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The National Council of State Title III Directors (NCSTIIID) hosted national meetings in Los Angeles, CA, jointly with the Council of the Great City Schools Bilingual Directors on May 16th and 17th. While many topics were discussed, one of the top concerns brought up by Title III Directors relates to the potentially significant reduction in the number of ELs that will be included in accountability determinations for making progress toward English proficiency under ESSA (the Elementary and Secondary Education Act as amended by the Every Student Succeeds Act 2015)


The concern from Title III Directors regarding the potential for a reduction in the amount of ELs that will be included in accountability determinations came from 3 related factors:

  1. Accountability determinations for ELs are being made at the school level under Title I of ESSA (under NCLB’s Title III, these determinations were made for all ELs in Title III funded districts)
  2. Accountability determinations for ELs are being made in fewer grades
  3. Accountability determinations for any student subgroup, including the EL subgroup, are only made in schools that have a large enough population of students in the subgroup (this size limit is called the “n-size”)

Accountability determinations for making progress toward English proficiency (attainment and growth) have moved from Title III under NCLB to Title I under ESSA. Under NCLB, Title III accountability determinations for ELs were made in all grades for all ELs in Title III funded districts. Under ESSA, accountability determinations for ELs are only required in schools in Title I funded districts in the same grades tested for the State’s annual content test (grades 3–8 and once in high school). For more resources on this topic, download our ebook on collaborating to successfully implement ESSA-related  changes for ELs.

The biggest concern expressed at the NCSTIIID meetings was the n-size used to decide if accountability determinations can be made. The term ‘n-size’ is used to reference the number of students needed in an accountability subgroup in order to make an accountability determination. For example, if an n-size of 25 is selected by the State, then accountability determinations will only be made for a particular subgroup of students if there are at least 25 students in that student subgroup in the school. So if a school has fewer than 25 ELs, then accountability determinations might not be made for those ELs’ progress toward or attainment of English proficiency (click here for more information on n-size and its affect on accountability determinations).

Why are ESSA's changes to n-size a concern?

Accountability determinations are often a key component of an evaluation of the success of a school’s or district’s EL program. If a school has too few ELs, it cannot make changes to improve its EL program because areas needing improvement aren’t identified.

The information shared at the NCSTIIID meetings indicate that there could be significant numbers of schools that won’t meet the required n-size for EL subgroup accountability determinations. One State Director commented that, based on the n-size (for that director’s State), less than 25% of schools in the State would have enough ELs to make accountability determinations.

The reduction in the numbers of ELs included in accountability determinations is concerning for EL advocates because it means that schools with failing EL programs could potentially get a bye – an automatic pass – on EL accountability and not be required to address any programmatic failures. Civil Rights law requires districts to periodically evaluate their EL programs and modify them to address any deficiencies identified. If no accountability determinations are made, then no failures (or successes) are identified in this manner. In addition, another connected concern is that there may be much less oversight of school or district level EL programs conducted by USED’s Office for Civil Rights than there is from the State employees that oversee ESSA programs. So if fewer ELs are included in ESSA accountability, then the cumulative effect has the potential of a loss of focus on the unique educational needs of English Learners.

Evaluation of EL programs should include consultation with parents of ELs. One potential positive development under ESSA is that Title I now has the requirement of scheduling regular meetings with the parents of ELs to receive feedback and recommendations to improve the district’s EL programs. While this may not offset the potential shrinkage in the numbers of ELs included in accountability determinations, it will at least provide an opportunity for EL advocates to address concerns about EL programs in schools that receive a bye for EL accountability determinations.

TransACT Parent Notices is a parent communications partner and provides ESSA compliant parent notices in multiple languages to support Title I and Title III directors in effective, compliant communication under ESSA. This includes a notice to invite the parents of ELs to the regular meetings required under Title I mentioned in the previous paragraph. Contact a Parent Notifications team member to see how districts and states across the country are using TransACT Parent Notices to support compliant parent communication. 

Other Highlights 

Other highlights from the meeting included:

  • A keynote address from a former English Learner
  • Discussions about educational experiences with a panel of English Learners (ELs) from North Hollywood High School
  • Presentations from the U.S. Department of Education (USED). 

About The Author

Dr. David Holbrook is a nationally recognized leader in federal programs administration and monitoring with expertise in Title I, Title III,Native American Education, and Federal Programs. Dr. Holbrook has also worked as a consultant with Title III of the US Department of Education and now serves as Executive Director of Federal Programs for TransACT.