districts hire mentors for promising 

principals. One district’s Title I director felt that the alignment of state and local differentiated 

accountability goals was critical to the success in implementing differentiated accountability. 

With input from the new superintendent, Indiana opted to offer both SES and school choice in 

Year 1 of school improvement, rather than reverse them, as indicated in Indiana’s originally 

approved application. 

Maryland also had undergone budget cuts resulting in a reduced state department staff and statemandated furloughs. To alleviate financial burdens for districts, the state Title I director 

explained that the state “softened its expectations” for districts to conduct a “nationally 

recognized” school climate survey and instead allowed districts to use any reliable instrument to 

conduct the survey. 

Most pilot states (seven out of nine) felt they did not have enough time 

between the approval of their differentiated accountability application and 

the start of the next school year to put all the pieces in place to support full 

implementation.

Title I directors from seven pilot states discussed the short time line between notification of 

approval of their waivers and the start of the next school year. States notified in June 2008 for a 

fall 2008 start and those notified in January 2009 for a fall 2009 start expressed the same 

thoughts—neither cohort felt it had enough time to prepare for implementation of its 

differentiated accountability plans. The state Title I director from Arkansas emphasized that, if 

differentiated accountability is offered again, “other states would appreciate having a longer time

line.” 

Along with new improvement categories, pilot states proposed new services and, in some cases, 

new positions to support their differentiated accountability plans. Putting it all in place proved 

challenging, and states reported that logistics were a problem. The Arkansas Title I director 

mentioned the difficulty in providing the training necessary for new state facilitators, and the 

Florida director mentioned last-minute staffing changes that had to occur due to the new school 

classification system.
Early Implementation 20 

In Georgia, schools and districts had already sent parent notification letters regarding options for 

school choice and SES, which required follow-up notifications with new guidelines. One rural 

elementary school principal said that he had a very short time in which to prepare his faculty for 

their new state-directed label. One Indiana principal reported that, with such “a time frame 

crunch,” he first concentrated on offering workshops to help the parents in his community 

understand the impact of the changes on the school and their children. 

Title I directors in Georgia and Louisiana both reported that they were able to implement their 

differentiated accountability plans, but that they felt they did not have enough time to prepare 

districts fully for the changes that accompanied differentiated accountability. The New York 

Title I director said the state was still in a planning phase, though the state had informed schools 

of the new school improvement categories, especially in cases where schools shifted into new 

categories.
Challenges and Lessons Learned 21 

Challenges and Lessons Learned

Study participants in eight pilot states indicated that they would recommend differentiated 

accountability to other states interested in the flexibility it offers. Illinois was not as enthusiastic 

as other pilot states because of state budget constraints and competing priorities. Illinois had not 

fully implemented differentiated accountability but was encouraging regional service provider 

organizations and school districts to work directly with schools in lieu of state involvement in 

order to deliver services to the over 800 districts in the state. 

While most of the actions and improvements attributed to differentiated accountability were 

already permissible under ESEA, participants felt that focusing on differentiated accountability 

provided the impetus or renewed enthusiasm to coordinate state and federal accountability plans. 

From their experiences implementing differentiated accountability, the study participants offered 

the following recommendations for undertaking any sweeping change in practice and policy: 

seek buy-in from all stakeholders, including staff at both the state and local levels, and be 

prepared to provide and accept assistance from external service providers.

State and local administrators reported challenges in garnering buy-in 

regarding the implementation of differentiated accountability.

In Arkansas, the Title I director and an elementary school principal from one district explained 

that the local school board had initiated districtwide change when it was directed by the state to 

adopt America’s Choice as the district’s K–12 school improvement initiative, a move for which 

teachers were unprepared. They both confirmed that they were meeting more often with district 

and building staff to gather input and ensure their staffs that they would be participating in sitebased decision making throughout the ongoing implementation process. The principal mentioned 

having the support of cluster leaders and instructional facilitators in her building to assist her in 

meeting with teachers and assuring them of the supports available to them. She reported that 

when she encouraged her teachers to set up their own professional learning communities, the 

teachers appreciated the control they had in designing their own professional development. 

One Florida district Title I director explained that one of her greatest challenges was the lack of 

receptiveness of some school and district leaders to differentiated accountability. She commented 

that, to ensure district buy-in, the district established a curriculum team so that decisions about 

instruction and interventions included input from the district reading specialist, the mathematics 

specialist, the director for high schools, the director for middle schools, and the technology team. 

She felt that this approach allowed the district to take a more comprehensive view of districtwide 

issues and coordinate the support provided to schools. 

In New York, district staff suggested that it was too early in the process to assess the impact of 

differentiated accountability but confirmed that it had been a challenge eliciting buy-in from 

principals when differentiated accountability prompted a shift of many schools from one 

improvement category to another. The Title I director in Ohio commented that the state’s 

greatest challenge was changing districts’ mind-sets but felt that the state garnered district buy-in 

when local educators realized that the district was not only accountable for district outcomes but 

also for developing the strategies for achieving those outcomes. 
Challenges and Lessons Learned 22 

State and local administrators reported having to defuse resistance to 

technical assistance in order to implement new services.

Instructional specialists from the Florida regional support centers encountered initial resistance 

in the low-performing schools, but this resistance lessened as the school staff came to recognize 

the skills and expertise of these individuals. One state support provider related that teachers 

began to accept the on-site specialists as partners rather than adversaries, but it took one year to 

develop that trust. 

One Georgia school principal advised other principals dealing with staff resistance to study the 

federal and state models in order to explain the process clearly and confidently when introducing 

differentiated accountability to staff. His school had a state director on-site daily, and many of 

his teachers were new to the process of restructuring and resisted the differentiated 

accountability interventions. The state support provider in Georgia confirmed this situation, 

explaining that “not everyone welcomes us with open arms,” but the support of the principal can 

have a positive influence on the attitude of the faculty. The principal recognized the advantage of 

the on-site support and explained that having a state director assigned to his school provided him 

with daily mentoring, guidance, and monitoring of his school improvement plan. 

In Ohio, state and local study participants supported the state’s decision to implement 

differentiated accountability and align school improvement interventions with school needs. One 

school principal explained that differentiated accountability is “a road map that has shown us 

exactly where we need to go, and has provided us with the tools that we need to get there. So it’s 

the ‘where’ and the ‘how’.” She was referring to the fact that differentiated accountability in 

Ohio did not mandate a step-by-step protocol but instead continued set performance goals for 

schools and showed schools how to use their own data to propose appropriate interventions for 

school improvement. One state support provider added that this represented a shift of 

responsibility for interventions from the state to the districts, so that schools viewed the state as a 

partner rather than a monitor.

Pilot states focused on building capacity at the local level.

Pilot states created or expanded a number of academies and institutes that focused on developing 

leadership skills and content knowledge of teachers and administrators at the local level. Several 

state leaders mentioned the importance of investing in human capital, and the pilot states 

provided an array of professional development opportunities that demonstrated their commitment 

to this idea.

The Title I director in Arkansas described the state’s differentiated accountability application as 

being “heavily embedded with leadership opportunities for superintendents, principals, and 

teachers.” The Arkansas general assembly appropriated funds for the Arkansas Leadership 

Academy prior to differentiated accountability, but, in an effort to maximize capacity, the state 

created a second academy using a train-the-trainers model that operated within schools providing 

on-site, ongoing leadership training. 

Indiana’s Leadership Institute paired a principal from one of the 20 lowest-performing schools in 

the state with a principal from a high-performing, high-poverty school, who served as a mentor. 

One principal who participated in the institute credited the experience with extending his 
Challenges and Lessons Learned 23 

personal and professional growth and improving his effectiveness as a principal. The state Title I 

director said that district superintendents requested involving more schools in the institute and 

reported that they see their schools being transformed by principals who have attended the 

institute. Georgia also offered two leadership academies for staff in low-performing schools, and 

Maryland indicated it is planning to build leadership capacity across the state through its 

Breakthrough Center. 
Challenges and Lessons Learned 24 

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Conclusions 25 

Conclusions

Interviews conducted in the nine pilot states found that these states reported using the flexibility 

provided under differentiated accountability to modify their accountability models to distinguish 

between low- and high-performing schools. State respondents also reported that their states 

expanded, realigned, or created support structures in order to implement earlier interventions and 

more comprehensive services. States took different approaches to implementing differentiated 

accountability; most created new school improvement categories, while one state opted to simply 

rename the existing ESEA categories. Many states reported focusing on building capacity at the 

local level to assist districts and schools in ongoing school improvement planning. 

Differentiated accountability was not implemented evenly across the participating states. Some 

reasons are logistical. Maryland, for example, has only 24 school districts, and the state 

superintendent hosts a weekly conference call with all local superintendents. New York, on the 

other hand, has 836 local districts with which to communicate, and for that state, dissemination 

of information in a timely manner is challenging. Some states, such as Georgia and Ohio, had 

regional service centers in place prior to differentiated accountability and were able to coordinate 

state and regional activities necessary to support differentiated accountability and prevent 

overlap. Seeing such a need, Florida created a regional support system to assist the state in 

delivering services. Still others, like New York and Illinois, reported a lack of commitment and 

interest in continuing to implement differentiated accountability as they first proposed. 

Most changes made under differentiated accountability were allowable prior to the waiver. The 

only significant exception was that differentiated accountability allowed states to offer 

supplemental educational services one year earlier and to count the costs of doing so toward a 

district’s “20 percent obligation,” an option selected by seven of the nine states.

4 The waiver did 

not provide additional funding, nor did it grant permission for states to use new approaches in 

determining AYP. Nonetheless, state respondents reported that implementing differentiated 

accountability encouraged them to employ new strategies for promoting and supporting school 

improvement and to target more intensive services to schools with the greatest needs. 

 

4 The “20 percent obligation” represents the amount of unspent Title I funding during a given school year that a 

school district must spend in a subsequent school year on public school choice-related transportation and 

supplemental educational services.
Conclusions 26 

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References 27 

References

American Institutes for Research (AIR). 2005. Toward more effective school districts: A review 

of the knowledge base. Washington, DC: American Institutes for Research. 

Barr, R. D., and W. H Parrett. 2007. The kids left behind: Catching up the underachieving 

children of poverty. Bloomington, IN: Solution Tree. 

Center on Education Policy (CEP). 2009a. Intensified support: Changes in school restructuring 

in Georgia under the No Child Left Behind Act. Washington, DC: Center on Education 

Policy.

———. 2009b. Mining the opportunities in “differentiated accountability”: Lessons learned 

from the No Child Left Behind pilots in four states. Washington, DC: Center on Education 

Policy.

Mass Insight Education and Research Institute. 2007. The turnaround challenge. Boston, MA: 

Mass Insight Education and Research Institute. 

Resnick, L., and T. K. Glennan. 2002. Leadership for learning: A theory of action for urban 

school districts. In School districts and instructional renewal, ed. A. Hightower, M. Knapp, 

J. Marsh, and M. McLaughlin, 160–172. New York: Teachers College Press.

U.S. Department of Education, Institute of Education Services (IES). 2008. Turning around 

chronically low-performing schools. Washington, DC: U.S. Department of Education, 

Institute of Education Services. 
References 28 

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Appendix A 29 

Appendix A:

State Differentiated Accountability Models

Under differentiated accountability, the school improvement categories and related interventions 

were intertwined, and each pilot state’s efforts were different. To provide a coherent picture of 

how differentiated accountability was implemented in each state, this section details each state’s 

differentiated accountability implementation progress and how the key findings were illustrated 

in each state’s approach.

Arkansas 

In 2006, Arkansas developed the Arkansas scholastic audit to analyze strengths and limitations 

of a school’s instructional and organizational effectiveness and make specific recommendations 

to improve teaching and learning. The audit served as the foundation for Arkansas’s proposal for 

the differentiated accountability model, which expanded participation in the audit and aligned a 

matrix of interventions to the audit standards. To coordinate responsibilities and utilize local 

expertise, Arkansas assigned schools and districts with the responsibility of conducting and 

monitoring their own audits for schools in the lowest three tiers of improvement, which needed 

assistance the least, and required schools in the more intensive improvement levels to develop 

school improvement plans with support from regional teams or state specialists.

At the time Arkansas submitted its request for a differentiated accountability waiver, 30 percent 

of Arkansas’s schools were in some level of improvement for reasons that varied from one 

subgroup missing a single adequate yearly progress (AYP) indicator to most subgroups missing a 

number of indicators. Arkansas proposed a model to distinguish between these schools by 

applying different labels and different consequences to schools appropriate to their actual school 

improvement status (see Exhibit A.1). Schools in Need of Improvement, Year 1 (SINI 1), 

through SINI 3 were categorized as Targeted Improvement, Intensive Targeted Improvement, or 

Whole-School Improvement, respectively. 

In its differentiation model, Arkansas compared the number of subgroups missing AYP 

indicators with the total number of subgroups measured using a measure called the Elementary 

and Secondary Education Act of 1965 (ESEA) performance ratio, which indicates the ratio of 

subgroups missed to the number of subgroups eligible. Arkansas selected a performance ratio of 

75 percent to distinguish schools in its differentiated accountability model. The model 

incorporated the Arkansas benchmark exam scores from the state NCLB accountability plan on 

file and categorized schools based on both the number of years and the extent of the reasons they 

did not make AYP. The improvement category for each school in the state was noted on the state 

website, with links to subgroup and intervention information specific to the categories. 

Exhibit A.2 provides a summary of Arkansas’s new improvement categories and related 

interventions. 
Appendix A 30 

Exhibit A.1

Arkansas differentiated accountability model categories, by Title I designation

State differentiated 

accountability 

categories

Title I: 

designation: 

missed AYP 

zero or 

one year

Title I: 

designation: 

Improvement, 

Year 1 

(SINI 1)

Title I: 

designation: 

Improvement, 

Year 2 

(SINI 2)

Title I: 

designation: 

Corrective 

Action 

(SINI 3)

Title I: 

designation: 

Restructuring, 

Planning 

(SINI 4)

Title I: 

designation: 

Restructuring, 

Implementation 

(SINI 5+)

Achieving Schools •

Targeted 

Improvement • • • 

Intensive Targeted 

Improvement • • • 

Whole-School 

Improvement • • • 

Intensive WholeSchool 

Improvement

 • • •

Exhibit reads: In Arkansas, Schools in Need of Improvement, Year 1 (SINI 1), under Title I are now labeled either 

Targeted Improvement, Intensive Targeted Improvement, or Whole-School Improvement.

NOTE: AYP = adequate yearly progress. ED approved Arkansas’ differentiated accountability plan in January 2009; Appendix C 

contains explanations of differentiated accountability categories.

SOURCE: Arkansas differentiated accountability application submitted to ED in 2008, December 2009 and January 2010 interviews, 

and state website (http://arkansased.org/smart_accountability.html).

In addition to required interventions outlined in the Arkansas differentiated accountability plan, 

schools in the Targeted and Intensive Targeted Improvement categories selected one additional 

intervention from a state-designated list, updated and revised for the pilot. Schools in Intensive 

Whole-School Improvement selected one additional restructuring action from a state-designated 

list available in the Arkansas differentiated accountability resource guide. Additional 

interventions included such actions as scheduling a scholastic audit, providing preschool options, 

extending learning time for students lacking sufficient progress in mathematics and literacy, and 

subcontracting with recognized educators to assist with data analysis, observations, and 

mentoring. The resource guide is an online tool that provides a comprehensive review of 

Arkansas’s differentiated accountability model, including descriptions of the new differentiated 

accountability labels and differentiation, interventions, and available support and resources 

appropriate to schools in the new school improvement status categories. 

The state matched its improvement labels to a tiered system of both previously used and new 

research-based interventions, and focused on providing services to students and building the 

capacity of schools and districts. Through an approach based on standards of effective schools, 

the most-intensive efforts occurred at those schools that had remained in school improvement for 

four years or more.
Appendix A 31 

Exhibit A.2

Arkansas differentiated accountability categories, by determination and corresponding 

intervention(s)

School categories Determination Interventions

Achieving Schools meet adequate yearly 

progress (AYP) and 

continue to work toward 

having all students proficient 

by school year 2013–14.

None.

Targeted 

Improvement

Schools have 75 percent or 

greater of subpopulations 

meeting annual measurable 

objectives (AMOs) but have 

one or more subpopulations 

not meeting AMOs for two to 

four consecutive years.

Schools develop their own plans to address 

student needs and access support, 

professional development, and monitoring from 

the state.

Intensive Targeted 

Improvement

Schools have 75 percent or 

greater of subpopulations 

meeting AMOs and one or 

more subpopulations not 

meeting AMOs for four or 

more consecutive years.

Schools develop a three-year school improvement 

plan that must include professional 

development to increase the intensity of their 

core reading and math instruction. All schools 

that feed into a targeted improvement school 

must participate in the same interventions.

Whole-School 

Improvement

Schools have either the All 

Students group not meeting 

AMOs or less than 75 

percent of subpopulations 

meeting AMOs and one to 

three years of school 

improvement status.

Schools are self-directed but must work in 

collaboration with regional teams to develop a 

three-year school improvement plan to address 

areas of deficiencies. The district is responsible 

for conducting a school audit, and a regional 

team monitors the progress of the plan and 

provides technical support for implementation. 

All feeder schools participate in the same 

intervention.

Intensive WholeSchool 

Improvement

Schools have the All Students 

group not meeting AMOs 

and/or less than 75 percent 

of subpopulations meeting 

AMOs and four or more 

years of school 

improvement status.

Schools work with a state-approved provider and 

follow more prescriptive guidelines regarding 

organizational structure, professional 

development, curriculum and instruction, and 

use of resources to address growth needs 

noted in the state audit. The state uses 

formative and summative assessments of 

student progress to monitor these schools for 

fidelity of the alignment of the instructional 

curriculum to the state frameworks document.

Exhibit reads: Achieving Schools meet AYP and continue to work toward having all students proficient by school 

year 2013–14. They have no assigned interventions.

NOTE: ED approved Arkansas’ differentiated accountability plan in January 2009.

SOURCE: Arkansas differentiated accountability application submitted to ED in 2008.

Under differentiated accountability, the state created three new types of positions to intensify 

support services for schools in improvement: instructional facilitators to provide classroom 

support; school improvement specialists to provide building-level support by monitoring 

compliance, coordinating school improvement strategies, and facilitating research-based 

instructional practices; and school improvement directors (provided by the state or district) to 

work with state-directed schools. The state also expanded the role of its regional education 
Appendix A 32 

service centers, using them to provide professional development directly aligned with the 

interventions available under the state’s differentiated accountability model. Before 

implementing differentiated accountability, the statewide system of support included state 

support teams comprising math, literacy, science, special education, and English Learner (EL) 

specialists, but under differentiated accountability, the state integrated the support teams into its 

new service model to expand and coordinate their services to more schools. The state also 

increased the capacity of its Leadership Academy by adding a regional training facility that 

provided leadership training to build capacity at the school level. 

To support state reform efforts, Arkansas contracted with America’s Choice, a for-profit provider 

of comprehensive school and instructional design services, technical assistance, and teacher 

professional development. Before Arkansas implemented differentiated accountability, 

America’s Choice operated only in low-performing schools, but after implementing 

differentiated accountability, the state opened America’s Choice trainings and workshops to all 

schools in the state. Schools in the early stages of improvement, with just a few subgroups 

missing one or more AYP indicators, then had access to training in the use of data and 

assessment, leadership, best practices, and research-based school improvement strategies. 

Florida 

Under differentiated accountability, Florida consolidated its state accountability model with the 

federal model to create new improvement categories (see Exhibit A.3). Florida’s state 

accountability system, School Grades, assigns points to schools based on demonstrated student 

proficiency in four subject areas (math, reading, writing, science) and student-learning gains in 

four component areas (two for math and two for reading). Florida uses the results to assign letter 

grades A–F to schools. The state model does not address subgroup performance. The 

differentiated accountability model consolidated Title I schools in need of improvement into two 

groups, separating schools in SINI 1–3 from those in SINI 4 and beyond and differentiating

schools in these two groups based on a combination of School Grades performance and 

percentage of AYP criteria met.

To determine its differentiated accountability categories, Florida first categorized schools based 

on performance (Category I or II). Schools in Category I were A-, B-, and C-graded schools that 

met at least 80 percent of the AYP performance criteria. Category II included schools that met 

less than 80 percent of AYP criteria, as well as all D- and F-graded schools. Once categorized, 

schools were further labeled Prevent, Correct, or Intervene. Schools in Prevent I or Prevent II 

were in SINI 1–3, schools labeled Correct I, Correct II or Intervene were the most critical, in 

SINI 4 and beyond. In 2007, the state identified 24 Intervene schools as the worst-performing 

schools since 2003 based on school grades and continued poor performance in reading and 

mathematics.
Appendix A 33 

Exhibit A.3

Florida differentiated accountability model categories, by Title I designation

State differentiated 

accountability 

categories

Title I 

designation: 

missed AYP

zero or 

one year

Title I 

designation: 

Improvement, 

Year 1 

(SINI 1)

Title I 

designation: 

Improvement,

Year 2 

(SINI 2)

Title I 

designation: 

Corrective 

Action

(SINI 3)

Title I 

designation: 

Restructuring, 

Planning 

(SINI 4)

Title I 

designation: 

Restructuring, 

Implementation 

(SINI 5+)

Prevent I • • •

Correct I • • •

Prevent II • • •

Correct II • • •

Intervene • • •

Exhibit reads: In Florida, Schools in Need of Improvement, Year 1 (SINI 1), under Title I are now labeled Prevent I or 

Prevent II schools.

NOTE: AYP = adequate yearly progress. ED approved Florida’s differentiated accountability plan in July 2008; Appendix C contains 

explanations of differentiated accountability categories.

SOURCE: Florida differentiated accountability application submitted to ED in 2008, November and December 2009 interviews, and

state website (http://flbsi.org/DA/).

In Florida, Category I schools required interventions for subgroups, and Category II schools 

required schoolwide interventions. Initiated under differentiated accountability, these new 

categories assisted schools in identifying their needs in Year 1 of missing AYP and planning 

interventions earlier. This included implementing Response to Intervention (RtI), an instructional 

approach that identifies students with disabilities and provides early intervening services to 

struggling students. 

Under the School Grades system, Florida did not rate schools based on subgroup performance; in 

contrast, the Title I AYP requirements under NCLB measuring subgroup performance resulted in 

very different school ratings. For the first time, some schools that had earned a letter grade of A 

learned that they did not make AYP under the new guidelines, often due to the performance of a 

single subgroup. Using differentiated accountability labels, this was evident from the data for 

subgroups in Category I schools (see Exhibit A.4a and Exhibit A.4b), showing that students with 

disabilities represented the highest percentage of subgroups missing AYP in Category I schools. 

One trend of note in Florida is that, while the percentage of student enrollment in the low-income 

subgroup was fairly consistent across all school improvement categories, the performance of this 

subgroup was not. 
Appendix A 34 

Exhibit A.4a 

Percentage of Florida schools, by select student subgroups

that did not make AYP in reading

Differentiated 

accountability

categories Total

All 

students

Lowincome EL SWD White Black Hispanic AsianNative 

American Multi

Prevent Ia 205 11% 13% 6% 33% 0% 19% 5% — — —

Correct I 519 23% 26% 12% 35% 3% 31% 10% — — —

Prevent II 29 90% 90% 48% 59% 28% 79% 55% — — —

Correct II 253 93% 92% 42% 70% 15% 79% 45% — — —

Intervene 11 91% 91% 9% 64% 9% 100% 18% — — —

Exhibit reads: In 2008–09 in Florida, the All Students subgroup missed adequate yearly progress (AYP) in reading in 

11 percent of the 205 Prevent I schools.

— Not available.

a Of the 205 schools in Prevent 1, some are in this category for reasons other than reading AYP (e.g., attendance or graduation

rates).

NOTE: EL = English Learner; Multi = multiracial; SWD = students with disabilities. ED approved Florida’s differentiated 

accountability plan in July 2008; Appendix C contains explanations of differentiated accountability categories.

SOURCE: Data extracted from state report submitted to ED in December 2009. (Pilots awarded in 2008 were required to submit a 

report to ED in December 2009 detailing how schools were labeled under the new system developed for differentiated 

accountability.)

Exhibit A.4b

Percentage of Florida schools, by select student subgroups

that did not make AYP in math

Differentiated 

accountability 

categories Total

All 

students

Lowincome EL SWD White Black Hispanic AsianNative 

American Multi

Prevent Ia 205 20% 34% 9% 36% 6% 26% 8% — — —

Correct I 519 39% 44% 13% 35% 8% 36% 16% — — —

Prevent II 29 100% 93% 48% 55% 31% 72% 55% — — —

Correct II 253 96% 94% 42% 69% 22% 77% 48% — — —

Intervene 11 82% 82% 9% 64% 18% 82% 18% — — —

Exhibit reads: In 2008–09 in Florida, the All Students subgroup missed adequate yearly progress (AYP) in math in 

20 percent of the 205 Prevent I schools.

— Not available. a Of the 205 schools in Prevent 1, some are in this category for reasons other than math AYP (e.g., attendance or graduation rates).

NOTE: EL = English Learner; Multi = multiracial; SWD = students with disabilities. ED approved Florida’s differentiated 

accountability plan in July 2008; Appendix C contains explanations of differentiated accountability categories.

SOURCE: Data extracted from state report submitted to ED in December 2009. (Pilots awarded in 2008 were required to submit a 

report to ED in December 2009 detailing how schools were labeled under the new system developed for differentiated 

accountability.)

For each improvement classification in Florida, the state defined a program of support services 

and interventions that included specific interventions for attaining the benchmarks and executing 

the school improvement plan; roles for the school, district, and state in preparing, directing, 

implementing, and monitoring the plan and reporting progress; measurable benchmarks for 

determining the progress of the plan; and consequences for noncompliance with requirements. 

Under differentiated accountability, Florida created regional support centers housing teams of 

specialists who work in the lowest-performing schools, conduct instructional reviews, and 

review school improvement plans and district intervention assistance plans. The regional support 
Appendix A 35 

teams provided technical assistance to all schools in improvement status on data collection and 

targeted professional development, addressing academic areas and subgroup needs. The teams 

comprised regional leaders, school improvement facilitators, and connecting partners. Regional 

leaders were change agents with a prior success record of improving student performance in 

demographically similar schools. They supported school improvement efforts in the region, built 

district capacity, provided and brokered professional development, and coached and mentored 

school principals and the school and district leadership teams. School improvement facilitators

were experts in primary and secondary curricula and pedagogy and had content-area knowledge. 

Facilitators supported the development and evaluation of district and school improvement plans, 

monitored the implementation of interventions, and provided other school improvement support 

services. Connecting partners brokered services and supports already in place to districts and 

schools, such as Reading First and RtI. Schools designated for less intensive interventions—

Prevent I and Correct I schools—also received services, though the support was indirect. The 

regional centers worked with the districts to build local capacity to help these schools.

According to the state Title I director, implementing differentiated accountability was a factor in 

allowing the state to widen the sources of support offered to schools. For example, whereas the 

state Title I office was the only source of school improvement support prior to differentiated 

accountability, schools were now able to receive this kind of support through the five regional 

centers. As a result, instead of having to go through the state office, school districts were now 

able to directly contact the five regional offices for services. In addition, as opposed to the past, 

school improvement interventions for schools labeled as A, B, or C were specifically targeted as 

described above. Finally, whereas in the past, State facilitators performed only a monitoring 

function in schools and did not provide direct support, regional centers were now able to provide 

instructional specialists to work directly in schools, for example, through the training of reading 

and math coaches.

The state Title I director felt that establishing the five regional centers and staffing them with 

regional directors and instructional specialists helped the Florida Department of Education move 

services closer to the schools. School districts were able to request services from centers close to 

them that are staffed with specialists who could respond more quickly than could the limited 

staff of the state. 

The roles of the school, district, and state were defined separately for each differentiated 

accountability classification of schools (see Exhibit A.5). The authority and responsibility to 

direct support and intervention shifted from the school to the district and then to the state as 

school classifications moved from Category I to Category II and from Prevent to Correct status. 
Appendix A 36 

Exhibit A.5

Florida school, district, and state support roles, by differentiated accountability categories

Differentiated 

accountability categories School role District role State role

Prevent, Category I School directs 

intervention.

District provides assistance. State reviews progress 

(monitors and reports).

Correct, Category I School complies with 

district-determined 

measures.

District directs intervention 

and provides assistance.

State reviews progress 

(monitors and reports).

Prevent, Category II School complies with 

district-determined 

measures.

District directs intervention 

and provides planning 

and assistance.

State provides assistance, 

monitors, and reports.

Correct, Category II School complies with 

district-directed 

interventions.

District complies with statedirected interventions.State directs intervention 

through the district, 

monitors, and reports.

Intervene School complies with 

district-directed 

interventions.

District complies with statedirected interventions.State directs intervention 

through the district, 

monitors, and reports.

Exhibit reads: For Florida schools in the Prevent I category, the school directs its intervention, the district provides 

assistance in implementing the intervention, and the state reviews the progress of the implementation.

NOTE: ED approved Florida’s differentiated accountability plan in July 2008; Appendix C contains explanations of differentiated 

accountability categories.

SOURCE: Florida differentiated accountability application submitted to ED in 2008; November and December 2009 interviews. 

Georgia 

In its differentiated accountability application, Georgia reversed the years in which supplemental 

education services (SES) and school choice were first offered, and developed three tiers within 

the Corrective Action category (SINI 3) in order to better match interventions to specific 

identified needs in these schools. For schools in this category, the state determined a school’s 

distance from the state’s annual measurable objectives (AMOs) and then placed the highestperforming 20 percent of schools in Tier 1, the middle 60 percent in Tier 2, and the bottom 

20 percent in Tier 3. Schools in SINI 1 and SINI 2 remained in improvement, while schools in 

SINI 4 and beyond were labeled State-Directed (see Exhibit A.6). 

Concurrent with filing its request for differentiated accountability, Georgia was updating its 

single statewide accountability system (SSAS) to collapse its consequence and intervention 

structure in order to reach schools sooner and resolve outstanding deficiencies more quickly, a 

decision in line with the goals of differentiated accountability. As part of this effort, the state 

involved itself more directly in local decision-making and governance issues as early as the 

Corrective Action stage of school improvement. 
Appendix A 37 

Exhibit A.6

Georgia differentiated accountability model categories, by Title I designation

State differentiated 

accountability 

categories

Title I 

designation: 

missed AYP 

zero or 

one year

Title I 

designation: 

Improvement, 

Year 1 

(SINI 1)

Title I 

designation: 

Improvement, 

Year 2 

(SINI 2)

Title I 

designation: 

Corrective 

Action 

(SINI 3)

Title I 

designation: 

Restructuring, 

Planning

(SINI 4)

Title I 

designation: 

Restructuring, 

Implementation

(SINI 5+)

Improvement • •

Corrective Action 

Tier 1

•

Corrective Action 

Tier 2

•

Corrective Action 

Tier 3

 • 

State-Directed • •

Exhibit reads: In Georgia, Schools in Need of Improvement, Year 1 (SINI 1), under Title I are now labeled 

Improvement schools.

NOTE: AYP = adequate yearly progress. ED approved Georgia’s differentiated accountability plan in July 2008; Appendix C 

contains explanations of differentiated accountability categories.

SOURCE: Georgia differentiated accountability application submitted to ED in 2008, December 2009 and January 2010 interviews,

and state website (http://www.gadoe.org/Pages/Home.aspx).

In addition to existing interventions for schools in improvement that required schools to notify 

parents of the school’s status and develop improvement plans aligned with SSAS, the Georgia 

differentiated accountability model added the following interventions: 

• All Title I schools in SINI 1 must offer either SES or school choice to their students, 

depending on the decision of the district. 

• All Title I schools in SINI 2 must offer both SES and school choice to their students. 

The state’s differentiated accountability model extended requirements for schools in 

Improvement to schools in Corrective Action and added the following for those in Corrective 

Action: 

• Tier 1 schools also must choose at least one additional intervention from the following 

list:

– Extend the school year or school day for the school. 

– Restructure the internal organizational structure of the school. 

– Appoint an outside expert to advise the school on its progress toward making AYP, 

based on its improvement plan. 

– Convert the school to a charter school. 

• Tier 2 schools also must choose at least one additional intervention from the Tier 1 list or 

the following: 

– Replace the school staff that are relevant to the failure to make AYP.

– Significantly decrease management authority at the school level.
Appendix A 38 

• Tier 3 schools will have Corrective Action chosen by the state from the Tier 1 list or the 

following: 

– Involve the state directly in decisions regarding the replacement of the school staff 

that are relevant to the failure to make AYP.

– Significantly decrease management authority at the school level.

Districts with schools labeled State-Directed were required to enter into a contract with the state 

that included both mandated and customized expectations. Mandated provisions included the 

following: 

• Assignment by the state of a state director to every state-directed school to be at the 

school full-time to provide direct supervision in the implementation of all school 

improvement actions. 

• Participation in Georgia Assessment of Performance on School Standards (GAPSS) 

review at levels SINI 5 and SINI 7.

• Participation in training, implementation, and monitoring of instructional strategies 

through Raising Standards Academies, a professional learning program developed by the 

Georgia Department of Education to provide strategies for teaching mathematics,

English/language arts and science in a standards-based classroom.

• Hiring instructional coaches for specific content areas of need, based on AYP results. 

In addition to the set of non-negotiable actions for schools labeled State-Directed, the state used 

recent school data to develop a set of customized expectations annually, with each school and 

school system to address the unique issues faced by that school. 

Under differentiated accountability, Georgia moved Restructuring Implementation from SINI 7 

to SINI 5, so schools received intensive “contract monitoring” support two years earlier. To 

facilitate this shift, the state moved its required use of the GAPSS analysis from SINI 7 to 

SINI 5. Using GAPSS—a system of online surveys, classroom observations of teachers, and onsite interviews—schools determined their performance on school standards, such as curriculum; 

instruction; assessment; planning and organization; student, family, and community support; 

professional learning; leadership; and school culture. 

With its differentiated accountability model, Georgia introduced new support structures and 

leadership into the schools by placing a state director in all SINI 4 and above schools (43 schools 

as of December 2009). State directors provided daily, on-site technical assistance, assisting with 

mentoring and coaching, data collection and analysis, and the ongoing implementation of 

interventions. State directors also were directly involved in the school improvement and 

restructuring process, including the replacing of staff. 

Under differentiated accountability, the state expanded the roles of the 16 Regional Education 

Service Agencies (RESAs). Prior to differentiated accountability, the RESAs served SINI 1 and 

SINI 2 schools; and, with the addition of state-funded school improvement specialists, they also 

served all schools in the newly designated Corrective Action tiers. The state provided 
Appendix A 39 

coordinated professional development for all RESA-based school improvement specialists to 

ensure that the state’s school improvement support was consistent across districts and schools. 

Illinois 

Illinois used its differentiated accountability model to eliminate the Corrective Action category 

in the federal model and based new labels of Focused and Comprehensive on whether schools 

met or missed AYP based on performance of the All Students group (see Exhibit A.7). Under 

this model, schools in any stage or year of improvement were further distinguished as either 

Focused or Comprehensive. 

Exhibit A.7

Illinois differentiated accountability model categories, by Title I designation

State differentiated 

accountability 

categories

Title I 

designation: 

missed AYP 

zero or 

one year

Title I 

designation: 

Improvement, 

Year 1 

(SINI 1)

Title I 

designation: 

Improvement, 

Year 2 

(SINI 2)

Title I 

designation: 

Corrective 

Action

(SINI 3)

Title I 

designation: 

Restructuring,

Planning 

(SINI 4)

Title I 

designation: 

Restructuring, 

Implementation 

(SINI 5+)

Focused Years 1–3 • • • 

Focused 

Restructuring 

Planning 

 • 

Focused 

Restructuring 

Implementation

 • 

Focused Continued 

Restructuring 

Implementation

 •

Comprehensive

Years 1–3 • • • 

Comprehensive 

Restructuring 

Planning

 • 

Comprehensive 

Restructuring 

Implementation

 •

Comprehensive 

Continued 

Restructuring 

Implementation

 •

Exhibit reads: Schools in Need of Improvement, Year 1 (SINI 1), under Title I are now labeled Focused or 

Comprehensive.

NOTE: AYP = adequate yearly progress. ED approved Illinois’ differentiated accountability plan in July 2008; Appendix C contains 

explanations of differentiated accountability categories.

SOURCE: Illinois differentiated accountability application submitted to ED in 2008, November 2009–January 2010 interviews, and 

state website (http://www.isbe.state.il.us/nclb/htmls/accountability_proposal.htm).

The model also created a new priority-school designation for the lowest-performing 3–5 percent 

of schools in the Comprehensive Restructuring Planning and Comprehensive Restructuring 

Implementation categories and infused ESEA’s Corrective Action strategies earlier in the 

improvement process. By removing the Corrective Action designation and requiring intensive 

interventions for schools in earlier stages of the improvement timeline, the state encouraged 

districts and schools to engage in long-term planning and implementation of needed supports. 
Appendix A 40 

Focused schools in Year 2 of improvement and beyond incorporated Corrective Action–type 

interventions from the following list in their school improvement plans:

• Restructure the internal organization of the school to focus instruction on the area of need 

(e.g., providing block scheduling and an aligned instructional program targeted to the 

subgroup[s] not meeting AYP). 

• Replace or reassign the school staff that are deemed relevant to the school not making 

AYP.

• Appoint one or more outside experts to advise the school on how to revise, strengthen, 

and implement its improvement plan to better address the area of focus and on how to 

address the specific issues underlying the school’s inability to make AYP.

Comprehensive schools in Year 2 of improvement and beyond incorporated corrective 

interventions from the following list in their school improvement plans:

• Institute a new curriculum aligned to state standards, with necessary professional 

development to support its implementation.

• Develop and implement frequent formative assessments permitting immediate analysis, 

feedback, and instruction. 

• Create an extended-day program for all students or for all underperforming students. 

• Implement a Response to Intervention model that emphasizes data-driven decision

making, team planning, and coordinated professional development, coupled with 

personalized student instruction and interventions. 

• For high schools, establish joint instructional and assessment programs involving feeder 

elementary school districts and dual credit/concurrent enrollment programs with 

postsecondary institutions. 

• Implement a comprehensive school reform program with the assistance and advice of one 

or more outside experts. 

In Illinois, a Regional Service Provider System, which was established prior to implementation 

of its differentiated accountability model, provides support services to schools and districts.

Services include ongoing monitoring and assistance developing and implementing school 

improvement plans and ensuring plans are data-driven and effective. The state intended to use 

differentiated accountability to expand the support available to districts and schools through the 

regional agencies. The state had intended for regional service agencies to provide programs and 

processes that targeted the specific academic deficiencies in Focused schools and to assist 

Comprehensive schools in the following areas: implementation of a comprehensive datagathering system and methods of data analysis; school-wide implementation of standards-aligned 

curriculum and instruction; principal mentoring and support; and improvements to student, 

family, and community support systems. However, as Illinois was still largely in the planning 

phases of its differentiated accountability plan during this evaluation, it was unclear whether this 

had occurred. State officials reported that they do not monitor the requests for and delivery of 

services between schools and service centers and do not maintain data on how schools 

implement their school improvement plans. The state also did not have its system of Focused and 
Appendix A 41 

Comprehensive interventions, as outlined in its differentiated accountability plan, in place at the 

time of this study.

After submitting its differentiated accountability application, Illinois turned its attention to its 

participation in the Partnership Zone, a public-private partnership with five other states to 

develop long-term reform strategies for their lowest-performing schools. Two other pilot states, 

Louisiana and New York, were selected for this Partnership Zone initiative, led by a nonprofit 

organization, which involved putting turnaround leaders in low-performing schools. 

Indiana

Indiana’s differentiated accountability model incorporated an indexed rating system to identify 

high-need Title I schools, based on English and mathematics proficiency, and to prioritize 

deployment of resources for assistance. The formula distinguished between those schools 

considered the neediest (i.e., Comprehensive) and those closest (i.e., Focused) to meeting AYP. 

In 2008–09, a total of 220 schools were in improvement in Indiana. By applying the index rating 

formula, 170 schools were labeled for Focused Improvement, and 50 schools were labeled for 

Comprehensive Improvement. The plan further labeled Focused schools in Year 8 of 

improvement or beyond as Focused Intensive, and it labeled the 20 lowest Comprehensive 

schools as Comprehensive Intensive (see Exhibit A.8). 

Exhibit A.8

Indiana differentiated accountability model categories, by Title I designation

State differentiated 

accountability 

categories

Title I 

designation: 

missed AYP 

zero or 

one year

Title I 

designation: 

Improvement, 

Year 1 

(SINI 1)

Title I 

designation: 

Improvement, 

Year 2 

(SINI 2)

Title I 

designation: 

Corrective 

Action 

(SINI 3)

Title I 

designation: 

Restructuring, 

Planning

(SINI 4)

Title I 

designation: 

Restructuring, 

Implementation 

(SINI 5+)

Focused • • • • •

Focused Intensive In Year 8

Comprehensive 

Support • • • 

Comprehensive • • • • •

Comprehensive 

Intensive • • • • •

Exhibit reads: Schools in Need of Improvement, Year 1 (SINI 1), under Title I are now labeled Focused, 

Comprehensive Support, Comprehensive, or Comprehensive Intensive.

NOTE: AYP = adequate yearly progress. ED approved Indiana’s differentiated accountability plan in July 2008; Appendix C contains 

explanations of differentiated accountability categories.

SOURCE: Indiana differentiated accountability application submitted to ED in 2008, November and December 2009 interviews, and 

state website (http://www.doe.in.gov/improvement/turnaround/differentiated-accountability).

According to the state Title I director, Comprehensive schools that showed improvement moved 

into the Comprehensive Support category, which allowed them to delay planning for 

restructuring while they continued to focus on their improvements. 

To implement differentiated accountability, Indiana added interventions and modified existing 

ones and applied them to schools based on schools’ Focused or Comprehensive needs. Under 

ESEA, for example, schools developed Corrective Action plans in Year 3 and submitted them to 

the district for approval. Under differentiated accountability, schools labeled Focused 
Appendix A 42 

implemented Corrective Action plans at Year 5 and underwent review and approval by a 

multidisciplinary panel at Year 8, while schools labeled as Comprehensive began implementing 

Corrective Action strategies in Year 3. The state inserted teacher training opportunities at Year 3 

to provide more support to teachers in Focused schools and potentially avert the need for 

Corrective Action.

In spring 2008, Indiana established three new support services, which the state included in its 

differentiated accountability plan. To address the needs of high-poverty, low-performing urban 

schools, Indiana developed the Institute for School Leadership Teams in April 2008 for school 

principals and leadership teams. The institute developed a two-year program based on researchbased results from high-poverty, high-performing urban schools and recruited highly 

distinguished principals to mentor principals in low-performing schools with similar needs and 

demographics. In June 2008, the state established the Indiana Teacher Reading Academies and, 

in conjunction with differentiated accountability, required the participation of all K–3 teachers 

and principals in Comprehensive schools at Year 3 or higher. Also in June 2008, the state piloted 

the Math Now Academy and embedded this initiative into its differentiated accountability model 

as part of the Indiana Teacher Reading and Math Academies, beginning in school year 2009–10. 

Under differentiated accountability, Indiana implemented the use of two diagnostic tools for 

student assessments, one for grades K–2 to provide formative assessment in reading and math, 

and one for grades 3–8 to provide formative assessment in English/language arts, mathematics, 

science, and social studies. Indiana required Comprehensive schools to hire data coaches to 

facilitate making decisions regarding instruction. After being trained by the state department of 

education in the use of the diagnostic tools, the data coaches worked in districts to help teachers 

better understand how to use assessment data to inform instruction and to assist principals and 

teachers in understanding and utilizing their school data to determine appropriate interventions 

and assessments for gauging and improving student performance. See Exhibit A.9 for greater 

detail on the state interventions for Focused and Comprehensive schools. 

To assist schools in the Focused and Comprehensive Intensive categories, the state required that 

these schools receive services from state support teams. Support teams analyzed school 

operations and instructional programs, evaluated the effectiveness of school personnel, and 

submitted recommendations and monthly reports to the state. To monitor the progress of the 

schools, the state hosted regular conference calls with support teams, which reported on their 

services and school responses. 

In order to increase the number of students receiving SES, the state required schools in Focused 

Year 4 and higher to maintain rolling enrollment for SES and allow providers to offer instruction 

on the school building premises after school. All schools in any Comprehensive category must 

maintain rolling enrollment for SES, allow SES providers to instruct in the school building, and 

offer student transportation for SES tutoring. 
Appendix A 43 

Exhibit A.9

Indiana differentiated accountability interventions for Focused and Comprehensive schools

Year of 

improvement

Focuseda

(required unless noted otherwise)

Comprehensiveb

(required unless noted otherwise)

1–2 Supplemental educational services 

(SES) and school choice

• School choice

• Required use of reading and/or math diagnostic tools

• Coaches (literacy and math)

• SES rolling enrollment, school site access for private 

providers, and transportation provided

3 Regional teacher training workshops 

and online training modules

• Indiana reading academy

• Indiana algebra initiative

• Implement Corrective Action (schools must select one):

– Replace staff responsible for continued failure to 

make adequate yearly progress (AYP)

– Replace principal or appoint outside mentor

– Hire English Learner specialist

– Sufficiently extend school day or year

4 • SES rolling enrollment and school 

site access for private providers

• Plan Corrective Action

• Plan restructuring

• Sustain Corrective Action

5–7 • Implement Corrective Action 

(schools must select one):

– Replace staff responsible for 

continued failure to make AYP

– Hire full-time literacy or math 

coach

– Hire English Learner specialist 

(minimum of 0.5 full-time 

equivalent)

– Sufficiently extend school day 

or year

• Implement restructuring (schools must select one):

– Replace principal if leader has remained the same 

during sustained failure to make AYP and replace all 

staff responsible for failure to make AYP

– Close the school

– Reopen school as a charter school

– Contract with a private management company with 

demonstrated effectiveness to run the school

8–Intensive • Required diagnostic tools

• State support teams

• Submit Corrective Action plan for 

state review and approval

• State support teams

• Institute for school leadership teams

• Superintendent must resubmit and publicly defend 

school’s Restructuring Plan before a state panel

Exhibit reads: In Years 1 and 2 of improvement, Focused schools are required to offer SES and school choice. a Focused schools defined at those closest to meeting AYP.

b Comprehensive schools defined as those neediest in terms of meeting AYP.

SOURCE: Indiana differentiated accountability application submitted to ED in 2008; November and December 2009 interviews.

Louisiana 

Prior to the 2001 reauthorization of ESEA, Louisiana had developed an accountability system 

based on school performance scores (SPS), calculated with a formula using assessment scores, 

attendance, drop-out, and graduation data. The formula produces scale scores ranging from 0 to 

200, and under differentiated accountability, the state continued to assign a performance score of 

one to five stars to schools using these SPS calculations (see Exhibit A.10). Based on a school’s 

annual SPS, the state sets its growth target for the next year. Growth targets represent the amount 

of progress a school must make every year to reach the state’s SPS goal of 120 by 2014 to 

comply with current ESEA requirements.
Appendix A 44 

Exhibit A.10

Louisiana school performance score ranges, by corresponding labels

Performance labels SPS ranges

Five stars 140.0–200.0

Four stars 120.0–139.9

Three stars 100.0–119.9

Two stars 80.0–99.9

One star 60.0–79.9

Academically unacceptable Below 60.0

Exhibit reads: A school is awarded five stars if its school performance scores fall between 140 and 200.

NOTE: SPS = school performance scores.

SOURCE: Louisiana differentiated accountability application submitted to ED in 2008.

Louisiana used the flexibility provided by differentiated accountability to retain its state system 

of accountability and continued to assign schools performance and growth labels; it also renamed 

the current ESEA school improvement categories and added a Pre-Identification label for schools 

that missed AYP for the first time (see Exhibit A.11). The state’s differentiated accountability 

model continued to determine school improvement categories according to subgroup AYP 

performance as defined by ESEA but did not merge its state system with ESEA. This means that 

the state maintained parallel systems, determining SPS and ESEA performance separately, and 

required schools to meet AYP under both systems. 

Exhibit A.11

Louisiana differentiated accountability model categories, by Title I designation

State differentiated 

accountability 

categories

Title I 

designation: 

missed AYP 

zero or 

one year

Title I 

designation: 

Improvement, 

Year 1 

(SINI 1)

Title I 

designation: 

Improvement, 

Year 2 

(SINI 2)

Title I 

designation: 

Corrective 

Action

(SINI 3)

Title I 

designation: 

Restructuring, 

Planning 

(SINI 4)

Title I 

designation: 

Restructuring, 

Implementation 

(SINI 5+)

Pre-Identification •

Initial Support •

Secondary Support •

Continued Support 1 •

Continued Support 2 •

Vital Support 1 •

Vital Support 2 •

Exhibit reads: Schools in Need of Improvement, Year 1 (SINI 1), under Title I are now labeled Initial Support.

NOTE: AYP = adequate yearly progress. ED approved Louisiana’s differentiated accountability plan in January 2009; Appendix C 

contains explanations of differentiated accountability categories.

SOURCE: Louisiana differentiated accountability application submitted to ED in 2008, November 2009–January 2010 interviews, 

and state website (http://www.louisianaschools.net/topics/understanding_acct.html).

While Louisiana did not create new identification tiers within ESEA categories, it did create tiers 

for interventions within categories based on what percentage of the total school enrollment the 

subgroup(s) missing one or more AYP indicators represented. By requiring one or two 

interventions, the state allowed schools with specific low-performing subgroups to select from a 

state menu of previously approved interventions. For schools that did not make AYP in the All 

Students category, the state assigned specific interventions to each category. Schools were 
Appendix A 45 

responsible for developing their school improvement plans using these interventions and were 

required to submit the plans to the state for approval. 

In Louisiana, the differentiated accountability model focused on the specific problems of the 

specific groups of students who were struggling. Under differentiated accountability, the state 

directed interventions to those student groups with the greatest need and increased services for 

those schools with larger proportions of low-performing students and those in need for longer 

periods of time. State officials felt that the benefit of differentiated accountability was that they 

could offer more choices from among approved interventions and facilitate buy-in by allowing 

schools and districts to select some of their own interventions. 

As schools moved up in school improvement categories, they implemented all of the 

interventions from the previous category plus those added in the subsequent category. In addition 

to interventions required by the state, schools selected as noted from the state menu of 

interventions (see Exhibit A.12).

Exhibit A.12

Louisiana state menu of interventions from which schools could create school improvement plans

Interventions

• Hire highly qualified teachers

• Provide professional development addressing specific subgroup needs

• Hire “specialist” or “lead teacher” with experience in research-based approach for specific subgroups

• Hire general academic specialists (as administrators)

• Extend the school year or school day

• Implement academic or operational program—Comprehensive School Reform Demonstration (CSRD) 

approach

• Replace staff

• Enter agreement with Louisiana Department of Education (LDE) for a Distinguished Educator

• Enter agreement with LDE for Turnaround Specialist Project

• Offer targeted or schoolwide supplemental educational services (SES)

• Offer targeted or schoolwide school choice

• Analyze and redraw attendance zones and feeder patterns

• Conduct external comprehensive needs assessment

• Conduct external implementation checks

• Contract an outside expert

• Restructure

• Reconstitution

• Decrease management authority

• Submit quarterly or monthly implementation reports

• Submit to state takeover

– Direct operation by state or state awarded charter

– Memorandum of Understanding (MOU) with LDE to contract with a provider to operate failing 

academic MOU to complete implementation of major Restructuring Plan

SOURCE: Louisiana differentiated accountability application submitted to ED in 2008; November 2009–January 2010 interviews.

To support differentiated accountability, the state continued to require districts to assign district 

assistance teams to schools in improvement to provide additional intensive support and conduct 

classroom observations to identify specific areas of need. Assistance team members were district 

employees trained by the state. The team was responsible not only for leading the needs 
Appendix A 46 

assessment, but also for collaborating with the school improvement team in implementing and 

evaluating improvement activities.

Louisiana used differentiated accountability to strengthen its state accountability system and 

reinforce existing practices, so little is new in its differentiated accountability model. In 

reinforcing its existing system, Louisiana focused on coordinating services with its regional 

education service centers. The centers provided a structure for establishing a shared partnership 

between the state and the districts, which facilitated a coherent delivery of menu-driven services. 

Under differentiated accountability, the primary role of the regional centers was to implement 

state-mandated programs that impact student achievement; staff members also assisted districts 

with school improvement planning, the state accountability system, instructional strategies, and 

school culture and climate.

The Louisiana state Title I director reported that Louisiana appreciated that differentiated 

accountability allowed the state to restructure school improvement categories, reorder categories 

to match state needs, and apply interventions based on state-established criteria. She felt that 

having a strong state accountability system in place prior to differentiated accountability was 

important in the state’s ability to support the implementation of differentiated accountability 

because it provided the foundation on which to build the differentiated accountability model and 

extend and enhance school support services. 

Maryland 

With differentiated accountability, Maryland classified schools in two improvement categories, 

Developing (schools in the first three years of school improvement status under Title I) and 

Priority (schools in Year 2 of Corrective Action or Restructuring Planning under Title I) and 

further differentiated within each category between schools with focused needs and schools with 

comprehensive needs (see Exhibit A.13). All schools entered school improvement through the 

Developing Schools stage and were classified as either Developing Focused schools or 

Developing Comprehensive schools. In Developing Focused schools, the All Students group met 

its AMOs, and fewer than three subgroups did not make the state’s AMOs in reading or 

mathematics. Also included as Developing Focused schools were those that did not meet other 

academic indicators in the Maryland School Assessments (science in elementary, middle, and 

high school; government in high school) and those with a 100 percent special services population 

that missed AYP for the first two years. In schools in the Developing Comprehensive category, 

the All Students group missed the state’s AMOs for reading or mathematics, or three or more 

subgroups missed the AMOs in reading or mathematics. Schools unable to change long-term 

performance patterns moved to the Priority stage if they had not achieved AYP for four 

consecutive years.
Appendix A 47 

Exhibit A.13

Maryland differentiated accountability model categories, by Title I designation

State differentiated 

accountability 

categories

Title I 

designation: 

missed AYP 

zero or 

one year

Title I 

designation: 

Improvement, 

Year 1 

(SINI 1)

Title I 

designation: 

Improvement, 

Year 2 

(SINI 2)

Title I 

designation: 

Corrective 

Action

(SINI 3)

Title I 

designation: 

Restructuring, 

Planning

(SINI 4)

Title I 

designation: 

Restructuring 

Implementation 

(SINI 5+)

Achieving Schools •

Developing Focused • • •

Developing 

Comprehensive

 • • • 

Priority Focused • • •

Priority 

Comprehensive

• • •

Exhibit reads: Schools in Need of Improvement, Year 1 (SINI 1), under Title I are now labeled Developing Focused 

or Developing Comprehensive.

NOTE: AYP = adequate yearly progress. ED approved Maryland’s differentiated accountability plan in July 2008; Appendix C 

contains explanations of differentiated accountability categories.

SOURCE: Maryland differentiated accountability application submitted to ED in 2008, December 2009 interviews, and state website 

(http://marylandpublicschools.org/MSDE/programs/esea/).

To address the needs of schools earlier than the Title I designation process, Maryland created the 

Achieving Schools status for schools missing AYP for the first time. Achieving Schools must 

undergo a local school system evaluation to determine the causes of their decline and take 

Corrective Action the next school year. By insisting on Corrective Actions early, the state hoped 

to limit the number of schools entering improvement status and maintain focus on those in 

greater need.

The state assumed that schools labeled as Developing Focused struggled in a very narrow area or 

with very few students and intervened with two requirements: 

• The state must review local school improvement plans but will leave responsibility for 

implementation at the district level.

• The district must assure the state that the evaluation objectives for state and federal 

school improvement funds are aligned with the school improvement goals. 

For Developing Comprehensive schools, the state determined interventions addressing capacity 

issues in leadership and available resources and added the following interventions to those 

required for focused-needs schools: 

• The school must administer a previously validated school climate survey and use the 

results to develop, with district oversight, three to five priorities for improving the 

school’s climate in its improvement plan. 

• The district and school leadership must consult with the Breakthrough Center to receive 

assistance in analyzing needs, recommending and prioritizing actions, and targeting 

professional development on persistent needs areas. 

• Local leadership must determine which of the six traditional Corrective Action steps 

should be pursued. 
Appendix A 48 

Maryland considered Priority Focused schools to have a persistent, focused problem requiring an 

evaluation of the effectiveness of the leadership and the teaching staff. In these schools, the state 

implemented all interventions used with developing schools but replaced the Corrective Action 

requirement with one requiring the schools to submit their school improvement plans to the state 

for approval by the Maryland State Board of Education. 

Maryland intervened with greatest intensity in Priority Comprehensive schools, considering that 

in these schools the knowledge and skills needed to improve were underdeveloped or lacking and 

that the need for capacity building was the greatest. For these schools, the state required all 

interventions applied to other categories and added the following: 

• The school system and school must select to reopen the school as a public charter school; 

contract with a private management company; and replace all or most of the school staff, 

including the principal, or appoint or employ a distinguished principal, along with 

replacing the staff relevant to the school’s failure to make AYP. Once the school system 

and school select the alternative governance, the state requires the school to develop and 

submit for state approval an individual improvement plan. 

• The local school system superintendent must hold two community meetings in the school 

zone to discuss the best alternative governance arrangements for the school with the 

community and parents, and the results of the community meetings and the selection of 

the alternative governance arrangement must be included in the school improvement 

plan. 

With its differentiated accountability plan, Maryland also realigned its existing intervention tools 

and resources and provided additional options—such as comprehensive planning; curriculum, 

instruction, assessment and professional development with accountability; leadership; 

organizational structure and resources; and school culture and climate—to better match critical 

aspects of school improvement planning. Schools selected interventions that varied in intensity 

and could be customized to the needs and the culture of each school (see Exhibit A.14).
Appendix A 49 

Exhibit A.14

Maryland state menu of interventions from which schools could create school improvement plan

Interventions

• Comprehensive needs assessment

• Master plan update

• School improvement technical assistance (SITA) program

• Climate survey

• Teacher capacity needs assessment (TCNA)

• Development of comprehensive school improvement plan

• Breakthrough Center

• Low-performing schools’ principals’ academy

• Online principal mentoring

• Maryland State Department of Education (MSDE) reading/math professional development program

• Positive behavior intervention support (PBIS) training

• Priority hiring of highly qualified teachers

• Teacher mentors

• Voluntary state curriculum

• District-provided technical assistance

• District-provided leadership/coaching

• District-provided instructional supervisor to coach, monitor, and evaluate

• Collaborative planning time

• Extended learning opportunities for low-performing students (before/during/after school, Saturday, 

summer school)

• School leadership teams

• Student support teams

• Progress monitoring by district

• Instructional walk-throughs with school department chairs

SOURCE: Maryland differentiated accountability application submitted to ED in 2008; December 2009 interviews.

To assist schools in building capacity, Maryland used differentiated accountability to establish 

the Breakthrough Center in 2008 and positioned it as the state’s primary conduit to support 

schools needing specific interventions to address the identified priorities. For example, in 2008, 

students with disabilities missed AYP in reading in 76 of the 85 Comprehensive Priority schools 

(89 percent) and missed AYP in mathematics in 87 percent of these same schools (see 

Exhibit A.15). The Breakthrough Center assisted these schools in the most-intense level of 

improvement with training modules and professional development focused on co-teaching 

strategies for special education students in regular classrooms.
Appendix A 50 

Exhibit A.15

Number of schools and percentage of subgroups not making AYP, by Maryland differentiated 

accountability improvement categories: School year 2008–09

Differentiated 

accountability 

categories

Total 

no. of 

schools

All 

students

Lowincome EL SWD White Black Hispanic AsianNative 

American

Developing Focuseda 45 2% 13% 0% 36% 0% 2% 2% 0% 0%

Developing 

Comprehensive 47 70% 74% 11% 74% 4% 77% 9% 0% 4%

Priority Focused 23 9% 4% 0% 9% 0% 9% 0% 0% 0%

Priority Comprehensive 85 73% 69% 13% 89% 6% 74% 11% 0% 0%

Developing Focused 45 0% 11% 2% 20% 0% 2% 0% 0% 0%

Developing 

Comprehensive 47 53% 68% 13% 66% 4% 55% 6% 0% 0%

Priority Focused 23 9% 9% 4% 22% 4% 9% 0% 0% 0%

Priority Comprehensive 85 76% 74% 14% 87% 1% 73% 11% 1% 1%

Exhibit reads: In 2008–09 in Maryland, the All Students subgroup missed adequate yearly progress (AYP) in 

2 percent of the 45 Developing Focused schools. a Of the 45 schools in the Developing Focused category, some are in this category for reasons other than reading and math AYP 

(e.g., attendance or graduation rates).

NOTE: EL = English Learner; SWD = students with disabilities.

SOURCE: Data extracted from state report submitted to ED in December 2009.

In 2003, Maryland passed the Bridge to Excellence in Public Schools Act, legislation that 

established many of the processes in place for school improvement. This law required all 

24 districts in the state to participate in an annual master planning process in which district 

officials report to a master plan review panel on the performance of the school system and 

schools and detail the measures that are taken locally to remedy low performance. Under 

differentiated accountability, Maryland shifted interventions one year earlier, requiring districts 

to work with schools after missing AYP for the first year and moving reforms used in Years 5 

and 6 of missing AYP to Year 4. In doing so, the state relied on the master planning process to 

work in tandem with its differentiated accountability model to identify schools eligible for earlier 

interventions. 

New York 

The U.S. Department of Education approved New York’s differentiated accountability waiver 

application in January 2009, and state officials indicated that, at the time of the interviews in 

December 2009, the state was still in the earliest stages of implementing its plan. New York used 

differentiated accountability to reduce the current number of school accountability categories 

from 17 to 8 by eliminating dual Title I and non–Title I streams of improvement, to integrate 

federal and state accountability systems, to collapse identifications for improvement into three 

simplified phases, and to provide schools with diagnostic tools, planning strategies, supports, and 

interventions specific to that phase in the improvement process and the school’s category of 

need. The state retained its Schools Under Registration Review (SURR) category for schools in 

any differentiated accountability category that were the farthest from state standards. SURR 

schools were at risk of losing their license and were automatically placed in restructuring.
Appendix A 51 

New York’s differentiated accountability model retained ESEA’s school improvement categories 

but added tiers of differentiation within each: Basic, Focused, and Comprehensive (see 

Exhibit A.16).

Exhibit A.16

New York differentiated accountability model categories, by Title I designation

State differentiated 

accountability 

categories

Title I 

designation: 

missed AYP 

zero or 

one year

Title I 

designation: 

Improvement, 

Year 1 

(SINI 1)

Title I 

designation: 

Improvement, 

Year 2 

(SINI 2)

Title I 

designation: 

Corrective 

Action 

(SINI 3)

Title I 

designation: 

Restructuring, 

Planning 

(SINI 4)

Title I 

designation: 

Restructuring, 

Implementation

(SINI 5+)

No consequence •

Improvement Basic • •

Improvement 

Focused • • 

Improvement 

Comprehensive • • 

Corrective Action 

Focused • 

Corrective Action 

Comprehensive • 

Restructuring 

Focused • •

Restructuring 

Comprehensive • •

Schools Under 

Registration 

Review (SURR)

 • • • • •

Exhibit reads: Schools in Need of Improvement, Year 1 (SINI 1), under Title I are now labeled Improvement Basic, 

Improvement Focused, Improvement Comprehensive, or Schools Under Registration Review (SURR).

NOTE: AYP = adequate yearly progress. ED approved New York’s differentiated accountability plan in January 2009; Appendix C 

contains explanations of differentiated accountability categories

SOURCE: New York differentiated accountability application submitted to ED in 2008, December 2009 and January 2010 interviews, 

and state website (http://www.p12.nysed.gov/accountability/APA/Differentiated_Accountability/DA_home.html).

Each category was determined by the degree to which there was systemic failure of groups of 

students to make the state’s AMOs or other academic indicators: 

• Basic (improvement phase only): Schools identified based on low performance of a 

single student group on a single accountability measure. 

• Focused: Schools identified based on low performance of two or more student subgroups 

but not the All Students group. 

• Comprehensive: Schools identified based on low performance of the All Students group 

or all student groups except the All Student group. 

Under differentiated accountability, the depth, scope, and comprehensiveness of the 

interventions as well as the primary provider of support, oversight, and assistance varied by 

phase of improvement and category. The plan shifted responsibility to the state to provide 

persistently low-performing schools with experts who can partner with districts to guide and 

direct improvement strategies and empowered districts to take primary responsibility for 

developing and implementing improvement strategies in schools that were not persistently 
Appendix A 52 

failing to make AYP with large groups of students. In such instances, districts had considerable 

flexibility to work with schools to design improvement plans that were tailored to the specific 

circumstances of the school. Further, for schools missing AYP based on the performance of a 

single group of students, New York’s differentiated accountability model allowed schools to 

assess their needs and develop their own improvement plans and shifted responsibility to the 

district to ensure the plan is implemented successfully. The state believed that, by giving districts 

greater latitude and more responsibility for addressing these two groups of schools, the state and 

the district could better concentrate resources on those schools that needed more comprehensive 

interventions in order to ensure improvements in student performance. 

To provide needed services earlier in the improvement process and establish a continuum of 

increased intensity of services, the state realigned a number of existing diagnostic, 

implementation, and oversight resources to match school improvement categories explicitly (see 

Exhibit A.17).

Exhibit A.17

New York required diagnostic, implementation, and oversight interventions

under differentiated accountability, by school improvement categories: School year 2008–09

School 

improvement 

categories

Required diagnostic 

intervention

Required implementation 

intervention

Required oversight and 

support intervention

Improvement Schools must conduct a 

school quality review

Schools must develop a 

school improvement 

plan

Districts must take primary 

responsibility for 

developing and 

implementing 

improvement plans

Corrective 

Action

Schools must conduct a 

curriculum audit

Schools must implement 

the curriculum audit and 

develop a Corrective 

Action plan

State must provide 

technical assistance to 

districts to implement 

improvement plans

Restructuring Schools must receive 

assistance from Joint 

Intervention Teams 

and Distinguished 

Educators

Schools must receive 

external assistance to 

implement improvement 

plan or phase out

State and its agents must 

work in direct 

partnership with the 

district to implement 

improvement plan or 

phase out

Exhibit reads: Schools in improvement must conduct a school quality review, develop a school improvement plan, 

and should receive support from their districts in developing and implementing their plans.

SOURCE: New York differentiated accountability application submitted to ED in 2008.

The state service provider reported that the assistant commissioner for school improvement was 

still considering establishing turnaround centers to provide services to low-performing schools 

with joint intervention teams and distinguished educators. In the meantime, the state continued to 

utilize its existing supports to implement differentiated accountability while planning and 

developing a new system of services. School liaisons at the state department of education worked 

with districts and schools to provide guidance and resources based on the needs of districts, and 

the state relied on its existing regional school support centers to provide on-site strategic 

assistance to help schools increase student achievement in English, mathematics, science, and 

social studies.
Appendix A 53 

New York allocated additional improvement funding to the neediest schools and monitors them 

heavily. The state used state school liaisons to conduct site visits and provide technical assistance 

in such areas as leadership, teaching and learning, assessment, professional development, or use 

of data for restructuring schools and schools under registration review. For example, one district 

had three school liaisons working with 24 schools in various stages of improvement. In addition, 

the New York state service provider said that he directed the services provided by his office to 

the lowest-performing 5 percent of schools in the state.

Ohio 

Ohio developed its differentiated accountability model around the key elements of 

accountability, differentiation, and interventions to better define the degree of complexity 

necessary for targeting intervention to schools and districts that have been identified for school 

improvement. The Ohio differentiated accountability model categorized districts and schools as 

needing Low, Medium, or High Support (see Exhibit A.18) based on the aggregate percentage of 

student subgroups that did not meet AYP in reading and mathematics. Districts and schools were 

labeled Low Support if they missed less than 20 percent of their AYP indicators, Medium 

Support if they missed 20–29 percent of AYP indicators, and High Support if they missed 

30 percent or more of their AYP indicators. Thus, a school in any year of improvement could be 

categorized as Low, Medium, or High Support. A High Support Year 1 school could access 

intensive support quickly and could access additional options if it continued not to make AYP. In 

2007, Ohio received permission from the Department to pilot a growth model, which reduced the 

number of schools identified for improvement. Under the growth model, students who missed 

proficiency targets were counted as having met the targets if they made significant gains.

Exhibit A.18

Ohio differentiated accountability model categories, by Title I designation

State differentiated 

accountability 

categories

Title I 

designation: 

missed AYP 

zero or 

one year

Title I 

designation: 

Improvement, 

Year 1 

(SINI 1)

Title I 

designation: 

Improvement, 

Year 2 

(SINI 2)

Title I 

designation: 

Corrective 

Action

(SINI 3)

Title I 

designation: 

Restructuring, 

Planning

(SINI 4)

Title I 

designation: 

Restructuring, 

Implementation

(SINI 5+)

Low Support • • • • •

Medium Support • • • • •

High Support • • • • •

Exhibit reads: Schools in Need of Improvement, Year 1 (SINI 1), under Title I are now labeled Low Support, Medium 

Support, or High Support.

NOTE: AYP = adequate yearly progress. ED approved Ohio’s differentiated accountability plan in July 2008; Appendix C contains 

explanations of differentiated accountability categories.

SOURCE: Ohio differentiated accountability application submitted to ED in 2008, December 2009 interviews, and state website 

(http://education.ohio.gov/GD/Templates/Pages/ODE/ODEDetail.aspx?page=3&TopicRelationID=129&ContentID=47348&Content=

117373).

Ohio proposed to provide schools and districts that missed AYP with new options for 

interventions, in addition to those required by federal and state law. Some options existed prior 

to differentiated accountability, but the state assigned them to lower improvement categories to 

intensify state efforts earlier in the improvement process. Interventions newly aligned with each 

of the three categories included the following:
Appendix A 54 

• In addition to existing state and federal requirements, schools designated as Low Support

schools may opt to develop and implement a district leadership team and school building 

leadership teams to implement recommendations in the Ohio Leadership Advisory 

Council framework.5

 

• Districts and schools identified as needing Medium Support must select one or more of 

the following options: 

– Have an on-site review by a state-approved diagnostic team with implementation of at 

least two critical items associated with the reasons the schools and/or district were 

identified for improvement. 

– Replace the building staff relevant to the issues.

– Institute and fully implement a new curriculum, including professional development 

for teachers.

– Significantly decrease management authority at the building level.

– Appoint an outside expert to advise the building on its progress. 

– Extend the school year or school day for the building. 

– Restructure the internal organizational structure of the building. 

• Districts and schools identified as needing High Support selected one or more of the 

following options: 

– Have an on-site review by a state-approved diagnostic team with aggressive 

implementation of critical items associated with the reasons the schools and/or district 

were identified for improvement. 

– Have the district/buildings implement their improvement plans under the oversight of 

the state support team.

– Reopen the school as a public charter school. 

– Replace all or most of the building staff (which may include the principal).

– Enter into a contract with an entity to operate the public school. 

For High Support districts failing to provide consistent oversight of the school improvement 

efforts or failing to demonstrate significant district improvement, the state selected additional 

interventions. These interventions included adjustments to funding; new requirements for 

curriculum and professional development; replacement of staff; and alternative governance and 

supervision arrangements, including replacing the superintendent and appointing a receiver or 

trustee to administer the affairs of the district in place of the superintendent and the local school 

board. 

Ohio’s goal was to improve the outcomes of the district system—the district and schools—by 

instituting consistent improvement processes across the district. The state used differentiated 

accountability to implement the Ohio Improvement Process plan, a policy that required a district 

and its schools in improvement status to move through the improvement process as a unit. This 

 

5

 The Ohio Leadership Advisory Council represents a large group of stakeholders convened by the Ohio Department 

of Education, in partnership with the Buckeye Association of School Administrators to identify the essential 

practices needed to be implemented by staff at all levels of the education system to ensure improvement in student 

performance.
Appendix A 55 

meant that a district not in improvement status, but with buildings in improvement status, was 

required to implement the basic treatments at the district level as if it had been identified.

Districts and schools remaining in the same category and not making significant progress were 

required to add an additional intervention once every three years. By unifying the treatments 

within a district, the state focused its limited capacity on districts and their associated schools 

with the most severe problems.

Under differentiated accountability, the state added a requirement that schools in improvement 

form district and school leadership teams to plan, monitor, and implement school improvement 

plans. This action was an option for Low Support schools but a mandate for schools in Medium 

or High Support status. 

To support differentiated accountability, Ohio leveraged existing state diagnostic team leaders by 

increasing their role in the district and school implementation of the Ohio Improvement Process 

plan. Prior to differentiated accountability, the state diagnostic team conducted local school and 

district assessments, debriefed the superintendent, and moved on to the next district. Under 

differentiated accountability, the state diagnostic team leader returned to the district to align the 

diagnostic review with the decision framework and served as an ongoing resource for districts as 

they created their focused school improvement plan. These teams absorbed much of the 

responsibility of the existing state support teams housed in the Education Service Centers, 

freeing them to focus on the neediest schools. The state service provider explained that this 

process was evolving prior to differentiated accountability, but that the waiver provided leverage 

and support for a preventative approach. 
Appendix A 56 

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Appendix B 57 

Appendix B:

State and Local Respondents Interviewed in the Nine Pilot States

Exhibit B.1

Interview subjects, by the nine pilot states

State State Title I director State service provider District Title I director School principal

AR Director for two years Project Manager for nine 

months; previously a 

field service provider

Director in small, rural district 

for two and a half years

Principal for three years;

school in restructuring 

status

FL Director for two years; 

involved with 

differentiated 

accountability from 

beginning

Director for one year; 

oversees state support 

to schools for 

differentiated 

accountability. Former 

turn-around principal in 

Miami

Director in large, coastal, 

suburban district for four 

years

Principal for five years; 

school made AYP in 

2008–09 for first time in 

five years

GA Program Manager for 

Title I for two years; 

Division Director of 

Title I for four years

Program Manager in 

Analysis and Planning 

Division

Director in small, rural district 

for six years

Principal for less than 

one year; assistant 

principal for two years; 

Teacher for 11 years in 

same school; school in 

restructuring

IL Director for four months; 

with state department 

of education for two 

years; involved with 

differentiated 

accountability from 

beginning

Director for 16 years; 

involved with 

differentiated 

accountability from 

beginning

Director in large urban district 

for seven years

Principal for six months; 

school reopened with 

new principal/staff in 

2009

IN Director of Differentiated 

Learners for four and 

a half years

Title I Specialist for less 

than one year; with 

Indiana Department of 

Education for three 

years 

Director in large, urban district 

for 15 years

Principal for four years; 

school in restructuring

LA Director for two years School Improvement 

Supervisor for two 

years

SES Coordinator in large, 

rural district for seven 

years

Principal for less than 

one year; school in 

restructuring

MD Director for three years Executive Director of the 

Breakthrough Center 

for two years

Director of School 

Improvement and 

Accountability in large, 

suburban district for 10 

years

Principal for five years; 

school in restructuring

NY Director for six years; 

involved with 

differentiated 

accountability since 

beginning

Research Specialist for 

five years on state’s 

Office of Accountability 

School Improvement 

Team

Acting Director Principal for nine years; 

school missing AYP in 

EL and SWD student 

subgroups

OH Director for six years; 

involved with 

differentiated 

accountability from 

beginning

Director for six years; 

manages district 

requests for services

Director in mid-size city district 

for one and a half years; 

with district for 42 years

Principal for four years; 

school reopened with 

new principal/staff in 

2005

NOTE: AYP = adequate yearly progress; EL = English Learner; SES = supplemental educational services; SWD = students with 

disabilities.

SOURCE: November 2009–January 2010 interviews.
Appendix B 58 

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Appendix C 59 

Appendix C: 

Summary of Methods States Used to Distinguish Tiers in Pilot 

Differentiated Accountability Models

States used a variety of approaches to distinguish between schools needing help with a limited 

number of subgroups and schools having more comprehensive needs. 

Arkansas 

Arkansas selected 75 percent as the performance target to distinguish tiers. School categories

under differentiated accountability and how they are assigned are as follows:

• Targeted Improvement schools are those in which 75 percent or greater of the 

subpopulations meet standards and one or more subpopulations failed to meet annual 

measurable objectives (AMOs).

• Intensive Targeted Improvement schools are those in which 75 percent or greater of the 

subpopulations meet standards and one or more subpopulations failed to meet AMOs for 

five or more years consecutively in the same subject.

• Whole-School Improvement schools are those in which the combined populations did not 

meet AMOs and/or less than 75 percent of subpopulations meet AMOs and are in Year 1, 

Year 2, or Year 3 of school improvement. 

• Intensive Whole-School Improvement schools have the same criteria as Whole School 

but have been in improvement for four or more years.

Florida 

Florida developed its differentiated accountability categories based on school grades earned in 

combination with whether schools met 80 percent of their adequate yearly progress (AYP) 

indicators and their number of years in improvement. School categories under differentiated 

accountability and how they are assigned are as follows: 

• Prevent I schools are those that have earned an A, B, or C in the Florida School Grades 

system, have met 80 percent of their AYP indicators, and are in Year 1, Year 2, or Year 3 

of school improvement. 

• Correct I schools are those that have earned an A, B, or C in the Florida School Grades 

system, have met fewer than 80 percent of their AYP indicators, and are in Year 4 or 

beyond in school improvement.

• Prevent II schools are those that have earned a D or F in the Florida School Grades 

system, have met 80 percent of their AYP indicators, and are in Year 1, Year 2, or Year 3 

of school improvement. 

• Correct II schools are those that have earned a D or F in the Florida School Grades 

system, have met fewer than 80 percent of their AYP indicators, and are in Year 4 or 

beyond in school improvement. 
Appendix C 60 

Georgia 

Georgia added three tiers within the Corrective Action category. Using the schools in Corrective 

Action, the state calculated quintiles based on a school’s distance from its AMOs to develop the 

three tiers and used the quintiles as follows: 

• Tier I schools are those in the top 20 percent. 

• Tier II schools are those in the middle 60 percent. 

• Tier III schools are those in the bottom 20 percent. 

Illinois 

Illinois renamed ESEA categories of Schools in Need of Improvement for Years 1–3 (SINI 1–3) 

as either Focused 1–3 or Comprehensive 1–3, and continued to use Restructuring labels for SINI 

4–5+, but added Focused and Comprehensive distinctions. Focused schools met AYP in the All 

Students category, and Comprehensive schools did not. 

Indiana

Indiana revised a formula-driven indexed rating system used prior to differentiated 

accountability and used an index cut-off score of 60.95 to distinguish between Focused and 

Comprehensive schools. 

Louisiana 

Louisiana did not add tiers to its state accountability model to distinguish within SINI categories 

but did rename the current SINI categories to: 

• Pre-Identification: Newly created category for schools that missed AYP for the first time.

• Initial Support: Former Title I year 1 improvement designation.

• Secondary Support: Former Title I year 1 improvement designation.

• Continued Support 1/Support 2: Former Title I corrective action designation. 

• Vital Support 1: Former Title I restructuring/planning designation.

• Vital Support 2: Former Title I restructuring/implementation designation.

Maryland 

Maryland separated schools into two stages based on their Title I SINI categories—Developing 

schools are those in SINI 1, SINI 2, or Year 1 of Corrective Action; Priority schools are those in 

Year 2 of Corrective Action or Restructuring. The state then added two tiers to each stage—

Focused and Comprehensive. 

• Focused schools are those that fail to achieve the AMOs for reading and/or mathematics 

for no more than two subgroups and that achieve all AMOs for the All Students group in 

reading and mathematics.
Appendix C 61 

• Comprehensive schools are those that fail to achieve the AMO for the All Students group 

for reading or mathematics or that fail to achieve the AMO for three or more AYP 

subgroups for reading and/or mathematics.

New York 

New York reduced the school improvement categories to three—Improvement, Corrective 

Action, and Restructuring—and added tiers within each category.

• Basic schools are those identified for one accountability measure and one student group 

but not the All Student group. 

• Focused schools are those identified for more than one accountability measure or more 

than one student group within an accountability measure but not the All Student group. 

• Comprehensive schools are those identified for one or more accountability measures and 

the All Student group. 

Ohio 

Ohio created three tiers within each SINI category based on the percentage of AYP indicators 

missed.

• Low Support schools are those missing fewer than 20 percent of their AYP indicators. 

• Medium Support schools are those missing between 20 percent and 29 percent of their 

AYP indicators. 

• High Support schools are those missing 30 percent or more of their AYP indicators. 
Appendix C 62