USED Issues School Improvement Interventions Letter: Fails to Address Title III Improvement Issues


Shortly before the Trump administration took office, the U.S. Department of Education (USED) issued a Dear Colleague Letter (DCL) (January 13, 2017) to State Education Agencies (SEAs) regarding the timeline for and provision of interventions in schools identified for improvement. The DCL covered Title I school improvement interventions for the 2017-2018 school year (SY) for both Focus and Priority schools under ESEA Flexibility and schools identified for Improvement, Corrective Action, or Restructuring under NCLB. In addition, it provided a timeline for when schools should be identified for ESSA school improvement as either Comprehensive Support and Improvement schools or Targeted Support and Improvement schools.

 On April 10, 2017 the USED issued a similar DCL with almost identical wording for school improvement interventions for the 2017-2018 SY and identical timelines for implementation of ESSA’s school improvement provisions. This letter also addressed stakeholder consultation for ESSA State Plans. Stakeholder consultation is still required even though there are no requirements to describe that consultation in the updated ESSA Consolidated State Plan Template.

The reason the April DCL’s school improvement timeline information was needed, even though most of the information regarding school improvement issues was nearly identical to the earlier DCL, is because the source of the authority for the school improvement timeline was in the recently rescinded regulations for Accountability and State Plans. So the April 10th DCL was needed in order to ensure that the timeline outlined in the now rescinded regulations remained in effect.

Title III Improvement Not Addressed

The Title I school improvement timelines are now clear, however, neither of the DCLs referenced above addressed how to handle school districts identified for Title III improvement under NCLB or ESEA Flexibility. They only addressed the Title I school improvement issues under NCLB or ESEA Flexibility. Under NCLB and Flexibility, a school district could be identified for improvement under Title III for missing Annual Measurable Achievement Objectives (AMAOs) for two consecutive years.

The only time USED has addressed Title III accountability / improvement status issues for the period of transition from NCLB to ESSA was in a DCL from January 28, 2016 (more than a year ago). In that DCL, USED instructed SEAs to freeze school district Title III accountability determinations at their current status for the 2015-2016 SY and 2016-2017 SY. Title III accountability for the 2017-2018 SY has never been addressed. Because of this, it is unclear what actions states should take regarding districts previously identified for Title III improvement.

TransACT is committed to keeping you up-to-date on what is happening at the federal level. Based on the April 10th DCL, parent notices for school improvement under ESSA won’t be needed until the 2018-2019 school year for most if not all states, and will only be needed in the 2017-2018 school year if a state with an approved ESSA State Plan chooses to identify schools for improvement and implement ESSA’s school improvement measures in 2017-2018 SY. If you have any questions or would like more information, please contact us at 425.977.2100, Option 3 or email at


Dr. David Holbrook

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, Federal Compliance and State Relationships with TransAct.