Release of ESSA “High Concept Ideas” – A First-Look Analysis


To:         Education Reporters & Editorial Board Members

From:    Buffalo Urban League, The Business Council of New York State, Committee for Hispanic Children and Families, District-Parent Coordinating Council of Buffalo, Education Trust–New York, Educators 4 Excellence, EPIC-Every Person Influences Children, High Achievement New York, National Center for Learning Disabilities, National Council of La Raza, New York Educator Voice Fellowship, New York Urban League, Public Policy Institute of New York State, United Way of New York City

Subj:      Release of ESSA “High Concept Ideas” – A First-Look Analysis

At today’s Board of Regents meeting, the State Education Department (SED) discussed their proposed “High Concept Ideas” for implementing the Every Student Succeeds Act (ESSA). As we described in the policy brief our coalition released last month, ESSA presents major opportunities and risks to our shared goal of reaching high levels of achievement for all New York students. The following brief memo highlights several of the ideas that SED has shared – and, just as importantly, what’s missing:

Three Good Ideas

SED High Concept Idea What’s Good About It
#7: “To ensure that schools focus on students with low performance in [English language arts] ELA and math, we will give schools ‘full credit’ for students who are proficient (Level 3 and 4 scores on Grade 3-8 assessments and Levels 4 and 5 on Regents) and ‘partial credit’ for students who are partially proficient (Level 2 scores on grade 3-8 assessments and Level 3 on Regents).” New York’s accountability system must ensure that academic achievement drives school performance determinations and improvement strategies. Providing partial credit for students who are partially proficient encourages schools to help all students make progress towards proficiency – not just those who are closest.
#14: “To ensure that all students benefit from access to rigorous coursework, we will measure student participation in advanced coursework and measure the degree to which students score at specified levels on advanced high school assessments or earn college credit.” It is essential to look at both participation and performance in college-ready coursework – e.g., not just whether students enroll in Advanced Placement courses, but also how they perform on the AP test. Important note: This measure would be strengthened by adding career readiness based on academic preparation plus attainment of industry-recognized and valued credentials.
#17: “To ensure that schools engage students, we will hold schools accountable based on measures of chronic absenteeism and removal of students from instruction (e.g., suspensions).” Research shows that chronic absenteeism and student discipline have a strong relationship with important student outcomes, like high school graduation. As we discuss in the policy brief, New York State will also need to standardize definitions and safeguard the integrity of data collection and reporting.


Two Troubling Ideas

SED High Concept Idea What’s Troubling About It
#13: “To ensure that schools maximize opportunities for students, we will create a high school ‘Success Index’ that gives partial credit for students who successfully complete the TASC through AHSEP programs and programs at the school, BOCES, or night school; and extra credit for students who earn a Regents diploma with advanced designation, CTE endorsements, or a Seal of Biliteracy.” A true high school “Success Index” would measure students’ college and career readiness and incorporate some of these concepts – like attainment of a Regents diploma with advanced designation, biliteracy, and certain CTE endorsements – into measure #14 described above. But treating high school “success” as separate from college and career readiness – and providing credit for attainment of a TASC high school equivalency without evidence of positive long-term outcomes – does not help prepare students for postsecondary success.
#16: “To ensure that school districts have time to implement improvement strategies, we will create new lists of Comprehensive Support and Improvement Schools once every three years.” This proposal allows students to remain in one of the absolute lowest-performing schools in the state for years without the school receiving assistance and support for improvement. Schools should be identified annually so that they can receive the attention and help they need.


Four Ideas That Raise Questions

SED High Concept Idea Questions to Ask
#2: “To ensure all students have access to advanced coursework, New York develop procedures to allow districts to administer and accept multiple types of alternatives to state assessments at the secondary level.” How will rigor be maintained? Would this proposal simply maintain current policy – e.g., allowing students to count an SAT subject test, International Baccalaureate exam, or AP test towards graduation instead of a Regents exam in that subject – or would it open the door to watered-down requirements that lack rigor and effectively create lower tiers of high school diplomas that do not have value for students?
#10: “To ensure that all schools value student proficiency, student growth, and improving student outcomes, we will hold schools accountable for percentages of students who are proficient and partially proficient in ELA and math; progress in increasing the percentage of proficient students over time; and growth of students in ELA and math from year to year.”


#12: “To ensure that schools support students regardless of the subgroup that they are part of, we will hold schools accountable for closing gaps between groups of students.”

Looking at both progress over time and gap-closing are essential to equity-focused ESSA implementation, but how it is done is important. ESSA requires states to set ambitious long-term goals for ELA and math proficiency and to establish interim progress measures to gauge whether schools are on track to meeting them. New York should set an ambitious but achievable long-term goal that is the same for all groups of students, which will necessitate closing gaps as all student groups make progress to this goal. Why is SED creating separate measures for progress and gap-closing if these issues are integral – as they should be – to how the state determines school ratings for ELA and math proficiency?
#26: “To ensure that [English language learners and multilingual learners] ELLs/MLLs have enough time and English instruction to understand coursework, New York State ELLs/MLLs will be expected to become English proficient in three to six years, and this timeline should be extended based on factors like age, prior amount of schooling, and the level of proficiency at entry and grade entered.” Is the “extended” timeframe based on English learners’ characteristics within or beyond the 3- to 6-year window? Giving English learners three to six years based on factors like age, prior schooling, and level of proficiency at entry is consistent with the research. However, extending the timeline beyond six years could create an indefinite (and therefore non-existent) deadline.
#28: “To ensure that all students benefit from strong home-school partnerships, we will promote state, district, and school-level strategies for effectively engaging parents and other family members in their student’s education.” Beyond “engaging” parents, how will the state accountability plan ensure that parents are integral participants in shared decision-making when a school is developing and implementing improvement strategies under ESSA?


Six Big Issues That Need Further Attention

  1. Invisible Students: The state’s accountability system will establish a minimum number of students – known as the n-size – that constitute a subgroup for accountability purposes in each school. N-size is important because when students don’t count, their education may not receive the resources and focus that it should. Selecting an n-size of 30, for example, would render an estimated 11,486 Latino students, 9,538 African American students, 19,910 students with disabilities, 10,810 English learners, and 4,405 low-income students invisible for accountability purposes.
  2. Accountability For What: A major risk in creating a new accountability system under ESSA is that we will lose sight of what matters most: whether students are academically prepared for postsecondary success. To ensure that student success is the paramount goal, academic measures — including student proficiency, student growth, graduation rates, and any other academic measures of college readiness — should count for more than 75 percent of a school’s rating under ESSA. ESSA also presents an opportunity to establish additional valuable accountability indicators addressing college and career readiness, chronic absenteeism, and student discipline (including but not limited to out-of-school suspension). It is also important that the state not adopt too many accountability indicators, not adopt accountability indicators that are beyond the control of the school, and not adopt accountability indicators that cannot be disaggregated or that cannot bear the weight of accountability.
  3. Meaningful Goals: As noted above, the achievement goals that New York State sets for ELA and math and for graduation rates are as important as the indicators it selects. Establishing long-term or interim goals that are too low, that provide too many years to demonstrate real progress, or that do not reflect the importance of accelerating growth for low-income students, students of color, students with disabilities, English learners, and other historically underserved groups would represent a major failure and reflect poorly on New York State’s ambitions for its students and its education system. Goals and progress targets must be rigorous, setting expectations of high achievement for all students and ensuring progress toward closing statewide achievement gaps.
  4. Targeted Help for Consistently Underperforming Schools: New York State’s accountability system must demand that any school that misses these rigorous state-set goals or progress targets for any group of students for two years in a row take action to improve. The state should ensure that schools work with their districts to develop and implement targeted improvement plans.
  5. Clear and Transparent Ratings: The state should establish a single rating for each school that describes the school’s summative performance on the accountability indicators and clearly signals when any group of students is consistently underperforming. Providing a single summative rating for each school is an essential pillar of transparency, and should accompany a “dashboard” that provides a deeper look at key data.
  6. Getting “Un”-Identified: Under ESSA, states have significant latitude to determine not only when schools are identified for support and improvement, but also when they are able to exit this status. New York State should establish exit criteria from comprehensive or targeted support and improvement based on whether schools are making significant, sustainable progress toward their long-term goals and measurements of interim progress – not based on making minimal short-term levels of improvement.

We look forward to continuing to encourage the Board of Regents and State Education Department to take advantage of the levers and opportunities in ESSA to expand opportunity for all New York students.