Our New Reviews of California and New York’s Draft ESSA Plans

Last spring, Bellwether partnered with the Collaborative for Student Success to convene an independent peer review of the first round of ESSA state plans. We brought together a bipartisan, nationally esteemed group of education policy experts to review the plans from 16 states and the District of Columbia.

We will do full reviews of the remaining 34 state plans after they’re submitted to the U.S. Department of Education next month. In the meantime, we decided to review the draft plans put out for public comment by California and New York, given the outsized importance of these two states in education policy and politics.

You can read our interim reviews of the California and New York plans here. Given the size of California and New York’s diverse student populations, as well as their geographic diversity, we believe feedback on their draft plans is important in not only strengthening these state’s final submissions, but also in providing information for other states still writing their plans.

This interim project was intended as a quick-turnaround, rapid-response analysis, and we did not use the full quality peer review process we used in round one — and which we will use again in round two. We recently received some feedback from California policymakers working on the plan about a few mistakes that were made in haste. We’ve made some edits as a result, and the reviews you’ll see on our website now incorporate these edits.

As one example, we wrote that, “at the indicator level… California has not yet specified definitions for chronic absenteeism…” While California has adopted a definition of chronic absenteeism for data collection purposes, their plan states they won’t know how they’re going to turn it into an indicator for accountability purposes until fall 2018. Our review could have been clearer about this distinction, and we’ve since updated it. As another example, we wrote “December 2018” where we should have written “January 2018,” and have since fixed this. In another place, we rephrased our comments about California’s exit criteria for low-performing schools. We had initially understood California’s proposed exit criteria to be normative, implying a school could exit simply if it improved its relative standing in the rankings. After taking another look, we have removed that language from our review. These revisions are now reflected in the online versions.

At the same time, there are also places where state policymakers may simply disagree with our goals behind this project, and hence our reviews of their plans. In comments to EdSource about our review, David Sapp, the deputy policy director and assistant legal counsel for California State Board of Education, referred to the state’s ESSA plan as “an application for federal funding.” While this is literally true — the plans are required to unlock each state’s share of federal Title I funding — this comment downplays the importance of these plans. We’re not just talking about a a small grant program; Title I is a $15 billion program nationwide and California alone receives about $2 billion a year from it. Title I traces its roots back more than 50 years, and Congress has stated that Title I’s purpose is to “provide all children significant opportunity to receive a fair, equitable, and high-quality education, and to close educational achievement gaps.’’

Those are the reasons we committed to this project in the first place, and it’s why we intend to once again conduct full reviews of all second-round states, including California and New York, following their final submissions in September. We’ll be fully transparent about that process, as we were in round one, and you can look for the results of that work later this fall.