EdTrust and All4ED Comment Re: School Improvement Guidance

October 4, 2024

Melissa Siry
Office of Elementary and Secondary Education
U.S. Department of Education
400 Maryland Avenue, SW
Washington, DC 20202

Dear Ms. Siry:

As organizations committed to advancing policies and practices that promote educational equity for students of color, students from low-income backgrounds, and other traditionally underserved groups and dismantling racial and economic barriers in our education system, All4Ed and EdTrust appreciate the opportunity to respond to the U.S. Department of Education’s (ED’s) request for public comments on its draft non-regulatory guidance, School Improvement and Related Provisions under Title I, Part A of the Elementary and Secondary Education Act of 1965 (ESEA). 

The purpose of the school accountability requirements in the ESEA is school improvement. Federally required identification of low-performing schools should create the conditions for State, district, and school leaders to engage in meaningful improvement, including rigorous needs assessments, a review of available resources and resource allocation to support students and schools most in need, and the selection and implementation of evidence-based interventions.

We view this guidance as an important step in ED’s efforts to improve implementation of these critical Every Student Succeeds Act (ESSA) provisions and applaud the Department for issuing such a comprehensive overview of the key requirements in the law. The draft guidance resolves many of the most frequently asked questions that State educational agency (SEA), local educational agency (LEA), and school leaders have about ESSA in a thorough, clear manner. The examples of best practices and approaches that SEAs and LEAs have taken since ESSA’s passage nine years ago are especially instructive for the field. This guidance will also be timely for stakeholders, given evidence from the Government Accountability Office and ED’s own monitoring efforts that States and school districts need significant additional support and assistance to understand what the law requires of them, what strategies have been effective in helping low-performing schools improve, and how they can leverage available resources to drive more equitable opportunities and outcomes for students.

In addition to our detailed feedback, which is enclosed with this letter and organized by draft guidance section, we offer several overarching recommendations for ED to consider below. These recommendations will not only strengthen the guidance but also support its implementation and use by State, district, and school leaders and build greater understanding of ESEA requirements and the responsibilities and opportunities for SEAs and LEAs to support school improvement.

(1) We recognize the draft guidance (rightly) reflects the statutory requirements for comprehensive support and improvement, additional targeted support and improvement, and targeted support and improvement schools (CSI, ATSI, and TSI, respectively). However, in our view, those statutory requirements are often minimal and inadequate to ensure that meaningful school improvement occurs — particularly when it comes to the involvement of SEAs in facilitating improvement in CSI schools and the involvement of SEAs and LEAs in facilitating improvement in ATSI and TSI schools. For example, certain questions in the guidance give the impression that TSI schools are largely on their own in developing and implementing a school improvement plan, without acknowledging that they may lack the capacity, resources, and knowledge that SEAs and LEAs have to identify evidence-based strategies that would better support their students.

Throughout the guidance, we urge ED to expand on how SEAs and LEAs can assume a leadership role and more strongly support school improvement activities, even where not statutorily required. This includes providing more examples of actions that SEAs and LEAs can take related to developing school improvement plans and selecting evidence-based interventions (based on a needs assessment and review of available resources), implementing and monitoring those plans, and providing resources to support low-performing schools in addressing any identified inequities. This could include developing templates, resources, and other tools; providing coaching or other staff to directly support identified schools; and creating policies to strengthen the school-improvement-plan process for all schools (such as requiring needs assessments and identification of resource inequities for all identified schools). We have noted several questions in our detailed feedback where the guidance would benefit from additional details or recommendations for optional actions that SEAs and LEAs could take.

(2) Improving low-performing schools is one of the hardest challenges SEAs and LEAs face, and this guidance can be a crucial tool in that work … if SEAs and LEAs use it. To that end, we encourage ED to develop a plan to raise awareness of the guidance among SEAs, LEAs, and key partners and to implement strategies that incentivize and support its use among State and district leaders. This could include strategies such as:

• • Encouraging or requiring SEAs to update their ESSA State plans for school improvement based on this guidance and establishing a timeline and submission process under which ED would review these amendments in the coming months;
  • Ensuring that the federal technical assistance centers (the National Comprehensive Center, regional Centers, and content Centers) are briefed on the guidance and are ready to disseminate and use it and related resources, with SEAs and LEAs;
  • Presenting the guidance at conferences, webinars, and other events with State and school district leaders, as well as presenting ED’s findings from targeted and comprehensive performance monitoring of ESSA implementation; and
  • Working with organizations that represent State and local leaders, including State chief school officers, State boards of education, State legislators, governors, district superintendents and other administrators, and school leaders, to ensure that they are sharing the guidance with their networks and understand it.

(3) Although the guidance on school improvement is welcome and sorely needed, SEAs, LEAs, and other stakeholders need similar guidance on other important — and related — areas of the ESEA that support school improvement and student outcomes and opportunities. We urge ED to issue similar non-regulatory guidance — with frequently asked questions, examples, and best practices — related to accountability indicators; n-size and the inclusion of student groups like recently arrived English learners and students with disabilities; annual meaningful differentiation of schools; the role of assessment participation rates in annual meaningful differentiation; and partial attendance.

(4) We recognize that funds under section 1003(a) of the ESEA are meant to support schools that are currently identified for support, consistent with the statutory requirements for identifying schools for CSI, ATSI, and TSI. However, there is compelling evidence that these funds are wholly inadequate to support and sustain improvement in all identified schools, let alone support the important roles SEAs and LEAs can play in facilitating the school improvement process. In future budget requests, we strongly encourage ED to request additional funding for section 1003(a). This could also include proposing new funding streams that would enable ED to provide sustainability grants for schools that have exited improvement and capacity-building grants for SEAs and LEAs.

By law, section 1003 funds are not designed to sustain school improvement efforts in schools that have exited status and are no longer identified; if section 1003 funding enabled a school to implement effective evidence-based strategies and improve student outcomes, the school and LEA would need to find their own funds to continue these strategies —potentially jeopardizing the significant progress the school has made. Federal funding for sustainability grants, with a matching requirement from SEAs and LEAs, would help bridge the gap and prevent schools that have made gains from being reidentified in the future.

ESSA made significant changes to school accountability and improvement and shifted more responsibility and decision-making authority to SEAs and LEAs. However, there is little funding available for SEAs and LEAs to build their capacity to carry out their new responsibilities (such as conducting or developing tools to analyze data and other evidence for needs assessments and resource allocation reviews; identifying potential evidence-based interventions and connecting LEAs and schools with external partners; providing technical assistance and coaching to staff and school leaders; implementing communities of practice; conducting oversight and monitoring of school improvement plan implementation; and more). Despite the need for funding to build and support these functions within SEAs and LEAs, SEAs can only reserve a fraction of the section 1003(a) funds. At the district level, these funds are intended to support individual schools, rather than invest in district capacity to improve multiple schools. Competitive school improvement grants for capacity-building at the SEA or LEA level could help these agencies facilitate effective school improvement processes and practices in identified schools.

Thank you for your continued focus on accelerating student academic progress, supporting meaningful school improvement in low-performing schools, and addressing resource inequities. We look forward to working with ED as it finalizes the guidance and would be happy to discuss any of these recommendations further with you and your team.

Sincerely,

All4Ed and EdTrust

Enclosure: Specific Q&A Feedback, By Section