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Advancing Accountability in Light of Approved ESEA Waivers

February 21, 2012 9 minute Read by Kerri L. Briggs

The George W. Bush Institute’s (GWBI) Education Reform team has had some time to dig into the state Elementary and Secondary Education Act (ESEA) waiver applications approved last week by the U.S. Department of Education. Building on our previous post, we have analyzed whether the approved waivers address the concerns we raised in our review of the originally submitted applications.

Undoubtedly, the states and the Department collaborated to achieve their respective goals. Further, in response to feedback from the Department, the states have strengthened their plans in several respects. The approved plans hold promise for prompting important reforms at the state level, including higher standards, improved assessments, and innovative teacher evaluation models. Unfortunately, the collaborative process did not address all of our concerns. A number of the approved plans still lack clarity; many states plan to limit consequences to a certain small percentage of schools; and most states failed to explain adequately how they will maintain accountability throughout the upcoming transitions.

State-level education reforms that fail to hold schools and districts accountable for student success are empty reforms. They threaten to roll back the progress inspired by No Child Left Behind (NCLB) and place tens of thousands of students at risk of graduating ill-prepared for college or the job market. Below, we discuss our concerns about the approved plans in more detail with the hope of encouraging states – both those with approved plans and those intending to submit their applications later this month – to remain committed to the principles of accountability outlined in the attached brief.

a)                  Uncertainty and lack of clarity

We noted in our earlier brief that many state applications suffered from uncertainty and lack of clarity.  The Department should be commended for its collaborative approach to working with states on clarifying certain aspects of their state applications. All approved states made adjustments and clarifications to their applications as a result of the review process. However several aspects of the approved waivers continue to lack detail. Many states received approval based on the “promise” to do something (e.g., implement new standards and assessments, refine a new element of the accountability system), and others require legislative or regulatory changes for the reform proposals to be implemented (e.g., teacher evaluation models, school grading systems). We do not believe states will willingly neglect to implement these reforms. However, it will require diligence – both by the states to implement the reforms and by the U.S. Department of Education to monitor the states’ progress. We’ve seen some issues with states meeting deadlines in implementing their Race to the Top applications. The stakes for not meeting the timelines promised in the waiver applications are even higher.

b)                  Student subgroups

Several approved states use some form of a “super subgroup” approach. This approach groups a percentage of low performing students or traditionally underserved students into a single subgroup. GWBI is not opposed to this approach and recognizes that it likely has some advantages with respect to focusing interventions on the instructional needs of schools and students, especially English language learners and students with disabilities. Further, we are pleased that the approved plans show some improvements and clarifications in this area. Most notably, the states agreed to set improvement targets for all subgroups. Additionally, approved plans show that states are committed to, at a minimum, publicly report achievement data disaggregated by the traditional NCLB subgroups. Further, some states that use the super subgroup added additional protections for subgroups in schools when those schools are not identified as “focus” or “priority schools” under the state’s accountability system. But these improvements do not resolve all our concerns regarding subgroup accountability (a principle at the heart of NCLB). Notwithstanding the positive gains in Florida, the effects of the super subgroup approach in other states’ accountability systems are untried. We hope those Florida gains are replicated and we’ll be analyzing the results as these new systems become operational.  Even for those states that continue to use the traditional subgroups in addition to a super subgroup, the performance of the traditional subgroups plays a diminished role in state accountability decisions. Many states did not provide a second level of analysis to show that schools with persistent achievement gaps or persistent low performance by certain subgroups will be identified and held accountable, even if that school is not classified as “priority” or “focus” under the state’s new accountability determinations.  It is vitally important that we do not wind back the clock to pre-NCLB days when the high performance of certain students or subgroups masked the reality that some students were not well served.

c)       Limiting consequences to a certain small percentage of schools

This is one area where we have seen little progress between submitted applications and approved plans. As we indicated in our January brief, several states (and half of the approved states) propose to limit consequences for failing to make adequate progress toward student success to a certain small percentage of schools (i.e., the lowest performing 5% or 15%). We understand these states were responding to a specific option provided in the guidance offered by the U.S. Department of Education. However, we remain unconvinced that this was threshold was established using any real analysis of the number or types of schools that are, in fact, failing. Again, we ask what happens to students stuck in schools that escape interventions more because of luck than any significant difference in performance? Due to the important advances implemented under NCLB, states now have the data and capacity to vary the type and intensity of interventions based on the particular needs of a school. We applaud the states that took a consistent approach to these interventions – applying consequences to all similarly performing schools regardless of how many schools fall within the intervention categories.

d)      Backing away from alternatives and choices for families

We have also seen only limited progress in the area of providing real alternatives for students trapped in underperforming schools. We recognize that this was not an identified priority in the U.S. Department of Education’s waiver guidance. So, the lack of change is not surprising. However, we feel compelled to continue to focus on this issue and to again commend those states that committed to offering opportunities for students through a variety of models (e.g. after school tutoring, school choice, opportunity scholarships and expansion of effective charter schools).School choice is particularly important when considered in conjunction with the percentage cap on the number of schools in which a state will apply meaningful in-school interventions. Our concerns on both of these issues would be partially allayed if those low-performing schools that fell outside the interventions cap were at least required to provide alternatives and choices for families.

e)      Maintaining accountability during transitions

Transitions remain a significant concern as well. The approved plans provide some additional detail on deadlines and general plans for how the transitions will take place. Yet, in light of the number and types of transitions – new content standards, new assessments, new performance standards, new achievement goals, new interventions and accountability determinations – states and schools will be implementing over the next several years, the level of detail appears inadequate. Few approved waiver plans explain unambiguously how each transition will impact the need to hold schools accountable for student performance throughout this school year and subsequent school years. It is not clear, for example, how states will transition schools from the current NCLB accountability model to the approved waiver model. How will the transition to new standards and assessments impact goals and accountability decisions? How will states and schools begin to transition to these new standards and assessments? These are not questions to be answered after the fact. States must begin planning now to ensure schools are held accountable for all students throughout each of these transitions.

This post was written by Kerri Briggs, Director of Education Reform, and Eric Smith, Ed.D., Fellow in Education Reform.