NACSA on ESSA Title I State Plans: “Accountability and Transparency Must Be Meaningful”

NACSA on ESSA Title I State Plans: “Accountability and Transparency Must Be Meaningful”

In a comment letter submitted today to the US Department of Education (ED), NACSA recommended changes to proposed Title I provisions under the Every Student Succeeds Act (ESSA) that would ensure accountability and a focus on quality were applied to all public schools.

Upon submitting the recommended changes, Amanda Fenton, director of federal and state policy for the National Association of Charter School Authorizers (NACSA), offered the following statement:

“For all public schools to be held accountable under ESSA, we must seriously reconsider our approach to identifying ‘dropout factories.’ As it stands, too many schools that specialize in drop-out recovery would be mislabeled, allowing other public schools that truly warrant the designation to get lost in the crowd.

“In addition, our recommendations acknowledge that thoughtful, well designed reporting and accountability provisions at the state and federal level are essential to creating a thriving charter school sector focused on quality. These policies must work together—and not at cross purposes—to be truly meaningful in the next generation of state plans.”

Specifically, NACSA recommends the following changes to the current proposed Title I rules under ESSA:

  • Make sure state report cards are meaningful for families, not misleading. Require absolute reporting on academic performance and enrollment for each charter school authorizer instead of burdensome, misleading comparative reporting. States will already be monitoring and reporting annually on this precise, accurate, and unambiguous information.
  • Work with state law, not against it, and protect an authorizer’s ability to hold charter schools accountable for their performance. As currently written, the rules could encourage states to design ineffective systems that would make it harder for authorizers to close charter schools for performance.
  • 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.

For more information about ESSA and authorizing, visit



The National Association of Charter School Authorizers (NACSA) is an independent voice for effective charter school policy and thoughtful charter authorizing practices that lead to more great public schools. Our research, policy, and consultation work advances excellence and accountability in the charter school sector. With authorizers and other partners, we have built the gold standard for charter school authorizing. Through smart charter school growth, these authorizers will give hundreds of thousands of children an opportunity for a better education each year. More at


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