Request for Public Comment - Accountability & School Improvement Addendum Proposal

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Oregon Department of Education - Oregon achieves - together

To: Superintendents, Principals, Charter School Leaders, School Improvement, Federal Directors, Education partners, K12 PIOs, Business Managers, All SSA Advisories and EL Advisory, SB13: Tribal History / Shared History, Title VI Directors, TAPP Directors
From: Tim Boyd, ODE Director of District and School Effectiveness
Date: February 23, 2022
RE: Request for Public Comment - Accountability & School Improvement Addendum Proposal

Dear Partners,

ODE is requesting and inviting public comment by Friday, March 3rd on a one-year addendum to how the agency identifies schools and districts for federal school improvement. An addendum is a technical word which is used by the U.S. Department of Education to mean a time-limited change to Oregon’s Every Student Succeeds Act (ESSA) Plan. ODE recognizes the limitations of this change process and the ways in which current federal school improvement designs and requirements don’t adequately meet or address the experiences, challenges, or needs of Oregon’s schools and districts. ODE also recognizes the value and importance of federal funds which are intended to support the highest needs schools with the most persistent challenges related to academic achievement and academic disparity. 

ODE’s approach to the addendum attempts to capture the impact of the pandemic on student achievement AND meet federal requirements as prior measures don’t allow for what is needed. 

Public comment is required and is desirable ahead of ODE finalizing it’s addendum. Comments are welcome using this survey. We encourage school leaders to share the opportunity for public comment, including educators and local community and education partners, in order to ensure broad representation in response. Additional details follow.


The Elementary and Secondary Education Act (ESEA), reauthorized as the Every Student Succeeds Act (ESSA), requires states to develop accountability models to monitor how school district and schools improve student outcomes and a system for meaningful differentiation used to identify Comprehensive Support and Improvement (CSI) and Targeted Support and Improvement (TSI) schools that need additional support in improving student achievement. Oregon’s approved ESSA Plan and system for annual meaningful differentiation includes student growth data for Language Arts and Mathematics as measured by Oregon’s statewide summative assessment. These data have been impacted by the pandemic and are not currently viable measures to annually differentiate CSI and TSI schools for additional support.

On December 31, 2021, the U.S. Department of Education offered states the opportunity to apply for short-term, one-year flexibilities with School Year (SY) 2021-22 ESEA accountability processing, school exits and identifications, and reporting via an addendum template. The Oregon Department of Education is planning to request some of these flexibilities to ensure it will meet the federal requirement to exit currently identified Comprehensive Support and Improvement (CSI) and Targeted Support and Improvement (TSI) schools, and to identify new CSI and TSI schools in Fall 2022. 

Proposed Shift

The student growth data typically used in Oregon’s accountability model has been significantly impacted by the COVID-19 pandemic. As such, adjustments to the model are needed in order to meet federal requirements. We are looking at small changes to the current system to minimize disruption while we work to improve our future accountability systems as data come back on-line. ODE is proposing to replace the student growth calculation with a measure that captures the change in average test scores in schools to begin to quantify the impact the pandemic has had on students. To be clear, these data are incomplete measures of student experiences in schools and the impacts of COVID on school districts, schools and communities. That said, ODE believes this is the best data currently available to meet federal requirements. We intend to resume the calculation of student level growth in the 2022-2023 school year, which will be used to identify additional schools whose focal students may be recovering more slowly from the pandemic. Additionally, staff at ODE will explore opportunities to make enhancements used to the accountability and support models required by the ESSA.

For more information, please contact Tim Boyd.