ESSA Plans Under Official and Unofficial Review

Two months ago, 17 states submitted the first plans required under a new federal law designed to put local leaders in the driver seat on education. The Every Student Succeeds Act, or ESSA, lets states decide how they will measure school performance as well as how they will identify and support low-performing schools. Those measures must be aligned with state goals and to college- and career-readiness standards.

Right now, officials at the U.S. Department of Education are reviewing the submitted plans to ensure compliance with federal law. Separate from the federal agency, outside groups with a vested interest in education policy are conducting their own assessments, and those reviews are mixed on both the quality of the plans and how bureaucrats are sticking to or exceeding the law.

“Some states are doing it well, some aren’t,” said Michael J. Petrilli, president of the Thomas B. Fordham Institute, adding that the range of quality in plans is to be expected. “These plans are part of a bureaucratic compliance exercise and so states are playing the game. We shouldn’t be surprised that they’re playing it strategically.”

The ESSA plans are lengthy, technical documents filled with statistical models, programming details, and, in some cases, best guess estimates for data that is still being collected. State education officials are creating accountability systems that evaluate how well schools are educating students, designing school report cards that are easy-to-understand for parents, explaining how they intend to improve performance among traditionally underperforming student subgroups, and setting ambitious goals for student achievement.

A Roadmap for Other States to Follow

Once a state submits its plan, federal officials have 120 days to conduct their review, which may include asking for more details or explaining how programs could be expanded. While that official work is being conducted, there are a plethora of organizations in the academic realm that are conducting their own unofficial reviews and providing assistance.

The Collaborative for Student Success is working with Bellwether Education Partners to evaluate the strengths and weaknesses of state plans. Using a diverse group of peer reviewers, which include experts from traditionally underrepresented groups such as students with disabilities and English language learners, the Collaborative plans to release the results next week.

“Our goal was to conduct an independent review that went beyond compliance,” said Jim Cowen, executive director of the Collaborative for Student Success. “Our intention is to give states feedback from a wide range of accountability experts, and especially to identify the best practices that emerge from the 17 plans.”

The reviewers looked at a number of components of each state’s plan, including whether states have high-quality academic standards and assessments in place, how states measure student growth and academic achievement, and how states plan to identify low-performing schools and the path those schools will have for exiting support status. In the wonky world of academic policy, this kind of comprehensive review can provide a roadmap for improving educational outcomes that other states can emulate.

“In the end, we want states to submit the best plans possible—not to fulfill a federal requirement but because better plans will lead to better results in the classroom,” Cowen added.

Cowen noted that the Collaborative plans to conduct a similar review in September after the remaining plans are submitted.

The Fordham Institute is also reviewing the 17 plans submitted to the Department of Education in April. Petrilli said he’s already seeing signs of federal and executive overreach. The Department of Education’s initial letter to Delaware described the state’s long-term academic achievement goals as “not ambitious.”

“Delaware is plenty ambitious,” Petrilli scoffed. “The law doesn’t define ‘ambitious’ and they don’t have any regulations on the books so the question is, what gives them the right to determine that Delaware’s goals aren’t ambitious enough. The law made clear this was meant to be in the domain of the states to set their goals.”

The Council of Chief State School Officers (CCSSO) issued a statement from Executive Director Chris Minnich calling federal feedback “too prescriptive in certain areas, and goes beyond the intent of the law.”

In addition to criticizing Delaware’s goals, federal officials asked for more information as to how the state will use Advanced Placement (AP) and International Baccalaureate (IB) exams as an indicator for the College and Career Preparedness indicator, since not every school administers exams associated with those programs. AP and IB are stalwarts of high school education across the country. Minnich’s statement expressed hope for “further clarification” from the Department of Education.

Federal Compliance or State Leadership?

The bulk of the work for anyone conducting reviews – whether federal officials or outside organizations – is still to come when the remaining 34 states submit their plans in September. Those states appear to have an advantage in being able to see how reviews and federal feedback go for their predecessors.

“People are definitely interested to see what’s in the initial batch of plans,” said Kirsten Carr, Director of Accountability for CCSSO.

CCSSO is among the organizations that offer assistance to states while drafting plans, including opportunities for officials from various states to sit down and talk in peer-to-peer exchanges. States that are further ahead in strategic planning can also offer valuable advice to those not so far along. Connecticut, for example, underwent a strategic planning process before ESSA was signed into law and already had in place – or was in the process of building – many components that ESSA would require. Still, Connecticut is one of the states that is giving “best guess estimates” in its plan. How federal officials handle that could be useful to others.

In building a new accountability system, Connecticut officials needed to determine expected growth for English language proficiency. After adopting new academic standards in 2015, the state experienced a “data void” and set about collecting fresh numbers, a process that takes time since language assessments take place only twice per year. Connecticut Deputy Commissioner of Education Ellen Cohn said federal officials told them to “do your best estimate of growth” after submitting their plan in April.

While Cohn spoke specifically to Connecticut’s plan, she inadvertently summed up how other states may be looking at the federal review: “It’s nice to get federal approval but we’re proceeding because we really have a very strong sense of what we should be doing for kids,” she said.

New Mexico officials, who were told by federal reviewers that their accountability system needs to fit better with federal law, would agree with Cohn.

“I think we have been recognized across the country as having a very robust and complete vision in our plan,” said Ashley Eden, Director of Strategic Initiatives. “We think it reflects the voice of New Mexicans.”

Reflection of local values comes from state, district-level, and school personnel, not federal mandates. Whether federal officials provide the clarity that CCSSO is hoping for remains to be seen, but at the least, reviews from groups like the Collaborative for Student Success will offer insight into how to combine quality components with local priorities.

Jessica R. Towhey is a contributor to RealClearEducation.