Shaping Our View on School Quality and Improvement: Comments on Title I Accountability Regulations

Don’t miss this week’s other commentary piece on Due Diligence.

This week, NACSA submitted comments to the US Department of Education concerning proposed regulations for Title I Accountability and State Report Card requirements in time for the August 1 deadline. The regulations are an important step in the implementation of the Every Student Succeeds Act (ESSA) that shape many elements of the way we view school quality and school improvement.

While the impact of many of these regulations will be similar across all public schools in each state, some have discrete consequences for charter schools and charter school authorizers.

NACSA’s comments focus on two areas that have a significant impact on authorizers, and one area that has larger implications for all public schools:

1. Annual reporting: state report cards should be meaningful for families, not misleading.

The proposed rules would require a new state report card element that reports on authorizers. For every school in each authorizer’s portfolio, the state report card would include two comparisons: (a) the academic performance of the school compared to the local school district or other geographic area, and (b) the enrollment demographics of the school compared to the local school district or other geographic area. The State would determine how the comparisons are put together.

NACSA supports annual reporting, but it must be meaningful and consistent. The proposed reporting would be burdensome for states and potentially misleading, making charter schools appear better or worse than they are. We instead recommend that such a report use absolute data (not comparative), which would be more accurate and would provide unambiguous information on enrollment characteristics and school performance to parents.

2. State support initiatives for low performing schools should work with state law, not against it, and protect an authorizer’s ability to hold charter schools accountable for their performance.

The proposed rules are constructed to treat charter school authorizers similar to Local Education Agencies (LEAs) when it comes to state support and intervention in school districts with persistently low-performing schools. States would have the option to design Title I policies that would allow or mandate direct support or intervention in some authorizers and the charter schools in their portfolios.

NACSA opposes the inclusion of authorizers in this rule. Instead of supporting school improvement, it could encourage states to design ineffective—and potentially harmful—systems that could undermine authorizer-driven accountability. This would make it harder for authorizers to close charter schools for performance. The Department should remove authorizers from the rule and instead use guidance to provide states with non-binding recommendations that capture the complexity of accountability and support in the charter sector.

3. Ensure states apply the “dropout factory” label accurately.

Drop-out recovery schools, known as Alternative Education Campuses (AECs), are inappropriately swept up into the “drop-out factory” label when states are required to use only a four-year cohort graduation rate to identify schools. The federal rules should allow states to use a smart, differentiated method that truly identifies schools that warrant a “drop out factory” label.

NACSA expects the best from the charter sector. With smart Title I regulations at the federal and state level, we can make sure all charter schools are held accountable to high standards.

For more information, read our statement on our letter or visit our ESSA for Authorizers page.