Response to Colorado's ESSA State Plan

As a coalition of business leaders, Colorado Succeeds is committed to ensuring that Colorado’s kids are prepared for Colorado’s jobs. We write to you to outline our feedback and recommendations on the Colorado Department of Education’s (CDE) draft plan for implementation of the Every Student Succeeds Act (ESSA). Our feedback is directly related to the ESSA Principles our coalition developed (see attached), in partnership with our statewide network of chambers of commerce, industry associations, and economic development organizations.

We were proud to have served on the “hub” committee and various “spoke” committees that drafted and vetted parts of the plan. This work produced a number of positive aspects of the current draft plan worth highlighting, including:

  • The continued disaggregation of student subgroups in accountability (specifically students of color, students living in poverty, students with disabilities, and emerging bilingual students) and the limited use of a “small school” subgroup for race/ethnicity. We believe it is important that every student remains visible and counted in accountability systems.
  • The continued commitment to challenging academic standards in 10 content areas that align to postsecondary success.
  • The extensive stakeholder engagement process undertaken by the Department to develop the state plan, especially relative to other states.

Alternatively, there are several areas where we feel strongly that the plan should be amended to do one or more of the following: include missing information or details; outline specific requirements or processes; add or strike specific language; or share important data or other information with key stakeholders. We have outlined our feedback under our five principles for this work.

Colorado must maintain high expectations across the board. All schools should deliver education that meets challenging academic standards and prepares all students to succeed in whatever path they choose to take after high school. Educators, administrators, and schools must meet ambitious goals for serving all students and supporting them in achieving to their full potential.

Count every student in participation rate calculations, including all non-participants.
Rationale: CDE’s suggested approach to address assessment participation rates is inconsistent with ESSA, which requires that districts and schools assess at least 95 percent of students across a state. The current method of excluding parent refusals from the participation rate calculations creates a perverse incentive for non-participation that must be addressed. The plan references state law (HB 15-1323) as part of the rationale for the proposed approach, however it is imperative to note that Colorado state law in no way contradicts federal law. In fact, current state law balances protection from negative consequences for students and families if students choose not to participate in state testing with an explicit assurance that schools and districts do not incentivize non-participation. The 95 percent participation provision of federal law originated to protect the most vulnerable students, specifically students with disabilities, by ensuring their inclusion in statewide testing. As such, we recommend the state count every student in participation rate calculations, including all non-participants, to increase transparency and demonstrate a concerted effort to assess and report meaningful data about every child. We further recommend that the state reenact policies, in line with current state statute, that direct specific consequences for schools and districts with participation rates below 95 percent.

Revisit the metrics and cut scores in the accountability system to ensure the system reflects Colorado’s complete commitment to preparing all students for college and career success.
Rationale: In the draft ESSA plan, CDE reaffirms its “complete commitment to college- and career-ready standards” such that each student in the state’s public education system “is prepared to compete academically and economically within the state or anywhere in the nation or the world.” However, the accountability system set forth in the plan is almost entirely normative, where students, schools, and districts are evaluated on what they can do compared to other students, instead of on what students know and can do. This is particularly inequitable for students who have not historically been expected or given opportunities to succeed at the levels of their more privileged peers. We believe these normative measures, including (a) the shift to average scores to measure student achievement, (b) the reliance on median growth without plans to incorporate adequate growth measures, and (c) indicator-level cut scores, overall cut scores, and long-term goals based on percentile ranks, will lead to less transparency and lower expectations, especially for students of color and low-income students. While there is value in each of these metrics and methods individually, combined in the current structure it is possible that schools and districts will receive the state’s highest ratings without all groups of students meeting the expectations Colorado has been establishing for 20 years. We ask that CDE reconsider the metrics and cut scores used in the accountability system such that it asks schools and districts to prepare students for college and career success, not just to be better than the school down the street or on the other side of the Continental Divide.

Set more specific measures of interim progress for each student subgroup in order to reach the ambitious long-term goals set for academic achievement and graduation rates for all students.
Rationale: The plan states that Colorado will use a six-year timeframe for all students to achieve the 53rd percentile on the baseline scale and increase the graduation rate to 90.3 percent, but does not specify interim targets for each group to reach those targets. Considering the varying baselines for each subgroup, students will also need to make varying rates of progress to close gaps. While the plan acknowledges that, “in future years, once additional results have become available, the baseline scale and subsequent interim targets and long-term goals may need to be revised,” we ask that CDE make ambitious commitments to our historically underserved students through both long-term goals and interim measures and map out the specific strategies that will make it possible for students to achieve those targets.

Provide more detail about how Colorado will meet the needs of students with disabilities.
Rationale: Discussion of how Colorado will meet the needs of students with disabilities is generally limited in the plan, even in sections that focus on this subgroup of students. We believe the plan could provide more detail on how the State will support students with disabilities to meet state standards and graduate, the process for determining whether former students with disabilities will be included (or not) in the students with disabilities subgroup, and how “significant cognitive disability” will be defined as it relates to alternate assessments. It is also not clear to what extent the State engaged with disability stakeholders in developing the plan.

Provide more detail on the State’s “Theory of Action” for attracting and retaining educator talent.
Rationale: Classroom teaching is the number one in-school contributor to student achievement, making the quantity and quality of Colorado educators a top priority for all who care about education. While we agree with the theory of action articulated in the plan, we believe it requires more detail, especially around how CDE is planning to increase the supply of teachers in the pipeline who reflect the diversity of Colorado’s student population and the specific strategies that will increase access to high-quality induction programs and ongoing professional development. Measures should capture most factors that make a school successful. Any rigorous and fair accountability system must be based on outcomes—not inputs. While academic progress of students should be the primary indicator of school performance, school accountability measures in Colorado should reflect our broader understanding of school success and encompass as many students as possible.

Provide a clear roadmap for how the state will start to incorporate additional post-secondary and workforce readiness indicators into the accountability system.
Rationale: CDE provides very little detail on how it will actually begin to include additional measures into the accountability system other than using the support of the current Accountability workgroup. While we agree the timeline is short for the 2017-2018 school year, we also know the current measures are not enough to accurately define school success. We would encourage CDE to devote actual resources in developing a menu of options for districts to start to include post-secondary and workforce readiness measures such as Advanced Placement Incentives, International Baccalaureate, industry credentials, concurrent enrollment, and apprenticeships. Colorado Succeeds is eager to partner with CDE on ensuring these measures are valid and reliable across the state.

Every component of accountability should be aligned with the next. Colorado’s public education system should follow a continuum from early childhood through post-secondary education. Likewise, an aligned school accountability framework should delineate a coherent path between outcomes we expect students and schools to achieve, incentives to act and drive continuous improvement, and interventions triggered as consequence for failing to make progress.

Clarify processes for evaluation and continuous improvement.
Rationale: One of the most impactful roles CDE can play is to evaluate the progress and impact of school improvement strategies, and to share lessons learned with schools and districts across the state. There should be processes to gather information about implementation and interventions on the ground, as well as cost-impact analyses. We believe this will ensure scarce resources make it to the classroom and have the largest impact possible on students, as well as help make the case for additional smart investments in our education system.

Accountability should empower school and district leaders, while driving them toward better outcomes. Educators and school leaders are who know their schools best and are committed to transformative change are best positioned to lead school improvement. Colorado’s accountability system should empower district and school leaders with flexibility and choice among rigorous interventions. At the same time, in those situations where school and district leaders do not step up, the state must be prepared to intervene and drive the change that is necessary.

Clearly identify that the “more rigorous interventions” for schools identified for Comprehensive Support and Intervention align with the state accountability system.
Rationale: While the plan identifies the potential actions for schools that do not improve after the four-year timeline laid out in ESSA, the plan does not make it clear that these interventions also align with the accountability pathways that are embedded in state law. The state plan should make it clear that the strategies outlined in Senate Bill 09-163 (the Education Accountability Act) to improve and hold schools accountable are in alignment with the requirements in ESSA.

Encourage bold thinking and reward innovation with the 7 percent set aside for supporting school improvement.
We respect and appreciate the hard work CDE staff put in to come up with a strategy to allocate the 7% of state Title I funds ESSA requiring the state to use for the purpose of supporting school improvement. A majority of the hub committee supported a plan that “has been designed to: maximize impact on student learning; incentivize innovative and bold ideas; create fair and transparent processes; increase efficacy and efficiency; and provide fairness and predictability to LEAs.” However, several of these goals are in direct tension with one another, most notably the desire to “incentivize innovative and bold ideas” while also providing “predictability to LEAs.” We believe that achieving the goal of incentivizing fresh thinking and bold actions is best achieved through a competitive allocation process of the 7% set-aside Title I funds for eligible districts. Competitive allocations, however, are fundamentally at odds with the notion of ensuring funding predictability. This relatively small amount of reserved funding should be used to make big bets on new strategies to help Colorado’s neediest student, rather than distributed through a rigid formula like the other 93% of Title I funding. Underserved students in our state need and deserve bold new thinking, not more of the same.

Take advantage of the option to set aside 3 percent of Title I funds for Direct Student Services (DSS).
Rationale: The Elementary and Secondary Education Act made it clear that education is a civil right, and passage of ESSA presents an opportunity for CDE to explore innovation in the service of student learning. This optional set-aside would help ensure that both Comprehensive Support and Improvement (CSI) schools, as well as Targeted Support and Improvement (TSI) schools, have the resources necessary to improve outcomes for students. Taking advantage of this optional set-aside would offer pathways for improvement that go beyond professional development, leadership training, curricular support, and other adult and school-focused interventions, and would instead focus school improvement efforts directly on supporting opportunities for students. This grant program would allow the State to provide additional funding to Colorado’s most struggling schools, which we believe is the very essence and ethos of funding equity. These funds could then be used to increase access to career and technical education (CTE), concurrent enrollment, advanced coursework, school choice transportation, credit recovery, and components of personalized learning.

Information must be accessible, transparent, and actionable. State accountability should drive decision-making of district and school leaders, as well as parents. Performance information should be disaggregated by student demographics so educators and administrators can target resources and interventions to meet the needs of their students in a timely way. Results should be reported publicly in an easy-to-understand format, with straightforward ratings that clearly communicate the progress made by schools and districts in enabling all students to succeed and ensure parents and community members understand how well a school is serving all its students.

Include plans for how the State will release and present data to the public.
Rationale: We believe one of the clear intents of ESSA is to provide greater transparency and accessible information about how students and schools are performing. We see this in several places in the legislation, including statutory requirements for a State report card “developed in consultation with parents and…in a language that parents can understand,” and cross-tabulated data. Colorado has indeed been a leader in providing data and information about schools to families, communities, and policymakers. Yet we are concerned, particularly given recent practices of changing data reporting rules and delaying data releases, that CDE is not affirming its commitment to providing required information about schools to communities. We ask CDE to include in the plan: (a) how it plans to comply with data release requirements; (b) how it plans to present and release data and school performance information to communities, including families (inclusive of non-English speaking families and families without internet access), educators, policymakers, and researchers; and (c) how it plans to consult with these communities about how data is released and presented.

Omit new data suppression rules from the state plan.
Rationale: Colorado Succeeds is a strong proponent of protecting student privacy. We are also strong proponents of systems-level transparency. We do not believe these principles to be in conflict; CDE can protect individual student level data while also being transparent about how different groups of students in schools, programs, and districts are doing. Yet, CDE recently introduced new suppression rules without evidence of a breach or problem in historical reporting practices. In the Department’s recent introduction of new data suppression rules, it is significantly more challenging, if not impossible, to tell how the education system is serving students. This is a disservice to students and families. This information is critical to not only understanding gaps in the opportunities students across the state can access, but also to learning and sharing lessons about what is working for students. We cannot improve and support education if we do not know how students are performing. We believe including the new suppression rules in Colorado’s ESSA plan goes above and beyond federal requirements and cements a practice that needs much more thought, stakeholder involvement, and iteration before implementation.

Colorado Succeeds is committed to partnering with CDE, the State Board of Education, and legislators to realize improved student outcomes for Colorado students, especially those who historically have been the most underserved by our public schools. We appreciate the opportunity to submit feedback and look forward to continued collaboration to find solutions that drive towards equity, opportunity, and innovation to provide the best possible outcomes for all Colorado’s students.


Scott Laband
President Colorado Succeeds