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. 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 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.