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.

The Tennessee Educational Equity Coalition Submits Comments on Federal Every Student Succeeds Act Rulemaking Guidance

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. 
Click here to read full com­ments
Click here to read U.S. Depart­ment of Education’s Notice of Pro­posed Rule­mak­ing.
We encour­age you to provide feed­back to the Ten­nessee Depart­ment of Edu­ca­tion on ESSA impli­men­ta­tion. You can access the feed­back form until Mon­day, August 15th. 
 
Thanks to all of you for your com­mit­ment to stu­dents in Ten­nessee. Please let us know if you have ques­tions or sug­ges­tions for us.
 
-Gini Pupo-Walk­er