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Ed. Department Offers States Feedback on Waivers

The second round of states26 plus the District of Columbia—that applied to the U.S. Department of Education for wiggle room from the No Child Left Behind law got feedback on their requests in a round of letters sent April 17. (To recap, 11 states have already been approved. Check out the 27 pending applications here.)

Education Week examined 22 of the 27 letters, and found some common areas of concern:

•Almost every state needed to do a better job of explaining how they'll train teachers and principals to implement the new math and reading standards developed under the Common Core State Standards Initiative. (A tricky issue all around, as outlined in this great story by my colleague Steve Sawchuk.)

•Many of the states were asked to spell out how they would make the standards accessible for English-language learners and students in special education. And some states—including Vermont and South Dakota—didn't do enough to make sure that graduation rates are a significant factor in accountability.

•States also had difficulty spelling out how they would cope with transitions—in some states to the new Common Core, and in others from their old accountability systems to their new ones.

•The department was also critical of the way many states crafted "annual measurable objectives" (goals for schools.) There was concern that many of the targets states set weren't rigorous enough, or didn't do enough to look out for the achievement of particular subgroups. Many states didn't go far enough to explain how they would intervene in schools that are missing achievement targets because of subgroup students (such as English-language learners).

•States also got dinged for their plans concerning "Priority" (bottom 5 percent) and "Focus" schools (those that are in danger of slipping into the bottom). In some cases, states didn't do a good job of spelling out exactly how they'd intervene in these schools. And in other cases, they didn't set a high bar for how they would decide when a school should get out of "Priority" or "Focus" status.

•Almost every state was also called out for not doing enough to explain how they were consulting with stakeholders. In some cases—such as Idaho and South Dakota—states were asked to do more to reach out broadly to teachers, community members, and others. Other states were asked to connect with particular communities. Kansas, for instance, was told it needed to engage groups representing English-language learners, students with disabilities, and Indian tribes. Ohio got similar instructions.

The department also noted that some of the requests went beyond the scope of what states were told they could ask for under the NCLB waiver guidelines. For instance, Vermont wanted to add a fifth model it could use with schools getting money under the School Improvement Grants, and Ohio wanted to give English Language Learners an extra year before they have to take English language arts tests for accountability purposes. The department essentially said, we'll get back to you on those separate issues. 

Here's the rundown on individual states:

The department is worried that Connecticut's new system could mask the performance of some low-performing students. The state also needs to do more to explain how it will identify high-performing schools (so-called "reward" schools). But the department liked the idea that the state would allow high-performing teachers in "reward" schools take a sabbatical to share best practices. More here.

Idaho's application was strong on professional development. But the state need to do a better job of setting annual measureable objectives (AMOs) for reading, math, and subgroups, and of explaining the role subgroups will pay in its overall accountability system.

The department is worried Illinois didn't specify rigorous enough interventions for "Priority" and "Focus" schools. And the department has concerns about Illinois' teacher evaluation system, including the fact that it wouldn't be fully implemented until the 2016-17 school year. But the state stood out for its work so far in implementing college-and-career ready standards.

Iowa set its goals too low when it comes to long-range performance targets. Subgroups don't play enough of a part in the portion of its accountability system aimed at closing achievement gaps. And it needs to do more to explain how it will use its accountability system to identify schools in different categories. The state also needs to set a high bar for when a school can exit "Priority" or "Focus" status. But Iowa did a good job of coming up with a plan for monitoring struggling schools. 

The department wants more information on how Kansas will identify and address the needs of subgroups, and implement their turnaround plans. For instance, the department doesn't think Kansas did enough to distinguish between how it will intervene in "Priority" schools (bottom five) versus "Focus" schools" (other troubled schools). The department is also unsure of how the state—which is piloting a new teacher evaluation system—will put it in place. But Kansas got high marks for its plans to recognize and reward high-performing schools and teachers.

North Carolina's application is strong in a number of areas, including procedures for pinpointing which schools need support. And it got a rare shout out for its plan to provide professional development on college-and-career-ready standards. The state also got a thumbs up for the initial implementation of its teacher evaluation system. Biggest weaknesses? The state needs to better explain how its new accountability system will interact with other supports for schools. And North Carolina needs to bolster its "exit criteria" for Priority and Focus schools.

Oregon needed to do a better job of differentiating between Priority and Focus schools. And its AMOs don't meet the waiver requirements. There's also not enough detail in the application about how the state will transition from its current accountability system to the new one. But Oregon got praise for demonstrating how it would work with outside partners (including the American Diploma Project) to transition to college-and-career ready standards.

Oregon also sent us their response to the Education Department. 

Ohio, a Race to the Top winner, got the thumbs up for its work so far on developing teacher and principal evaluation systems, and for showing how it would identify schools with big achievement gaps. But the state needs to improve its plans for serving English-language learners and special education students in transitioning to college- and career-ready standards. And the state needs to better explain how it will support Priority and Focus schools, and set a high bar for getting schools out of Priority or Focus status.

South Dakota needs to do a better job of setting AMOs for reading and math, and of including subgroups in its accountability index. And it must explain how student growth will be measured at the high school level. But the state's plan for standards implementation is strong.

The department had a number of issues with Utah's accountability plan, such as a lack of AMOs, including for particular subgroups. There also just weren't enough protections in the plan to make sure that subgroup achievement wouldn't be masked, the department wrote. Utah also didn't do enough to show that it would put rigorous interventions in place for Focus schools, particularly for those that struggle with subgroup kids. And Utah doesn't have enough incentives or supports proposed for schools that are Title I, but aren't Priority or Focus status. But Utah's application was strong when it comes to transitioning to new standards and in developing a foundation for its teacher evaluation system.

Vermont  was weak overall in explaining its proposed accountability system. And the state didn't provide enough detail on the transition to college- and career-ready standards.The application also didn't do enough to spell out how the state would support Priority and Focus schools. But the state got a gold star for its outreach efforts to stakeholders.

Interestingly, Virginia—the one state that so far that has applied for a waiver without participating in the Common Core State Standards Initiative—got positive feedback from the department on the infrastructure it has put in place to develop strong standards. (Virginia's application includes a lengthy description of its work with its postsecondary institutions—as well as national organizations such as Achieve and the Southern Regional Education Board—to develop college- and career-ready standards without going to Common Core.)

But Virginia got dinged for its accountability system, which the department contends doesn't do much on subgroup accountability beyond requiring schools to report progress. And the application doesn't include meaningful annual measureable objectives. Plus, the department wasn't clear on how Virginia will put its new teacher and principal evaluation system in place.

The standout, shining star based on the letters we received? That appears to be Maryland, a Race to the Top winner, which got a feedback letter that was long on praise and short on areas for improvement. The department had a long list of positives - including Maryland's plans for intervening in struggling schools, transitioning to college- and career-ready standards, and its work so far on teacher evaluation. The department wanted more specificity when it comes to how the Old Line State will validate the measures it's using in the teacher evaluation system. 

Big, big thanks to my colleagues here at Edweek for helping me collect these letters.—and even bigger thanks to the state folks who shared their letters with us.

UPDATE: So where are the rest of the letters? Great question. Most states listed above considered the letters public documents and sent them to us. Delaware, Nevada, New York, Rhode Island, and the District of Columbia, apparently don't agree—they declined to share their letters. We're still waiting to hear back from other states and will update this space as we get more.

UPDATE 2: Another big thanks, this time to Arkansas and Mississippi for sharing their letters with us. Many of the trends noted above continue in these two states.

Arkansas was lauded for its plan to transition to college-and-career ready standards, including its "impressive" professional development activities. But, as with other states, the department questioned the state's plan for intervening in priority and focus schools. And, as with other states, the department is worried the achievement of subgroup students could be obscured by Arkansas' decision to combine subgroups. Arkansas also needs to be more clear about how it will ensure that schools are held accountable for the graduation rates of subgroup students. Arkansas also was asked to provide more information about how it plans to ensure that free tutoring providers are properly screened.

Mississippi got brownie points for its outreach efforts on college-and-career standards. But, overall, the department was unclear about how the state was going to make the transition to new standards. And the department has a long list of things for the state to clear up when it comes to its accountability system. The department is worried the state didn't set ambitious enough goals. And it's concerned that subgroup students may get lost in the shuffle, including when it comes to graduation rates. The department also cited Mississippi's interventions for priority, focus, and other Title I schools.

UPDATE 3: South Carolina just posted its waiver feedback letter—and a response. The Palmetto state got a rare shout-out for its work in looking out for subgroups, and high marks on standards and teacher evaluation. But the department was underwhelmed by the state's goals for student acheivement in elementary and middle schools. The feds are also concerned that the state's plan for measuring student growth isn't rigorous enough.

Another weakness? Outreach to districts. Maybe that's because the South Carolina Association of School Administrators held a meeting with Rep. James Clyburn, D-S.C. to ask Secretary Duncan not to approve the state's request?

South Carolina has also posted an edited version of its waiver application. The state made some interesting changes, such as changing its "n-size" from 40 to 30, and making graduation count more in its accountabilty system for high schools. They've also included a long justification of their goals—and a long and involved description of the rigorous process they plan to use in selecting providers for free tutoring services, among other changes. The state also added information in its section on "outreach" explaining how it has responded to concerns about subgroup accountability.

UPDATE 4: Another thank you, this time to the folks in Washington state for giving us their letter.

Washington won praise for its work on standards, and for adding tests in subjects other than math and reading to its accountability system. (Washington will also test in science and writing.)

But the department was troubled by its plans for focus and priority schools. Specifically, the feds think Washington's fixes for priority schools don't match-up with the department's turnaround principles, particularly when it comes to teacher effectiveness and using data to inform instruction. (Interestingly, Washington is one of a handful of states that's planning to keep choice and tutoring in place for focus and priority schools.)And the department is worried Washington didn't set a high enough bar for schools to exit priority or focus status.

UPDATE 5: Michigan was kind enough to send us their letter as well. As with Washington, the feds complimented Michigan's move to include other subjects (in this case, science, social studies, and writing) in their accountability system.

But the department needed more clarity on how the state's accountability system would work for subgroup students. For instance, they're worried that Michigan's "bottom 30 percent" subgroup will mask the achievement of some kids. And they think the state's 'n-size' of 30 may be too high. Plus, they're concerned graduation rates didn't play enough of a role in the state's accountability system.

UPDATE 6: Thanks to Arizona and Louisiana for sharing their letters with us. Arizona won kudos for its work on standards and teacher effectiveness. But, as with other states, the department was dissatisfied with Arizona's accountability plan. The state didn't set ambitious enough goals, and it didn't do enough to look out for subgroup students, including when it comes to graduation rates.

Louisiana has posted its letter and response online. The department was impressed with several aspects of Louisiana's plan, including the "rigor" of its interventions for low-performing schools. But peer reviewers were also concerned about how subgroup students would fare. Louisiana has already revised its application to address those concerns.

UPDATE 7:  And thanks to Missouri and Wisconsin for sharing their waiver letters.

Like other states, Missouri faced a rash of questions about its accountability system. The department said the state lacked "a complete system" for holding all Title I schools accountable for student achievement. And, as in other states, the department was worried that the state's AMOs aren't ambitious enough. They're also worried about the state's proposed interventions, for both Title I and non-Title I schools. But the state was lauded for its plan to transition to college-and-career ready standards.

Wisconsin was strong in an area noted as a weakness for a number of other states - helping special populations, such as English Language Learners transitioning to the Common Core state standards. But the Badger state - like many others - was told its plan lacked ambitious AMOs, including for subgroup students. And it was told it needed to be more specific exit criteria for priority and focus schools - which is another major recurring theme in the waiver feedback letters.


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