Feedback was submitted to the U.S. Department of Education on the Notice of Proposed Rulemaking which addressed the need to focus on Accountability, Supporting English Learners, and Equitable Access to Resources and Supports.
This week, the Tennessee Educational Equity Coalition submitted comments on the U.S. Department of Education's Notice of Proposed Rulemaking on Accountability, Data Reporting, and State Plans as amended by the Every Student Succeeds Act (ESSA).
The Coalition thanks and applauds Secretary of Education John King for his leadership in guiding the rulemaking for the ESSA, and his voice and commitment to equity and civil rights through the law.
However, the Tennessee Educational Equity Coalition highlights three areas of concern and includes recommendations for amending the proposed regulations to better address the needs of underrepresented students.
Key Comments on Accountability:- The ideal N-size of a subgroup must be 20 or smaller, given that we know that when
N-sizes are too high subgroups can disappear from the accountability system. - Action must be taken if a school is underperforming for any subgroup of students after two consecutive years.
- The definition of "underperforming" should be based on overall achievement towards a statewide goal or target that is tied to postsecondary readiness.
Key Comments on Supporting English Learner Students:- States must set ambitious, long-term goals for English language proficiency.
- ESSA regulations should also include a maximum state-determined timeline for proficiency so that states are incentivized to ensure the needs of ELs are met.
- States must also set consistent standards for determining when students require English language services and determining when students are ready to exit programs.
- Data on performance of students who exit the English Learner subgroup must be disaggregated from that of students who are classified as English Learners.
Key Comments on Access to Resources and Supports:- Resources must include, at minimum, equitable funding, effective teaching and leadership, and access to rigorous coursework.
- States must ensure that districts evaluate inequities not only between schools, but also within schools, and between groups of students within those schools.