Your Cheat Sheet for the Proposed ESSA Accountability Rules
By Andrew Ujifusa and Alyson Klein
It's been close to two weeks since the U.S. Department of Education released proposed regulations for the Every Student Succeeds Act that would govern school accountability. We've touched onseveral high-profile issues in the draft rules since they were made public, including their requirement for a single overall rating for schools and the tricky shift to ESSA that some schools might face in 2016-17.
But below, you can find several of the most important issues in a straightforward, "cheat sheet" format. We've organized the material into three categories:
• What ESSA says about the issue in statutory language;
• How the proposed ESSA regulations would handle the issue, and;
• Some of the reaction to the proposed regulations. (We included this where it was relevant—not every area has gotten serious pushback or praise at this early stage.)
Let us know if you think we've missed any major issues in the comments section, or email us ataujifusa@epe.org, or aklein@epe.org. You have until Aug. 1 to submit your comments to the department about these proposed rules. They're expected to be finalized at some point after that later this year.
Overall School Rating
• What ESSA Says: ESSA does not explicitly require states to apply an overall rating to each school in their accountability plans.
• What the Draft Rules Say: The regulations require a "summative" rating for each school. States have to have at least three categories of summative ratings. The rating can take the form of a number (say on a scale of 1 to 100), an A through F grade, or it could just be a category (say, "needs improvement", "satisfactory", or "excellent.") Plus, states need to make publicly available any data that informs the overall summative rating. If schools are calculating the rating based on growth, achievement, and school climate, for example, they need to publish that data for parents, alongside the overall score.
• The Reaction: Supporters of such a comprehensive rating for schools say the proposal is consistent with the intent of ESSA to provide clear information to educators, parents, and others. Some, however, are concerned that it could undermine alternative methods of school accountability, such as "dashboards" that provide information about various indicators, but don't place a single rating on schools.
Test Participation
• What ESSA Says: States are still required to test all students annually in English/language arts and math in grades 3-8 and once in high school. But states are allowed to set consequences for schools that don't meet the 95 percent participation threshold. States could also have laws explicitly allowing parents to opt their children out of tests.
• What the Draft Rules Say: States must choose one of three sanctions for schools that miss the threshold, such as giving schools the lowest rating on their academic achievement indicators or knocking down their overall ratings. Or else states can submit their own plans for dealing with test-participation problems.
• The Reaction: Fans of annual standardized tests say the proposal is appropriate and highlights how important these tests are. However, those friendly to the testing opt-out movement argue the plan is too prescriptive and that states would not get the flexibility they think the law contains when it comes to dealing with high opt-out rates. (If you're thinking the legal environment for opt-out seems complicated or unclear right now, you're not alone.) AFT President Randi Weingarten is among those critical of the proposed rules here, saying they're too punitive.
Accountability Indicators
• What ESSA Says: States must create an accountability system that relies on both academic indicators like test scores, graduation rates, and English-language proficiency, plus at least one indicator of school quality, which could be teacher engagement, student engagmement, school climate, or anything else the state cooks up that's subject to federal approval of their accountability plans. Each of these indicators must carry "substantial" weight. And the academic indicators, as a group, must be given a weight "much greater" than the school-quality indicator.
• What the Draft Rules Say: The proposed regulations don't define what "much greater" means or give any sense of what would be an appropriate weight for each indicator. They do say, however, that the academic indicators need to give equal weight to math and reading. And they say that the school-quality indicator should be something that research shows will contribute to student achievement or boost graduation rates. (There's research to back up indicators like access to the arts, or science and social studies classes, U.S. Secretary of Education John B. King, Jr. said in a recent interview with Education Week.)
Also, the school-quality indicator should be something that shows real differentiation from one school to another. For example, the department is discouraging states from using average daily attendance; it says there's simply not enough variation from school to school, which means it's harder to tell which schools need closer attention and support. Also, importantly, just as with the summative rating, states need to come up with at least three performance levels for each indicator. That means if a state picks, say, teacher engagement, it needs to figure out what it means for a school to have at least high, low, and medium teacher engagement. (States could come up with more than three levels, if they want.)
•The Reaction: Mike Petrilli, of the Thomas B. Fordham Institute, thinks the department is attaching too many strings to the school quality indicator. Check out his post here.
Subgroups of Students and 'N' Sizes
• What ESSA Says: States need to consider the performance of each subgroup of students (that's English-language learners, racial minorities, students in special education, and disadvantaged kids) seperately, no combining of subgroups into "super subgroups." Also, states need to set an "n" size, meaning the minimum number of students in a particular group that a school must have in order for that group to count for accountability purposes. The state gets to pick the "n" size it wants—the department doesn't get to require any particular number. (The thinking behind an "n" size: If a Your Cheat Sheet for the Proposed ESSA Accountability Rules - Politics K-12 - Education Week:
