Joint 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
RE: Non-Regulatory Guidance, School Improvement and Related Provisions under Title I, Part A of the Elementary and Secondary Education Act of 1965 (ESEA)
Dear Ms. Siry:
The undersigned organizations welcome the opportunity to respond to the U.S. Department of Education’s (ED’s) request for comment on the draft non-regulatory guidance pertaining to the school improvement provisions within Title I, Part A of the Elementary and Secondary Education Act (ESEA). We submit these recommendations as a collaboration of national organizations seeking to advance shared education equity priorities through federal, state, and local policy advocacy.
We support and appreciate the recent guidance and want to commend the inclusion of several key components that were particularly beneficial. First, the clear, illustrative examples of ongoing state practices and other hypothetical scenarios were especially helpful in creating a better understanding of what is expected from state educational agencies (SEAs), local educational agencies (LEAs), and other stakeholders. Throughout, the guidance on how LEAs can best support school improvement efforts is also impactful and insightful. Furthermore, the guidance effectively outlines how SEAs can reduce barriers and streamline processes, while highlighting the responsibilities conferred to the states in relation to the federal government.
While this guidance is commendable, we strongly encourage the development of similar non-regulatory guidance focused on other key related areas of Title I, Part A, such as n-size, accountability indicators, the meaningful differentiation of schools, and the inclusion of recently arrived English learners and students with disabilities. These are essential elements of the ESEA accountability framework that warrant clear, detailed guidance to help states and districts navigate the challenges they face and ensure the correct implementation of the law. Consistent guidance across these areas would provide a more comprehensive roadmap to meet federal requirements while addressing the diverse needs of student populations.
Regarding areas of improvement in the draft guidance, our feedback (described in greater detail in the attachment) can be organized into several categories. First, we recommend further emphasizing the state role in supporting school improvement and addressing school needs and resource inequities. Currently, much of the focus of this guidance is on LEA’s roles and responsibilities, but SEAs can play a crucial role in leveling the playing field across districts as well as supporting and incentivizing strong school improvement practices. Second, while there are several worthwhile and constructive questions and examples referencing the role of LEAs in supporting school improvement, more can be added to strengthen and further clarify this guidance. LEAs work more closely with identified schools, and additional guidance on strategies they can use to effectively support struggling schools would be beneficial.
Third, more specific recommendations for what constitute “evidence-based” school improvement strategies — and discussion of how LEA and school leaders should be evaluating evidence — are sorely needed. The current draft emphasizes three that the Department has prioritized — high-impact tutoring, extended learning time, and addressing student attendance and engagement — but there is a much broader array of strategies that are evidence-based and those should be emphasized as well, such as data-based decision-making, multi-tiered systems of support, the deployment of high-quality instructional materials, teacher pay incentives, professional development and coaching, dual and concurrent enrollment programs and career-connected learning, and family engagement.
Additionally, more specific recommendations should be provided in the guidance, particularly for schools in Comprehensive Support and Improvement (CSI) but also for Targeted and Additional Targeted Support and Improvement (TSI and ATSI, respectively) schools, about how school improvement plans (SIPs) can support specific student groups that may need tailored interventions. We also recommend ways that the final guidance could include additional suggestions about how SEAs can provide more transparency into the school improvement process. Both would enhance the guidance’s inclusivity and applicability.
It would also be helpful to provide more real-world examples from ED’s monitoring of SEA and LEA implementation and/or links to external ED resources on the topics in the guidance, which could offer practical insights into successful strategies and help SEAs and LEAs learn from existing models. In several areas of the guidance, we recommend expanding the discussion on the benefits and drawbacks of different allowable approaches, such as how to maximize the utility of planning years and the trade-offs associated with various allocation methods for 1003 school improvement funds from SEAs to LEAs. This would help SEAs make more informed decisions that suit their specific contexts and needs.
Lastly, we note a few places in the guidance where the language could be clarified to avoid any ambiguity. While the guidance is strong, these suggestions would further enhance its clarity, comprehensiveness, and practical utility.
We thank you for the opportunity to comment on this guidance, and we appreciate the detail and comprehensiveness of this needed resource. We look forward to reviewing the final guidance and assisting the Department and external stakeholders as they implement the ESEA school improvement provisions.
Sincerely,
All4Ed
Center for American Progress
EdTrust
Education Reform Now
Migration Policy Institute National Center on Immigrant Integration Policy
National Center for Learning Disabilities
National Urban League
Teach Plus
UnidosUS
