Every Student Succeeds Act: Early Observations on State Changes to Accountability Systems
Published: 2017-07-13T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Federal, state, and local governments spent about $640 billion in 2015 to educate nearly 50 million public school children in the United States. ESSA, enacted in December 2015, reauthorized the Elementary and Secondary Education Act of 1965. To receive federal education funds for school districts with high concentrations of students from low-income families, ESSA requires states to have accountability systems that meet certain requirements, but gives states flexibility in how they design their systems.
GAO was asked to review states' early experiences with ESSA. This report examines (1) selected stakeholders' and states' views of ESSA's flexibilities as states redesign accountability systems, and (2) Education's next steps in implementing ESSA.
GAO interviewed representatives of nine prominent national education stakeholder groups, selected for their knowledge about state accountability systems; met with education officials in California and Ohio—states that were among those stakeholders cited as offering differing approaches to developing their systems; interviewed Department of Education officials; reviewed relevant federal laws and guidance; and reviewed accountability system guidance from California and Ohio and these states' draft state plans.
GAO is not making recommendations in this report. The Department of Education provided technical comments on a draft of this report, which we incorporated as appropriate.
section_title: What GAO Found
paragraphs: According to most of the nine education stakeholder groups GAO interviewed and officials in the two states GAO visited, the Every Student Succeeds Act (ESSA) strikes a good balance between flexibility to meet state needs and ESSA requirements. Accountability systems measure student and school performance to identify and assist low-performers. States are currently developing plans for accountability systems under ESSA. According to stakeholders, some states are using ESSA's flexibilities to significantly change their accountability systems while others are making more limited changes. Changes stakeholders discussed pertained mostly to four key components (see figure). GAO visited California and Ohio and these two states reported using ESSA's flexibilities to distinguish between levels of school performance, among other things. For example, Ohio plans to assign letter grades to schools on each of six performance indicators. Under Ohio's proposal, schools will also receive overall letter grades beginning in 2018. California plans to distinguish performance with grades for performance on each of six state indicators. Their proposed system will not provide overall scores for schools. California officials said reporting on individual indicators will allow them to show key distinctions in performance that an overall score could mask.
Four Key Components of Accountability Systems Under the Every Student Succeeds Act
Education officials said next steps in implementing ESSA are the review and approval of ESSA-required state plans, and to continue to provide technical assistance to states. Officials also said that they are developing monitoring protocols for in-depth reviews of states' ESSA-related activities and will pilot them in early 2018. ESSA also includes certain reporting and review requirements, for example, (1) annual state reports to Education on student and school performance; (2) annual Education reports to Congress on state reported data; and (3) approval by the Secretary of Education of significant changes to state plans.

section_title: Letter
paragraphs: Federal, state, and local governments spent about $640 billion in 2015 to  educate nearly 50 million public school children in the United States.  Ensuring that all students have access to a high quality education is a  widely shared goal. Accountability systems help foster this goal by  measuring student and school performance and providing information on  that performance to key stakeholders—parents, teachers, government  officials, and taxpayers. The Every Student Succeeds Act (ESSA)  requires all states to have accountability systems that meet certain  requirements, but gives states flexibility in how they design their  systems. In general, ESSA requires states to measure the performance  of their schools and use those measures to identify underperforming  schools and student subgroups for additional assistance.
You asked us to report on states’ early efforts implementing ESSA. This  report focuses on (1) selected stakeholders’ and states’ views of ESSA’s  flexibilities as states redesign their accountability systems, and (2) U.S.  Department of Education’s (Education) next steps in implementing ESSA.
For this work, we interviewed representatives of nine prominent national  education stakeholder groups knowledgeable about accountability  systems, six of which worked directly with states as they revised their  accountability systems in response to ESSA. We also visited state  educational agencies, school districts, and a total of four state  stakeholder groups in California and Ohio. (See appendix I for a list of the  national and state stakeholder groups with whom we met.) We selected  California and Ohio because they were among the states that national  stakeholder groups cited as being illustrative of different state approaches  to developing their proposed accountability systems. In each state, we  visited three school districts that had schools in each grade span— elementary, middle, and high schools—and varied in size and geographic  location. These states provide illustrative examples of how two states are  revising their accountability systems in response to ESSA, and are not  generalizable to the 50 states. We also interviewed Education officials,  and reviewed relevant federal laws and Education guidance pertaining to  ESSA accountability provisions. Lastly, we reviewed accountability  system guidance from California and Ohio as well as relevant portions of  their draft state plans which describe how they will comply with ESSA  accountability requirements.
In this report, we focused on four components of state accountability  systems under ESSA that we identified during our early interviews with  stakeholder groups as being key components of these systems, and as  areas in which states are making changes to their systems. We refer to  these four components as: (1) determine long-term goals, (2) develop  performance indicators, (3) differentiate schools (referred to in this report  as distinguishing between levels of school performance), and (4) identify  and assist low-performers.
We conducted this performance audit from December 2016 to July 2017  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: State accountability systems under ESSA include four key components:  1) determine long-term goals, 2) develop performance indicators, 3)  differentiate schools, and 4) identify and assist low-performers (see fig.  1).
ESSA requires states to submit state plans to the Secretary of Education  to receive Title I funds. These funds support schools and districts with  high concentrations of students from low-income families. ESSA requires  that states develop these plans with “timely and meaningful consultation”  with a variety of stakeholders, and also coordinate the plans with certain  other federal programs. Education has developed a state plan template  that states can use when formulating their consolidated state plans and  procedures for submitting these plans. ESSA requires that state plans be  peer reviewed and that the Secretary of Education approve them if they  meet the requirements in the law.
As of May 2017, 16 states and the District of Columbia had submitted  their plans to Education for review; the remaining plans are due by  September 18, 2017, according to Education’s guidance. Both states we  visited as part of our review intend to submit their plans by the September  deadline.
section_title: Stakeholders and Selected States View ESSA’s Accountability Provisions as Flexible
subsections: section_title: Stakeholders See ESSA as Flexible and Said Some States Are Making More Changes to Their Accountability Systems Than Others
paragraphs: Representatives of all nine national stakeholder groups we spoke with  saw ESSA’s accountability provisions as somewhat flexible, with most  indicating that ESSA strikes a good balance between flexibility and  requirements. One stakeholder said, for example, that ESSA “threads  the needle very well” between giving states flexibility in designing their  accountability systems and placing requirements on states to help ensure  that all children have an opportunity to get a good education. Most  stakeholders also mentioned ESSA provisions related to developing  performance indicators as an example of flexibility. One stakeholder, for  example, saw, these provisions as flexible because they allow states to  define the exact indicators they will use, including indicators that measure  student growth in addition to student proficiency when assessing  academic performance.
Representatives of four national stakeholder groups that have worked  directly with states to help them develop and revise their accountability  systems told us that the extent to which states are revising their  accountability systems varies because some states are satisfied with their  current systems and others are using the flexibilities in the law to make  significant overhauls. According to representatives of one stakeholder  group, for example, many states already began revising their  accountability systems as a result of waivers Education granted under the  previous reauthorization, the No Child Left Behind Act of 2001 (NCLBA).  They further said that ESSA is generally flexible enough for states to  continue down the path they started in implementing their NCLBA  waivers. In addition, representatives of several stakeholder groups  mentioned that for states that see their current accountability systems as  lacking in some way, or because consultation with state stakeholders has  pointed to the need for significant change, ESSA provides room for them  to consider innovative revisions.
section_title: Ohio’s and California’s Approaches to Incorporating ESSA Provisions into Their Accountability Systems
paragraphs: Ohio and California, the two states we visited, illustrate how different  states are using the flexibilities in ESSA to develop accountability  systems that are tailored to meet state needs as well as ESSA  requirements for each of the four key components of state accountability  systems: determine long-term goals, develop performance indicators,  differentiate schools, and identify and assist low performers. (See  sidebars for summaries of ESSA requirements for these components.)
Highlights of Selected ESSA  Requirements: Long-Term Goals  ESSA requires states to design and establish  ambitious long-term goals, including  measurements of interim progress toward  meeting them. For example, states are to set  goals for all students, and separately for each  subgroup of students, for improved academic  achievement and high school graduation  rates, among other things.  Student subgroups include economically  disadvantaged students, students from major  racial and ethnic groups, children with  disabilities, and English learners.
Ohio officials told us that they chose a 10-year timeline for meeting their  long-term goals to help address stakeholder concerns about providing  schools and districts sufficient time to meet the new goals. For example,  one of Ohio’s proposed goals is that at least 80 percent of students score  proficient or higher on Ohio’s statewide assessments in English  Language Arts and math within 10 years. Meeting this goal may be easier  for some schools and groups of students than others, as some are further  away from the goal than others. To close this “achievement gap,” the  state plans to set its proficiency goals for each student subgroup such  that those groups furthest behind will be expected to make greater annual  gains in an effort to catch up over the 10-year period. Further, in an  effort to make the 10-year long-term goals achievable for lower- performing groups, the state’s draft plan proposes to set the 10-year  proficiency goals for them lower than the 10-year goals for higher- performing subgroups. Ohio state officials and stakeholders told us that  some stakeholders were concerned about having different goals for  different subgroups: Some find the annual or long-term goals for low  performing subgroups too ambitious and others find it problematic that  certain students would be held to different standards than others. State  officials said to meet the ESSA requirement of having ambitious long-term  goals, they designed their approach to significantly close the achievement  gap over 10 years. At the time of our work, Ohio was still working on its  final approach to address this issue.
According to California’s draft plan, California plans to achieve its goals  within 5 to 7 years—a timeframe that coincides with regularly scheduled  reviews of the performance indicators used in its accountability system.  Unlike Ohio, California is proposing that schools and districts propose  their own interim goals to close achievement gaps and that the same  timeline for long-term goals (5 to 7 years) apply to all student subgroups.  State officials mentioned that district interim goals must take into account  the current performance of student subgroups and how far this  performance is from the state’s long-term goals.
Highlights of Selected ESSA  Requirements:  Indicators  States are required to annually measure, for  all students and for student subgroups, four  “academic” indicators. These indicators  include academic achievement for all public  schools, as measured by proficiency on the  annual state assessments, and the four-year  adjusted cohort graduation rate for public high  schools, among other things.  In addition, states are also required to have,  for all public schools, at least one statewide  indicator of school quality or student success  that meets certain criteria. This indicator may  include measures of student and educator  engagement, student access to and  completion of advanced coursework,  postsecondary readiness, school climate and  safety, or any other indicator the state  chooses that meets the requirements in the  law.
Ohio officials told us that they plan to use their current indicators as the  foundation for meeting ESSA’s requirements for academic indicators, and  make some revisions or refinements as needed. With regard to ESSA’s  required indicator of school quality or student success, state officials said  they plan to include chronic absenteeism because studies show that  school attendance is strongly correlated with successful student  performance. Because the state already collects attendance data, the  indicator also reduces the need for additional data collection. Ohio  officials and stakeholders said that ESSA has prompted many substantive  conversations about what to use for the school quality or student success  indicator. For example, Ohio stakeholders and a school district official told  us that they have concerns about using chronic absenteeism as a  measure because schools and districts cannot control whether students  come to school and that other indicators might be beneficial measures.  State officials mentioned that in response to these concerns, Ohio’s draft  plan now includes a commitment to pilot a school climate survey for  potential inclusion as an indicator of school quality or student success in  future years.
Although California’s draft plan proposes using its existing indicators to  meet ESSA’s requirements for academic indicators, the state also plans  to develop some new ones. For example, as an additional academic  indicator, the state proposes to use chronic absenteeism. According to its  draft plan, there is a strong correlation between strong academic  performance and school attendance. For the school quality or student  success indicator, California chose suspensions, with high rates  indicating poor quality and failure, and low rates indicating success. State  officials said that ESSA flexibilities allowed them to differentiate what was  considered high and low rates of suspension by grade level (i.e.,  elementary, middle, and high school). They explained that this is  important because it allows them to tailor the indicator for each level.
Differentiate Schools (distinguishing between levels of performance) accountability system, including the four  academic indicators, for all students and  for each subgroup of students; and  include differentiation of any school in  which any subgroup of students is  determined by the state to be consistently  under-performing.
Ohio officials told us that they propose to continue to use the state’s  current system of six indicators, with modifications, to assess school and  student performance. Under the proposal, schools would receive a letter  grade on each indicator. Some of the indicators, such as academic  achievement, would measure current performance while other indicators,  such as academic progress, would measure growth. Ohio state officials  told us that they also intend to roll up indicator scores into an overall letter  grade for schools in 2018. They said that reporting a letter grade on each  indicator provides detailed information, while an overall letter grade  provides an easily understandable overview of performance. Ohio  stakeholders and school district officials expressed concerns about both  the use of letter grades and rolling up grades on each indicator into an  overall score. They explained that words, such as meets or exceeds  expectations, could more accurately communicate performance than  letter grades.
California officials said they plan to distinguish performance of schools  and student subgroups by using a dashboard in which school and student  subgroup performance would be color-coded based on each of six state  indicators. These officials said that each indicator measures current  student performance as well as changes in performance over time. Unlike  Ohio, California does not plan to aggregate the indicators into overall  scores for schools and student subgroups. California officials told us that  they chose their approach for two reasons. First, aggregating scores on  indicators into an overall score can mask individual areas where a school  may be struggling. In contrast, reporting individual indicators allows key  distinctions to be maintained in performance across a variety of factors.  Second, officials said that measuring performance in both the current  year and over time on each indicator provides a more complete picture of  performance.
Ohio state officials told us that their processes for identifying low  performing schools (known in Ohio as priority schools) and schools with  underperforming subgroups (known in Ohio as focus schools) will be  similar to the process they used under their NCLBA waiver and will  include new indicators, such as chronic absenteeism as one indicator of  school quality or student success. Furthermore, Ohio officials in one  district discussed a requirement in ESSA that they believe will improve  Ohio’s system of intervening in low-performing schools and subgroups— that states establish criteria for how schools can exit certain ESSA  improvement categories. As part of meeting this requirement, these  officials said that Ohio is developing benchmarks for graduation rates and  student growth indicators, which they said should make it clear to districts  when they can release schools from improvement categories. addition, states are to notify each school  district about schools in which any  subgroup of students is consistently  underperforming, and ensure the district  provides notification to these schools.
For each school identified, the school or  district is to develop and implement, in  partnership with stakeholders, either a  comprehensive support and improvement  plan or a targeted support and improvement  plan, as applicable, to improve student  outcomes. These plans must be informed by  all state indicators and include evidence- based interventions.  States are to, among other things, establish  statewide exit criteria for schools identified for  comprehensive support and improvement and  additional targeted support.
California’s draft state plan proposes to identify low-performing schools  and student subgroups based on where they fall on its dashboard of  color-coded performance indicators, and lists three options for how the  state may do this. Regarding assisting low-performing schools and  student subgroups, California state officials said they plan to give districts  the authority to develop interventions. California officials in one district  said that ESSA provides flexibility to reconsider how they provide school  interventions. They said, for example, that they can now provide an  intervention such as tutoring when they feel it will be most effective— before, during, or after the school day—and that this was partly because  of ESSA.
section_title: Developing and Implementing State Monitoring Plans Is a Key Next Step for Education in ESSA Implementation
paragraphs: Given current timelines, Education officials said that the department is  currently focused on the review and approval process for state plans and  providing assistance to states in developing their plans. Under ESSA, the  Secretary of Education is responsible for establishing a peer-review  process to assist in the review of state plans, and for approving state  plans that meet the requirements of ESSA. Education officials told us  that the peer reviewers will consider the technical, educational, and  overall quality of specific portions of state plans when making their  recommendations to the Secretary. According to guidance Education  provided to peer reviewers, another goal is for reviewers to provide states  with objective feedback on the technical, educational, and overall quality  of their plans.
Education officials told us that they are developing monitoring protocols  that they will pilot with eight or nine states in early 2018. These protocols  are intended to guide in-depth reviews of state activities related to ESSA  implementation. The officials noted that they are piloting the protocols to  ensure that they have an appropriate monitoring tool to obtain information  on how states are implementing ESSA requirements. Officials told us that  Education used similar in-depth state reviews when developing past  monitoring protocols, reviewing a select number of states each year with  the goal of reviewing all states within a 3- to 4-year cycle. Given that  some states have submitted their state plans earlier than others for  approval, officials also noted that they will pilot the monitoring protocol in  states that progressed enough to warrant monitoring. To complement the  in-depth monitoring, Education officials said they also plan to continue  their past practice of maintaining regular contact with all states.
Education officials also told us they are determining whether there is a  need for additional guidance to states on aspects of ESSA  implementation. Education has provided assistance to states in a number  of ways. For example, the department hosted webinars on the state plan  template that states may choose to use, and on the peer review process.  Education has also implemented a technical assistance initiative called  the State Support Network to support state and district school  improvement efforts under ESSA. This network aims to connect states  and districts with technical assistance providers and subject matter  experts to develop strategies for supporting schools. According to the  network’s website, it aims to help states and districts learn from prior  school improvement efforts, assess needs and assets to inform  strategies, and build sustainable systems to support continuous  improvement. During our review, representatives of most national  stakeholder groups with whom we spoke told us that states could use  guidance on a number of issues. One example of guidance that they told  us states might consider useful is identification of appropriate evidence- based interventions. As part of its ongoing assistance to states,  Education has addressed this topic in a number of ways, including non- regulatory guidance, resources via the State Support Network, and case  studies.
ESSA requires states and Education to report annually on specific  aspects of ESSA implementation and states to submit significant changes  to their plans to Education for review (see sidebar for a summary of these  requirements). states to submit annual reports to the  Secretary of Education. These annual  reports must include information on  student achievement based on the annual  state assessments, including  disaggregated results for student  subgroups. The reports must also include  certain information on English learners,  schools identified for support and  improvement, and teacher qualifications,  among other things.
Under Education’s current reporting procedures, states submit  information for each school year the following fall. Education officials  said that they plan to continue this practice, so state submissions in fall  2018 would be the first to include information based on ESSA  requirements, i.e., for school year 2017-2018.
Annual report to Congress: ESSA also  requires the Secretary of Education to  submit an annual report to specified  congressional committees that provides  both national and state-level data on the  information collected from the states’  reports.  that once a state plan is approved it  remains in effect for the duration of the  state’s participation in Title I, though it  also directs states to periodically review  and revise plans as necessary to reflect  any changes in state strategies or  programs. If a state makes any significant  changes to its state plan, such as  adopting new academic assessments, the  state must submit a revised plan or  amendment to Education for review.
On June 16, 2017 we provided a draft of this report to Education for  comment. That same day, Education issued additional guidance for  states on developing their state plans, including some guidance related to  accountability systems. Education provided technical comments on our  draft, which we incorporated as appropriate.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies of this report to the U.S.  Secretary of Education. In addition, the report will be available at no  charge on the GAO website at http://gao.gov.
If you or your staff have any questions about this report, please contact  me at (617) 788-0580 or nowickij@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff who made key contributions to this report  are listed in appendix II.
section_title: Appendix I: National and State Stakeholder Groups With Whom GAO Spoke
section_title: Appendix II: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Bill Keller (Assistant Director),  Nancy Cosentino (Analyst-in-Charge), James Bennett, Deborah Bland,  Mindy Bowman, Sarah Cornetto, Randolfo DeLeon, Anna Duncan, Holly  Dye, Brian Egger, Sheila R. McCoy, and Monica Savoy made key  contributions to this report.