Every Student Succeeds Act: Early Observations on State Changes to Accountability Systems
Released: 2017-07-18T00:00:00

Letter

Background

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.

Stakeholders and Selected States View ESSA’s Accountability Provisions as Flexible

Stakeholders See ESSA as Flexible and Said Some States Are Making More Changes to Their Accountability Systems Than Others

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.

Ohio’s and California’s Approaches to Incorporating ESSA Provisions into Their Accountability Systems

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.

Developing and Implementing State Monitoring Plans Is a Key Next Step for Education in ESSA Implementation

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.

Appendix I: National and State Stakeholder Groups With Whom GAO Spoke

Appendix II: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

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.