Federal school improvement accountability guidance released

The guidance includes timelines for identification and exiting of schools in improvement status under the ESEA.

The U.S. Education Department’s draft Frequently Asked Questions: Impact of COVID-19 on Accountability Systems Required Under the Elementary and Secondary Education Act of 1965, 120 LRP 32606 (EDU 10/20/20), provides guidance on timelines for identification and exiting of schools in improvement status under the ESEA.

ED officials wrote that applications for COVID-19 waivers issued last spring included an assurance that schools identified for comprehensive, targeted, or additional targeted support and improvement in SY 2019-20 would maintain the schools’ improvement status for SY 2020-21. An identified school must “implement its improvement plan and receive appropriate supports and interventions.”

As all states applied and were approved for the waivers last spring, ED says state educational agencies don’t have the assessment data necessary for schools to exit improvement status in SY 2019-20, with the exception of schools identified for CSI based on adjusted cohort graduation rates. Adjusted cohort graduation rate reporting requirements were not waived by the department last spring, ED officials wrote. If the graduation rate data shows improvement necessary to exit CSI status, a state can exit such schools based on SY 2019-20 data.

The FAQ notes that state educational agencies have the option to use the COVID-19 State Plan Addendum to shift timelines “for school identification designation and application of exit criteria” for schools already identified for improvement. Thus, if an identified school was in year two of its designation for SY 2019-20, the SEA has the option to shift the timeline such that the school would be in year two for SY 2020-21.

An SEA that planned to implement exit criteria in SY 2019-20 for CSI and ATSI schools could also shift the exit criteria for such schools to SY 2020-21 using the COVID-19 State Plan Addendum, according to the guidance.


SEAs have the option to continue to follow the previously approved timeline for identification of schools for CSI, TSI and ATSI schools, or shift identification for CSI and ATSI schools by a year, even if it means the state has not identified CSI schools for three years using the addendum. For TSI schools, which must be identified on a yearly basis, an SEA that planned on identifying schools in fall 2020 must resume reporting in fall 2021 using data from SY 2020-21.

If a state’s consolidated plan to identify consistently underperforming subgroups includes using data from SY 2019-20, the state “must submit an amendment to the department to indicate how it will modify its methodology to identify TSI schools due to consistently underperforming subgroups in fall 2021.”

If the shift is for one year only, SEAs can apply using the COVID-19 addendum to their ESEA consolidated state plans. Longer-term shifts require states to follow the ESEA consolidated state plan amendment process.

FAQ: Impact of COVID-19 on Accountability Systems Required under the Elementary and Secondary Education Act of 1965 is open for comment through Nov. 20, 2020. Comments can be sent to [email protected].

Charles Hendrix covers education funding and other Title I issues for ESEA Now, a DA sister publication. 


Charles Hendrix
Charles Hendrix
Charles Hendrix has been writing about federal K-12 education policy, including the Elementary and Secondary Education Act, since 2006, and has in-depth knowledge of Capitol Hill and the federal legislative process. He is a senior editor with LRP Publications and the author of What Do I Do When® The Answer Book on Title I – Fourth Edition. He lives in South Florida with his son and their trusted chiweenie, Junior.

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