TCTA urged the Texas Education Agency to do more to address inequitable gaps in the assignment of qualified teachers to poor and minority students, and to include more holistic measures of school success in its proposed State ESSA Plan. The federal Every Student Succeeds Act, which replaced the No Child Left Behind Act, requires states to submit ESSA plans to the U.S. Department of Education for review and approval by Sept. 18, 2017. The Texas Education Agency posted its proposed plan for public comment through Sept. 1.

TCTA submitted comments expressing concerns about the lack of provisions in the draft plan that would ensure the state’s ability to meet ESSA’s requirements for state and local school districts to identify and address inequities in the assignment of ineffective, out-of-field, or inexperienced teachers to poor and minority students, particularly with respect to situations in which Districts of Innovation exempt themselves from state teacher certification requirements. 

Additionally, TCTA expressed dismay that the draft plan did not take advantage of ESSA’s addition of school quality or student success measures for states to use in their state accountability systems to supplement state standardized test results. The proposed plan instead doubles down on the use of state standardized test results by proposing use of student performance on STAAR Math and Reading as the measure of school quality or student success for elementary and middle schools.   

In our comments, TCTA noted that ESSA specifically listed educator/student engagement and school climate/safety as possible indicators of school quality or student success. TCTA pointed out that, given the struggle that the state has had in identifying non-test-based indicators of school success for elementary and middle schools, this would be an excellent opportunity to focus on incorporating school quality indicators (like a validated school climate survey measuring student/educator engagement and school climate/safety). TCTA said a key advantage to using such an indicator is that it can be applicable to all grade levels, and administered statewide.

In addition to urging TEA to include provisions in the State ESSA Plan regarding how it intends to address or require these districts to address equity gaps that exist based on disproportionate assignment of out-of-field teachers to poor and minority students, TCTA recommended that the plan include state use of federal Title II funds to support local school district quality mentoring programs based on state-established program standards, in its list of strategies to address the issue.

The draft plan’s proposal includes state use of Title II funds to fund the creation of a Texas Equity Toolkit and to provide for skill development for principal supervisors. TCTA pointed to the significant research based supporting the effectiveness of quality mentoring programs in retaining teachers and contributing to student success in advocating that state support of local school district quality mentoring programs be added as an additional strategy for state use of Title II funds. 

TCTA also objected to the draft plan’s proposal to give priority for federally-funded school improvement grant funds to campuses that have the “operational flexibility” to successfully implement their school improvement plans. TCTA noted that although the draft plan doesn’t define “operational flexibility," other communications from TEA define “operational flexibility” as alternative management, in-district campus charters, and Districts of Innovation. TCTA objected to TEA’s proposal to favor these controversial forms of school structure over others and urged TEA to eliminate this provision from the draft plan as not comporting with ESSA provisions for the state to provide operational flexibility to schools on a case-by-case basis and only if appropriate/necessary.

Presumably, TEA will review and respond to the public comments submitted on the draft plan as well as make any revisions to the plan based on public comment. TEA must submit the final plan to the U.S. Department of Education by Sept. 18 for review. The Department can return the plan to the state for further revision or approve it. TCTA will monitor and report on developments as they occur.