A Look at TEA’s Plans for Compliance with Every Student Succeeds Act

Come hell or high water, the process of mapping out the state’s implementation of federal requirements that replaced the No Child Left Behind Act goes on. Because of the disruptions caused by Hurricane Harvey, however, federal officials gave the Texas Education Agency some extra time to submit the state plan required by the successor federal statute, the Every Student Succeeds Act. The new due date is September 25.

Meanwhile, Texas AFT has taken advantage of the period for public comment on the draft version of the TEA implementation plan. By way of background, you will recall that NCLB was replaced by ESSA in December 2015. As TEA has described it:

The new law increases flexibility and decision-making authority afforded states, encourages states and schools to be innovative, and holds states accountable for results. ESSA requires federal review and approval of a state consolidated plan, which provides a comprehensive overview of how each state will use federal funds to advance its own goals and visions of success for students.

Texas AFT’s comments on the draft plan were submitted on August 29. We found some things to commend but generally see the draft plan as a restatement of existing state policy rather than an embrace of the opportunity to innovate. We hope that comments like ours give TEA a nudge to revise the draft plan and seize the opportunity to depart from the test-driven status quo of the state accountability system. And we look forward to participating in the planned stakeholder engagement mentioned in the TEA plan over the next several months during the development of the new accountability system called for in HB 22, the revision of state law on accountability passed this spring by the Legislature.

Unfortunately, as of now the TEA plan continues the state’s over-reliance on outcomes on STAAR grades 3-8 and end-of-course assessments in ELA/reading, math, writing, science, and social studies. Texas AFT maintains that assessment of academic achievement should rely not only or primarily on standardized tests, but also on multiple other indicators of student performance that can inform teaching and learning. While ESSA requires elementary schools to offer the same assessments to all public school students statewide, states may choose to offer nationally recognized alternative assessments at the high school level (SAT or ACT, for example), as long as assessments are reliable, valid, and comparable. Texas should take advantage of the opportunity to expand the definition of academic achievement to include the alternative assessments that are currently considered by individual high school graduation committees to meet state graduation requirements in lieu of STAAR results.

This proposed state plan’s continued focus and over-reliance on standardized tests does little to address the concerns of 27,186 Texans who completed SBOE chair Donna Bahorich’s survey on testing and accountability in 2016. The public’s take on the state’s current testing regime was overwhelmingly negative: 63 percent supported scrapping the state’s STAAR tests in favor of a national test—for example, the SAT, ACT, or Iowa Test of Basic Skills–and 80 percent said students should be allowed to graduate or advance to the next grade level regardless of their state test results. Texas should take advantage of the ESSA re-write of federal education law to address public concerns and innovate in the way we measure student success to more accurately inform teaching and learning.

We are pleased to see that TEA proposes, in addition to including the four-year graduation rate in the state plan, to include as well extended-year cohorts with goals for the five- and six-year rates, along with interim targets over five-year intervals. This approach creates positive incentives for schools to admit, retain, and support students with challenges that prevent them from graduating in the standard four years.

We are also pleased that certain targets beyond minimum graduation requirements, such as industry or workforce certification, graduation from a particular program, or the attainment of an associate’s degree, are included as indicators of school quality and student success indicators for high schools. However, at the elementary level and in middle school, the measure of school quality or student success is based solely on outcomes of the STAAR grade 3-8 in reading and math. The over-reliance on a single measure continues the overuse of standardized testing and will make it difficult for teachers and schools to distinguish between growth and continuous development.

Again, we note that ESSA affords Texas the opportunity to rely on research-based methods that use multiple measures such as those pioneered by the New York Performance Standards Consortium. The consortium’s approach requires students to demonstrate accomplishment in analytic thinking, reading comprehension, research writing skills, the application of mathematical computation and problem-solving skills, computer technology, the use of the scientific method in undertaking science research, appreciation of and performance skills in the arts, service learning and school to career skills. Experts external to the schools, from universities and the business world, participate in reviews of student work. Such indicators could be piloted locally before incorporating them into the statewide system.

For English Learners, this draft plan has set a goal of only 46 percent of students making progress in achieving English language proficiency by the year 2032. This is not the sort of “ambitious” goal called for under ESSA, especially given the rapid rise in the number of students who do not speak English as their first language. According to a 2015 study by the Intercultural Development Research Association (IDRA), no secondary schools in Texas were consistently exceeding academic benchmarks with English learners. Compounding these problems is the chronic underfunding of educational services for bilingual students through an outdated state funding weight.

TEA’s plan vows to identify annually campuses meriting comprehensive support and intervention, beginning with the August 2018 school ratings, which will be based on 2017-2018 performance data. However, the plan states that TEA will not have new and improved assistance services fully developed until the 2018-2019 school year. Until TEA is fully equipped to assist struggling schools, it is inappropriate for schools to be subject to the severe sanctions entailed by the school-ratings scheme.

Regarding ESSA’s required review of resource allocation, the TEA draft states the resource review “may include analysis of per-pupil spending on identified campuses relative to non-identified campuses.” Per-pupil funding is a critical indicator of whether a school has sufficient resources, and it should be a required consideration when determining whether a school has adequate resources.

Texas AFT’s final comment on the draft plan called for a stronger focus on community schools as a proven, preferred option for campus improvement. Included in TEA’s list of transformation options for schools receiving competitive grants should be the choice of transforming the school into a community school. Including specific reference to the option of community schools would have the side-benefit of reducing the current draft plan’s empirically unwarranted emphasis on incentivizing resort to charter management or charter takeover as a preferred form of campus transformation.