Tag Archives: Title I

How Will States Handle New Title I Powers with Minimal Federal Oversight?

U.S. Secretary of Education Betsy DeVos, photo by Michael Vadon via Flickr

U.S. Secretary of Education Betsy DeVos, photo by Michael Vadon via Flickr

Last week Congress threw Every Student Succeeds Act (ESSA) accountability regulations out the window, and all signs from the Department of Education under Secretary Betsy DeVos point to a minimal review of state ESSA plans. For example, a little known ESSA provision could change the shape of Title I spending in schools, and under new guidelines, states don’t even have to describe their plans for implementing this new power.

Title I is a $14 billion federal grant program aimed at supporting low-income students. For decades, Title I programs have been split into two categories: targeted programs, where funds exclusively support low-achieving students, and schoolwide programs, where funds can support schoolwide improvements more flexibly. Prior federal law restricted schoolwide programs to schools with more than 40 percent low-income students. Under ESSA, all states now have the power to waive the 40 percent requirement and allow schools with less concentrated poverty to implement schoolwide reforms using Title I funds. This new flexibility could make Title I programs more effective for disadvantaged students — if states step up and use their new power wisely. But, while the Obama-era regulations required states to explain how they would issue schoolwide Title I waivers, the new template issued yesterday by the Trump administration doesn’t ask states about this provision.

There are several upsides to the expansion of schoolwide programs. Schoolwide Title I programs require schools to perform a comprehensive needs assessment, while targeted programs do not. These needs assessments are designed to engage the whole school community, and use data to identify to key areas for improvement. In contrast, a common criticism of targeted Title I programs is that they encourage schools to implement small add-on programs, like tutoring, rather than addressing bigger issues that impact all students, like curriculum and teacher quality. Schoolwide programs also allow for Title I funds to be combined with other federal and state funding streams, amplifying the impact of multiple small funding streams and reducing administrative overhead.

But there are risks that come along with this flexibility. Title I’s convoluted funding formulas already give plenty of money to wealthy, large school districts, and unchecked flexibility in spending could further dilute the effects of Title I on its intended beneficiaries — low-income students. While combining multiple funding streams reduces administrative burdens, it can also remove guardrails to ensure that money is being spent responsibly and equitably. That is why state monitoring of school Title I plans and interim progress indicators are all even more important under ESSA.

In a few states, schools below 40 percent low-income students are already allowed to implement schoolwide Title I programs. Even before the passage of ESSA, the Education Flexibility Partnership Act (Ed-Flex) approved ten states for Title I flexibility beginning in 1999. More recently, several states used their No Child Left Behind Flexibility Waivers to allow for schoolwide Title I programs in their lowest performing schools.

The success of this new nationwide flexibility will depend on states taking an active role to monitor and assess schoolwide Title I programs — whether they are enacted at schools above or below the 40 percent threshold. Early drafts of ESSA state plans suggest that many states do not yet have a clear vision for this — and now they don’t even have to include details on Title I waivers in their state plans at all. Out of 15 draft ESSA state plans available online last week (all likely to be rewritten), nine states had very broad, non-specific language for how they would review requests to shift to a schoolwide Title I program.

Light oversight is no excuse for states to take it easy. States should not just rubber-stamp requests for flexibility when it comes to Title I when there is so much at stake for low-income students, and advocates should push for more specifics on how states will ensure Title I money is well-spent.

Could Potential Trump Education Plan Make Inequality Greater Again?

When it comes to education policy, Donald Trump’s positions are largely a mystery. But here is what we know so far: he hates the Common Core, and he regularly flirts with the idea of eliminating the U.S. Department of Education. There. That’s the whole of Trump’s plan to make American Education Great Again. Unfortunately for The Donald, improving America’s schools will be far more complicated than eliminating high-quality standards state-by-state and downsizing a federal bureaucracy.

Yet, what Donald Trump lacks in experience or expertise, he more than compensates, he claims, by hiring the very best people. Enter New Jersey Governor Chris Christie, one of the favorites to be Trump’s running mate, and whose education policies would be a terrible national model for a Trump Administration to pick up.

The mere thought of Governor Christie driving national education policy is enough to make almost any teacher shudder. Remember when he said that teachers’ unions deserved a “punch in the face?

As troubling as that comment is, Governor Christie’s latest idea — so called school “Funding Fairness — is particularly odious. At first glance, the proposal could be attractive: ensuring all students receive the same baseline level of state funding. In practice, however, this new funding model would amount to taking millions of dollars from school districts with highly concentrated student poverty, and redistributing those funds across more affluent districts. As a result, many urban, high-poverty districts could lose millions.

In other words, Governor Christie’s big idea to make public education great in New Jersey is to take millions of dollars from students in need,  and give them to students who are better off. That idea is completely backward and unfair.

But should Trump and Christie make it to the White House, this profoundly inequitable approach to school funding could become national policy. Continue reading

What’s Behind Door #3? The Giant Local Testing Loophole in Alexander’s ESEA Proposal

There’s been no shortage of column inches devoted to testing and the “choose your own adventure” approach in Sen. Lamar Alexander’s draft to rewrite the Elementary and Secondary Education Act. And annual testing will likely dominate the discussion at the first Senate hearing on reauthorization today, even though many (including key witnesses, like Brookings’ Marty West) have already shown why backing away from annual testing is a horrible plan.

But annual testing is only half the story. That’s because Alexander’s bill doesn’t just offer two statewide testing options for policymakers to fight about. It also offers a separate testing option for districts on top of the state choices. And although education wonks are up-in-arms over the merits of door #1 vs. door #2 for states, most have, unfortunately, ignored the giant local testing loophole that is behind door #3.

Through it, districts could opt-out of statewide testing and use their own tests instead, regardless of whether Congress chooses door #1 or door #2. But the real kicker is that this loophole isn’t actually new at all. Alexander’s draft bill just makes it far easier for districts to take advantage of–and abuse–existing flexibility. 

Districts would only need state approval that their local assessments meet the same federal requirements with which state tests comply. And given the increasing number of districts pushing back on state testing, door #3 would be an irresistible option for many, even as it undermines the comparability of data between schools for evaluation and accountability; states’ abilities to provide technical assistance, support, and professional development to districts; and state investments in new assessment systems aligned to college- and career-ready standards.

Continue reading

Alexander’s ESEA Draft: A Plan Isn’t a Good Plan

We already know just how little has changed in Senator Alexander’s new ESEA reauthorization proposal since his last stab at rewriting the federal law in 2013. But it’s worth elaborating on just how far Alexander is willing to go to “stop the national school board.” Never mind Senator Murray’s and Secretary Duncan’s insistence that federal policy must serve as a safeguard for educational equity and opportunity, and combat “the soft bigotry of ‘it’s optional.” Alexander’s draft does exactly the opposite. It doesn’t just provide more options for states by limiting the federal role. It allows for unlimited options by eviscerating the federal role.

That shift is most apparent in Alexander’s approach to Title I. Under his proposal, nearly $15 billion in Title I dollars would be distributed without any real mechanism to ensure state compliance. In all, I counted over a dozen ways in which federal oversight of state implementation would be hampered in Title I alone: The bill would create barriers for the Department to enact regulations if a negotiated rulemaking fails to reach consensus and would prohibit the Secretary from specifying, defining, or prescribing just about anything related to state standards, assessments, accountability and improvement systems, or educator evaluations. In short, the theory of action behind the nation’s largest federal K-12 education program would boil down to: submit a plan.

In general, I’m not a fan of plans. Just try reading the ones states submitted to receive an NCLB waiver–so many details, so little information on whether those detailed policies are actually improving student outcomes. But the Title I plans states would develop to comply with Alexander’s proposal could be far worse, lacking both detailed narrative and actual evidence to prove states meet key requirements.

That’s because, as my colleague Chad Aldeman pointed out (again), Alexander relies on assurances that states are holding up their end of the bargain, rather than demonstrations that they are (as NCLB requires). Assurances can be nothing more than promises—and the Secretary has few tools to enforce them in the new draft.

What does policymaking via assurance look like? Here’s a Cliff’s Notes version of a Title I state plan that could meet the requirements of Alexander’s proposal:

Dear Secretary,

Here in the 51st state, we have really great standards.  Our colleges pinky-promise that students who meet the standards won’t be placed in remediation.

Further, we have really great tests, even though a handful of districts are creating their own and our process for ensuring reliability or consistent scoring is half-baked. And we’re also only administering state tests in three grades, so that means there aren’t any statewide growth measures—just local ones, maybe, but we swear we’re keeping track of that.

Speaking of growth, we have an accountability system that’s super awesome. It’s based on a multiple measures dashboard (see attached 47-factor dashboard that helpfully breaks down information into an easily downloadable, 33-page, 10-font report for each school), that includes the four-year adjusted cohort graduation rate (since that’s the only detail the feds require), proficiency rates, and a bunch of other metrics.

And if we do find that some Title I schools are low-performing—and we’re not saying that they are—we promise that our districts are working hard to improve them. We don’t know if those efforts are based on science or research, but we’re sure you don’t mind.

Keep an eye out for our report cards!

Sincerely, 51st State

Alexander’s draft bill may appear to keep at least some key elements of federal policy intact: challenging standards, testing, school ratings, improvement strategies, and so forth. But thanks to the reliance on assurances, its Title I provisions are merely options masquerading as enforceable requirements.

It just goes to show, the only thing worse than a plan… is a really bad one.