The Iowa Department of Education in September released the final draft of the state’s Every Student Succeeds Act (ESSA) accountability plan required under the new federal law. In case you were not aware, ESSA is the reauthorization of the Elementary and Secondary Education Act (ESEA). The previous version of ESEA was No Child Left Behind (NCLB) that passed under President George W. Bush, and it went several years without being reauthorized until ESSA was passed by Congress and signed into law by President Barack Obama in December of 2015.

The law authorizes the U.S. Secretary of Education to approve or reject each state’s plan.

I had the opportunity to read Iowa’s ESSA accountability plan this week and wanted to share five concerns.

1. I hate the very idea of the ESSA state plan.

This has nothing to do with the Iowa Department of Education. When Congress was debating ESSA and Republicans promised this was going to provide more flexibility for states and return local control a lot of us knew better. Since ESSA required states to submit plans to the U.S. Department of Education we have yet another instance of states coming to the federal government and asking “mother, may I?”

The U.S. Department of Education has already shown that state flexibility is a myth by rejecting some plans. I wrote at Truth in American Education about this:

The state accountability system must follow ESSA’s required structure. That is not flexibility, and it certainly is not local control.

2. It doubles down on standards and accountability reforms.

ESSA requires assessments and state standards. Advocates will be quick to tell you that it does not require Common Core. It doesn’t in so many words, but as a requirement of the ESSA, states must “demonstrate” to the Secretary that they have adopted standards that align to the same definition of “college and career” standards used to force states into adopting Common Core under NCLB waivers (ESEA section 1111(b)(1) and (2) and 34 CFR §§ 200.1−200.8).

The Iowa Department of Education mentions in its plan that two components of their Multi-Tiered System of Supports (MTSS), which is also known as Response to Intervention, are “Assessment and Data-Based Decision Making” and “Evidence-Based Universal Instruction.” They describe this as part of the state’s support for educators, (pg. 5):

Assessment and Data-Based Decision-Making. This includes training on the implementation, interpretation, and use of assessment results to support educators to make appropriate instructional decisions. This also includes understanding data-based decision-making practices at both the system and student level. Evidence-Based Universal Instruction. This includes standards-based instruction, resources, professional learning on Iowa Academic Standards and the building blocks that create the infrastructure for universal instruction, as well as research/evidence-based instructional practices to meet the needs of all students.

First, the assessment results do not come quickly enough to help teachers make adjustments, at least not for the students who are currently struggling. (We still have not seen the 2016-2017 Annual Yearly Progress.)

Second, I don’t think “data-based” means what they think it means because nothing that has been advocated by education reformers has been “data-based.” Same goes for “evidence-based” instruction since they use the Common Core State Standards (aka Iowa Academic Standards for math and ELA) that is the epitome of dataless reform.

MTSS just doubles down on reforms that are more faith-based than evidence-based. I’m all for faith-based initiatives when we’re talking about the Bible; when it involves education reforms, not so much.

Is it evidence-based? Show us the evidence!

3. The long-term goals are not ambitious.

On page 35 they have the table of baseline and long-term goals for Iowa’s students, as well as, specific goals for specific subgroups.

I want to address some concerns about what appears to be an inequity between goals for black students and white students. The goals are drastically different. I’m in an unusual position of defending the Iowa Department of Education here.

Let’s take 3rd graders as an example.

The baseline they list for all third graders from the 2015-2016 Annual Yearly Progress (AYP) is 76.0 percent for reading/language arts and 78.7 percent for math. These numbers represent the percentage of all Iowa’s third-graders who are proficient in reading/language arts and math (not an average test score). By the way, the baseline in the ESSA plan is too low as the 2015-2016 AYP for 3rd graders in reading was 76.9 percent (25,939 of 33,729 3rd graders tested proficient on the Iowa Assessments). I assume the current sample size used by the state of Iowa determined their baseline (the previous N-Size is >10, NCLB required >30, for ESSA accountability Iowa will use >20), but I digress.

The overall long-term goal for 3rd graders in the state is 78.5 for reading/language arts and 81.2 for math. This target set for the 2021-2022 school year represents 0.5 percent per year.

Now if you look at white third graders as a subgroup. Their baseline is 80.6 percent for reading/language arts and 83.2 percent for math. Their goals to reach by the 2021-2022 school year are 83.1 percent for reading/language arts and 85.7 percent for math representing a 0.5 percent growth each year.

When you look at black third-graders, 49.0 percent is the baseline from the 2015-2016 AYP in reading/language arts, and it is 49.4 percent for math. The goals for the 2021-2022 school year for black third-graders are 54.0 percent in reading/language arts and 54.4 percent for math representing one percent growth each school year.

This benchmark seems low, but you have to consider the subgroups started from vastly different baselines. It would not be realistic to start at the same level. Does this achievement gap suck? Yes, yes it does, which brings to my issue, as it relates to proficiency benchmarks for Iowa’s ESSA plan which is two-fold.

An expectation for one-half or one percent growth per school year is not ambitious. Common Core and the other magical education reform silver bullets bandied about are so incredible proficiency should increase faster than that. A difference in goals per school year with different subgroups is an artificial way to try to “close the achievement gap.”

If you set the bar low, then you have a better chance to show progress. You’ve heard the phrase “shoot for the moon, land on the outhouse.” (I used this as a catchphrase for organizational goal setting.) Well, the Iowa Department of Education is shooting for the outhouse.

Also, an obvious question we should ask is this – what is considered proficient? We already know what Iowa considered proficient with the Iowa Assessments (which many believe was set too low by the state because of NCLB), but what about the new assessment? We’ll have to see.

Under the state of Iowa’s definition of proficiency under the 2015-2016 AYP, 77.9 percent of 11th graders are proficient in reading/language arts, and 81.7 percent are proficient in math. ACT, however, reported only 31 percent of Iowa’s graduates are college-and-career ready. Houston, we have a problem.

4. Schools will be graded in-part based on the school environment.

The Conditions for Learning student survey, adapted from the more extensive Iowa Youth Survey (IYS), will be an indicator within the ESSA accountability index. The Conditions for Learning survey will by year three make up 18 percent of an elementary or middle school’s score for the accountability index; for high school, it will make up eight percent of their score.

The Iowa Youth Survey historically was given biannually to sixth, eighth, and 11th-grade students. The state plans to administer the Conditions for Learning survey to all students grades 5-12 according to the ESSA plan by 2019. The ESSA plan does not specify the distribution method or the exact questions, but it does say it will favor current IYS questions as they have data trends for those.

Some examples of the questions that could be used (rate how true):

“Students in this school respect each other’s differences (for example, gender, race, culture, learning differences, sexual orientation, etc.)”

“My teachers give me useful feedback on my work.”

“In the current school year, how many times have you filled out and turned in a Bullying/Harassment Report Form to this school?”

“I have received a threatening or hurtful message from another student in an e-mail, on a website, on a cell phone, from pager text messaging, in an internet chat room or in instant messaging.”

“There is at least one adult at school that I could go to for help with a problem.”

The larger IYS included behavior questions, and these questions are somewhat benign. My concern is that school environment surveys are subjective, so the scores making up 18 percent of an elementary school and middle school’s accountability rating score for ESSA is high. Also, we don’t know exactly what will be on that survey, if parents are notified when it is given, whether or not students will be allowed to opt-out, and who will get the student-level data.

I also shudder at the possibility the survey results could lead to new legislation and new mandates in order to improve Iowa’s schools’ environment.

5. There is no mention of an opt-out process.

Supposedly under ESSA states were able to outline an opt-out procedure. Iowa didn’t do that, and the Iowa Department of Education has not been forthcoming about whether parents can legally opt their children out.

No Child Left Behind required 95 percent participation, but that was a mandate for states and school districts, not for individual students. ESSA also requires 95 percent participation. The Iowa Department of Education has said Iowa Administrative Code (executive rules) Chapter 281-12 requires 100 percent participation. I find that humorous since I’ve read it and found no such mandate. Schools are mandated to administer one district-wide assessment annually, but nowhere in the Iowa Code or the Iowa Administrative Code does it say students are required to take the assessment.

Student participation accounts for 10 percent of a school’s ESSA accountability index score. It seems like it will be all or nothing so schools and the Iowa Department of Education will continue to pressure students to take the assessment and mislead parents about their right to opt-out.

Conclusion:

I could write more, but this article is already longer than I planned. In a nutshell, what I see from Iowa under the new ESSA accountability plan is more of the same – a continuation to be a follower of educrat groupthink that has not served students or parents well.