PDF Office of Elementary and Secondary Education

UNITED STATES DEPARTMENT OF EDUCATION

OFFICE OF ELEMENTARY AND SECONDARY EDUCATION

June 30, 2017

The Honorable Candice McQueen Commissioner of Education Tennessee Department of Education 6th Floor, Andrew Johnson Tower 710 James Robertson Parkway Nashville, TN 37243

Dear Commissioner McQueen:

Thank you for submitting Tennessee's consolidated State plan to implement requirements of covered programs under the Elementary and Secondary Education Act of 1965 (ESEA), as amended by the Every Student Succeeds Act (ESSA), and of the amended McKinney-Vento Homeless Assistance Act (McKinney-Vento Act).

I am writing to provide initial feedback based on the U.S. Department of Education's (the Department's) review of your consolidated State plan. As you know, the Department also conducted, as required by the statute, a peer review of the portions of your State plan related to ESEA Title I, Part A, ESEA Title III, Part A, and the McKinney-Vento Act using the Department's State Plan Peer Review Criteria released on March 28, 2017. Peer reviewers examined these sections of the consolidated State plan in their totality, while respecting State and local judgments. The goal of the peer review was to support State- and local-led innovation by providing objective feedback on the technical, educational, and overall quality of a State plan and to advise the Department on the ultimate approval of the plan. I am enclosing a copy of the peer review notes for your consideration.

Based on the Department's review of all programs submitted under Connecticut's consolidated State plan, including those programs subject to peer review, the Department is requesting clarifying or additional information to ensure the State's plan has met all statutory and regulatory requirements, as detailed in the enclosed table. Each State has flexibility in how it meets the statutory and regulatory requirements. Please note that the Department's feedback may differ from the peer review notes. I encourage you to read the full peer notes for additional suggestions and recommendations for improving your consolidated State plan.

ESEA section 8451 requires the Department to issue a written determination within 120 days of a State's submission of its consolidated State plan. Given this statutory requirement, I ask that you revise Tennessee's consolidated State plan and resubmit it through OMB Max within 15 days of the date of this letter. If you need more time than this to resubmit your consolidated State plan, please contact your Office of State Support Program Officer, who will work with you in establishing a new submission date. Please recognize that if we accommodate your request for

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The Department of Education's mission is to promote student achievement and preparation for global competitiveness by fostering educational excellence and ensuring equal access.

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additional time, we may be unable to issue a written determination on your plan within the 120day review period.

Department staff will contact you to support Tennessee in addressing the items enclosed with this letter. If you have any immediate questions or need additional information, I encourage you to contact your Program Officer for the specific Department program.

Please note that the Department only reviewed information provided in Tennessee' consolidated State plan that was responsive to the Revised Template for the Consolidated State Plan that was issued on March 13, 2017. Each State is responsible for administering all programs included in its consolidated State plan consistent with all applicable statutory and regulatory requirements. Additionally, the Department can only review and approve complete information. If Tennessee indicated that any aspect of its plan may change or is still under development, Tennessee may include updated or additional information in its resubmission Tennessee may also propose an amendment to its approved plan when additional data or information are available consistent with ESEA section 1111(a)(6)(B). The Department cannot approve incomplete details within the State plan until the State provides sufficient information.

Thank you for the important work that you and your staff are doing to support the transition to the ESSA. The Department looks forward to working with you to ensure that all children have the opportunity to reach their full potential.

Sincerely,

/s/

Jason Botel Acting Assistant Secretary

Enclosures

cc: Governor State Title I Director State Title II Director State Title III Director State Title IV Director State Title V Director State 21st Century Community Learning Center Director State Director for McKinney-Vento Homeless Assistance Act: Education for Homeless Children and Youths Program

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Items That Require Additional Information or Revision in Tennessee's Consolidated State Plan

Title I, Part A: Improving Basic Programs Operated by Local Educational Agencies (LEAs)

A.3.i: Native Language

In its State plan, the Tennessee Department of Education (TDOE) indicates that Tennessee is an

Assessments Definition

English-only State and therefore does not provide a definition of "languages other than English

that are present to a significant extent in the participating student population." The ESEA and its

implementing regulations require that the State provide this definition and identify the languages

meeting that definition, including at least the most populous language other than English spoken

by the State's participating student population.

A.4.i.a: Major Racial and Ethnic In its State plan, TDOE discusses a combined Black/Hispanic/Native American (BHN) subgroup.

Subgroups of Students

While this subgroup is permissible, it is not clear whether each of the individual racial and ethnic

subgroup of students is also separately included in the State's accountability system. The ESEA

requires a State to include in its accountability system each major racial and ethnic group as well

as the subgroups of economically disadvantaged students, children with disabilities, and English

learners.

Clarifying this requirement in the State plan will also require TDOE to clarify this matter in related areas of its State plan to ensure all ESEA required subgroups are properly included. In particular, the ESEA requires:

That the Academic Achievement indicator measures the performance of each individual subgroup of students in addition, at the State's discretion, to the performance of the combined BHN subgroup. (Requirement A.4.iv.a)

That TDOE's system of annual meaningful differentiation is based on the performance of all students and each individual subgroup of students in addition, at the State's discretion, to the combined BHN subgroup. (Requirement A.4.v.a)

That the identification of schools with one or more "consistently underperforming" subgroups be based on the performance of each individual subgroup separately in addition, at the State's discretion, to the performance of the BHN subgroup. (Requirement A.4.vi.e)

That the schools identified for Additional Targeted Support and Improvement be based on the performance of any subgroup of students, on its own, which would lead to identification for comprehensive support and improvement under ESEA section 1111(c)(4)(D)(i)(I) (i.e., based on being among the lowest-performing schools). If it so

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A.4.ii.d: Minimum N-Size and Ensuring Student Privacy

A.4.iii.b.2: If Applicable, LongTerm Goals for Each ExtendedYear Adjusted Cohort Graduation Rate

A.4.iii.b.3: Measurements of Interim Progress

A.4.iv.a: Academic Achievement Indicator

chooses, TDOE may also identify schools based on the performance of the BHN subgroup. (Requirement A.4.vi.f) In its State plan, TDOE outlines specific strategies for ensuring that subgroups of students have sufficient numbers of students to provide accurate reporting. However, TDOE does not address how it will protect the privacy of individual students. The ESEA requires a State to describe how it ensures that its minimum number of students will protect the privacy of individual students. In its State plan, TDOE describes reporting an extended-year adjusted cohort graduation rate but is not clear whether TDOE intends to establish and report against long-term goals for an extended-year adjusted cohort graduation rate. Although establishing long-term goals for an extended-year rate is optional, if a State chooses to do so, the ESEA requires the State to identify and describe ambitious long-term goals for all students and each subgroup of students for the extended-year adjusted cohort graduation rate(s), which the statute requires be more rigorous than the long-term goals set for the four-year adjusted cohort graduation rate. The ESEA also requires that the graduation rate long-term goals include the same multi-year length of time for all students and for each subgroup of students in the State. Because TDOE does not include baseline data for all students and for each subgroup of students, it is unclear whether TDOE meets the statutory requirements. TDOE provides measurements of interim progress toward its long-term goals for the four-year adjusted cohort graduation rate. However, if TDOE intends to establish long-term goals for an extended-year adjusted cohort graduation rate, the ESEA requires a State to also provide measurements of interim progress toward those goals.

It is unclear whether TDOE intends to include performance on science in the Academic Achievement indicator. For the Academic Achievement indicator required under ESEA section 1111(c)(4)(B)(i)(I), a State may only include proficiency on the annual assessments required under ESEA section 1111(b)(2)(B)(v)(I) (i.e., reading/language arts and mathematics); a State may include performance on assessments other than those required under ESEA section 1111(b)(2)(B)(v)(I) (e.g., science) in the indicator for public elementary and secondary schools that are not high schools as required under ESEA section 1111(c)(4)(B)(ii) (i.e., the Other Academic indicator) or in the School Quality or Student Success indicator for any schools, including high schools.

In its State plan, TDOE states that its Academic Achievement indicator includes measures of absolute achievement as well as measures on AMO targets, which TDOE describes as "growth to achievement." Accordingly, it is unclear whether TDOE intends to include a

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A.4.iv.c: Graduation Rate

A.4.v.a: State's System of Annual Meaningful Differentiation A.4.v.c: If Applicable, Different Methodology for Annual Meaningful Differentiation

A.4.vi.a Comprehensive Support and Improvement Schools--

measure of student growth in the Academic Achievement indicator for elementary and secondary schools that are not high schools. The ESEA permits a State to include a measure of student growth for high schools within the Academic Achievement indicator, but does not permit a measure of student growth for other grade bands within that indicator. A State may include a measure of student growth in the Other Academic indicator for elementary and secondary schools that are not high schools or in the School Quality or Student Success indicator for any grade band. Please refer to requirement A.4.i.a as it pertains to the BHN subgroup. ESEA section 1111(c)(4)(B)(iii) requires that the Graduation Rate indicator only include measures based on the four-year adjusted cohort graduation rate and, at the State's discretion, one or more extended-year adjusted cohort graduation rates, and be based on the State's longterm goals. TDOE may include other high school measures, such as those related to postsecondary, military, and workforce readiness, as School Quality or Student Success indicators, provided those measures meet all applicable requirements for School Quality or Student Success indicators (i.e., are valid, reliable, comparable, used statewide in all schools, and allow for meaningful differentiation in school performance). The ESEA requires a State to describe its Graduation Rate indicator. Because TDOE is unclear if it intends to include an extended-year adjusted cohort graduation rate in the Graduation Rate indicator and because it does not describe how such an extended-year adjusted cohort graduation rate is combined with the four-year adjusted cohort graduation rate within the indicator, it is unclear whether TDOE meets the statutory requirements. Please refer to requirement A.4.i.a as it pertains to the BHN subgroup.

The ESEA requires a State to include all public schools in its system of annual meaningful differentiation and to describe that system in its State plan. TDOE has provided information that implies that it uses a different methodology for annual meaningful differentiation for certain schools, but does not specify that its different methodology is limited to schools for which an accountability determination cannot be made or describe the different methodology, including the types of schools to which it will apply and how the methodology will be used to identify such schools for comprehensive or targeted support and improvement. Accordingly, it is unclear whether TDOE meets the statutory requirements. TDOE identifies its lowest-performing schools from among all schools, not just schools that receive Title I, Part A funds, which may result in some non-Title I schools being identified in

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