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What Classifies a Student Subgroup As “Consistently Underperforming?” Here Is What the Approved State ESSA Plans Say

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December 12, 2017 02:43 pm

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The Every Student Succeeds Act (ESSA) reflects a clear intent to advance equity. Given this, it is critical to analyze how states are exercising their increased discretion to advance educational opportunities and outcomes for historically underserved students.

In analyzing the sixteen consolidated state ESSA plans the U.S. Department of Education (ED) already has approved, the Alliance for Excellent Education (All4Ed) identified some noteworthy trends across states. A particularly concerning pattern is the ways in which states have defined a “consistently underperforming” subgroup of students.

Under ESSA, states must establish a methodology to identify three categories of schools for support:

  1. Schools with overall low performance receive comprehensive support and improvement (CSI).
  2. Schools with at least one “consistently underperforming” subgroup of students receive targeted support and improvement (TSI).
  3. Schools with at least one very low-performing subgroup of students receive additional targeted support and improvement (ATSI).

States identify schools for CSI based on the performance of all students and identify schools for TSI and ATSI based only on the performance of student subgroups. ESSA sets explicit requirements for identifying a school for ATSI―a school must have a student subgroup that performs at the level of the lowest-performing 5 percent of all Title I schools. By contrast, states have the flexibility to define what classifies a student subgroup as “consistently underperforming” to trigger TSI.

Arriving at this framework for school improvement was not without controversy, contention, and a complex legislative history. In the end, however, the U.S. Congress ironed out a conceptualization of accountability that requires state education agencies to differentiate broad assistance for all students from directed assistance for specific subgroups of students.

While the first cohort of approved state ESSA plans incorporates satisfactory methodologies to identify schools for CSI, many do not implement ESSA’s policy regarding targeted support as intended under the law.

To provide a quick reference for the strengths—and shortcomings—of state ESSA plans, All4Ed has developed one-page “dashboards” that provide a green, yellow, or red designation for more than one dozen policies, including a state’s definition of a “consistently underperforming” subgroup. Fourteen out of the sixteen states with approved ESSA plans received a red or yellow designation in this area on their dashboards. A state received a red rating if its definition did not comply with ESSA requirements or was not meaningfully different from the statutory definition of a “low-performing” subgroup that qualifies for ATSI, meaning a student subgroup that performs at the level of the lowest-performing 5 percent of all Title I schools. The latter approach essentially ignores the intention of ESSA for states to identify three categories of schools. Congress clearly envisioned a distinction between TSI and ATSI, as U.S. Senator Patty Murray (D-WA), one of the leading architects of the law, explained in a recent hearing. Lastly, a state received a red rating if its definition was too vague to comply with the law.

States that received a yellow rating formulated a definition that is meaningfully different from “low performing,” but requires a student subgroup to perform poorly across three or more indicators to trigger targeted support. In practice, many states with this yellow rating require a student subgroup to perform poorly on all or most of their accountability indicators before providing targeted support. For example, in one state student subgroups receive a summative rating based on students’ performance on all the state’s accountability indicators. Schools with one or more subgroups that fall within the lowest 10 percent of performance in the state based on this rating for three or more consecutive years will be identified for targeted support. When implemented, this likely will mean that students will need to perform poorly across all the state’s indicators, including academic achievement, academic progress, high school graduation rate, English language learner proficiency, science proficiency, chronic absenteeism, climate surveys, and other School Quality and Student Success indicators to receive support.

Systems like this could pose a significant problem. Requiring a student subgroup to perform poorly in multiple areas to trigger support discounts the gravity of each indicator on its own. For example, in Florida in School Year 2013–14, 135 schools reported 80 percent of their Latino students graduated within four years. But at these same schools, 60 percent or fewer of Latino students achieved proficiency in reading. That same school year a similar trend occurred in Virginia where seventy-two high schools reported that 80 percent of their African American students graduated on time. But in these same schools, 60 percent or fewer of their African American students achieved proficiency in math. Essentially, if a state uses a composite to trigger targeted support, subgroups need to struggle egregiously in all areas to receive the support they need. Just as a doctor would not wait for a patient to receive multiple diagnoses before treating him or her, states must not wait until a subgroup underperforms on virtually all indicators before providing support.

Some states keenly recognize this and define “consistently underperforming” subgroups differently. In Nevada, for instance, a school receives targeted support when any subgroup misses its goal for academic achievement, or its goals for two or more other indicators, for two consecutive years. Meanwhile, Oregon identifies schools for targeted support when any subgroup of students has a high school graduation rate at or below 67 percent.

As states from the second cohort revise their consolidated state ESSA plans based on ED’s feedback, they should look to the policies in Nevada and Oregon as exemplars for constructing their definitions of a “consistently underperforming” subgroup of students. The policies in these two states ensure early directed assistance for historically underserved students who may not otherwise achieve their full potential. States and stakeholders can learn about bright spots and opportunities for improvement on this and related policies in each state ESSA plan based on an independent peer review at

But creating a strong definition of a “consistently underperforming” subgroup is only the first step. The real work lies in a school’s ability to create and implement evidence-based interventions and improvement plans. For more information about how schools can do this effectively, check out All4Ed’s report School Interventions That Work: Targeted Support for Low-Performing Students.

To learn more about the emerging trends in state ESSA plans, join All4Ed’s webinar “State ESSA Plans: Gift or Empty Stocking for Nation’s Students?” tomorrow at 3:30 p.m. Register and submit questions for the webinar at


Phillip Lovell is vice president of policy development and government relations and Shayna Levitan is an intern at the Alliance for Excellent Education.

Photo by Allison Shelley/The Verbatim Agency for American Education: Images of Teachers and Students in Action

Accountability, Elementary & Secondary Education Act, Every Student Succeeds Act

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