College and Career Readiness

Earlier today, U.S. Secretary of Education Arne Duncan weighed in on the question of whether states can delay their timeline for using Common Core assessments in accountability systems for schools and teachers. The tests are set to be fully deployed during the 2014-15 school year, and according to the original policy for offering No Child Left Behind waivers, the results from the assessments would also be used for school accountability and educator evaluations that year (except in states that applied for waivers after August 2012 – see this nifty chart for a full breakdown). Under the new policy, however, states would be able to apply to hold off using the evaluation results for personnel decisions for an extra year – meaning that, in some states, the results from the 2014-15 year would be used to provide feedback and inform professional development only.

The question of whether to “pause” or place a “moratorium” on Common Core implementation has divided education stakeholders. Fifteen organizations, including the American Federation of Teachers and National Education Association, support a moratorium on high-stakes accountability (including student promotion and graduation policies, personnel decisions, and school improvement designations) associated with the Common Core. Instead, these groups - the Learning First Alliance - would like to focus all immediate efforts on improving the supports teachers have to adopt the Common Core, including professional development, curriculum, technology infrastructure, and other resources. On the other hand, Chiefs for Change – a group of eleven reform-minded chief state school officers – urged Secretary Duncan to maintain the Common Core implementation timeline, even for high-stakes decisions, noting that states made these commitments years ago and should not backtrack on accountability.

Others took a slightly more measured approach, but still supported a pause on some components of implementation. The Council of Chief State School Officers asked for state flexibility in three areas: school ratings, teacher evaluations, and which assessments to use for accountability during 2013-14. Some states could maintain the rigorous timelines laid out in their waiver plans, while others could choose to slow down on one or all of these components.

And it appears that Secretary Duncan chose to take the CCSSO route, more or less. States could apply – if they want – to delay the most serious consequences for teachers, like decisions to award tenure or dismiss staff, for one year. Additionally, states would have new flexibility for implementing assessments and school accountability systems. They could apply to use either existing state assessments or Common Core field test results for accountability in the 2013-14 school year (to avoid the so-called “double testing” problem).

While Secretary Duncan insisted the new policy is not a “pause” or a “moratorium” on Common Core, it’s hard to distinguish between an “extension” – the language used by the Department – and a “pause.” No matter what you call it, the requirement for waiver states to use evaluations for personnel decisions can be shelved for a year. And there is no question that states have had a lot of time to fully transition to the Common Core – in most cases, over four years, longer than they had to implement all of the components of No Child Left Behind. In the words of Chad Aldeman, “If this isn’t enough time, what would be?” Will opposition to using teacher evaluations for personnel decisions really die down by the time 2016 rolls around? Further, the new policy could create additional confusion in an already confusing waiver process. It says something that the Department has to release a four-page, state-by-state chart just to explain the timeline for implementing the waiver components (still waiting for a state-by-state chart explaining what they’re actually doing – a far more complicated question).

Still, the Secretary’s decision is a fair compromise between the competing advocacy groups’ positions. And I give credit to the Department for one thing: holding firm on the most critical component of accountability, continuous improvement. More so than the punitive consequences, like school closures and teacher dismissals, accountability really serves to provide meaningful and transparent feedback to schools and educators and give them a roadmap to improve. During the transition to college- and career-ready standards, it is imperative for both schools and teachers to be evaluated on their progress and to use information from evaluations to improve the implementation process. If accountability and other incentives for educators are not aligned to the standards, what kind of signal does that send about the value of implementing them well?

So yes, there will be a pause. And members of Congress can now wave binders full of waivers, and then waivers of waivers, during hearings. But at least the Department is not pressing pause on what’s most important: its expectations for higher standards, better assessments, and continuous improvement.

In a companion report to The Condition of College & Career Readiness, a recent paper from ACT traces enrollment, retention, re-enrollment, and migration patterns of 2011 ACT-tested high school graduates. Since 1983, there has been little change in retention and persistence rates at U.S. colleges and universities. The report seeks to raise awareness that many students do not take a direct path to completion, and in fact, 41% of graduates attended more than one institution, 38% enrolled part time, and over 40% of students transferred during their college experience in 2011.

Among the report’s findings:

• According to the report, a direct relationship exists between scores on ACT subject tests and retention, persistence, and degree completion.
  • Additionally, students who earn minimum (benchmark) scores in more than one subject area are more likely to enroll in a four-year institution.
• Between 22 and 43 percent of ACT-tested high-school graduates across the country who enrolled in higher education in 2011 either did not re-enroll or had unverifiable enrollment statuses.
  • In addition, student mobility between colleges indicates a need for policies supporting a seamless transition from institution to institution.
• Of 2011 ACT-tested high school graduates, most are retained in the state of their original enrollment.
  • Most students who initially enroll in state re-enroll in state for their second year.
  • Most students who enroll out of state re-enroll out of state for their second year.
  • The rates of students who are retained in state and those who enroll and re-enroll out of state for two-year colleges are lower than rates for public four-year colleges.

Welcome to the Syllabus, a guide that provides insight into what’s happening in higher education.

Read:

Going to College is Worth it – Even if You Drop Out, Dylan Matthews
The Washington Post

There was a time when high school was rare and college was reserved for the elite. In today’s world, the value of education is vastly different. Some sort of postsecondary education is an expectation for most. It seems that one must attend and graduate college for entrée into the middle class. Due to stagnating wages and rising college prices, however, many have questioned whether attending college is a financially sound decision. According to researchers at The Hamilton Project the answer is “yes.” Their recent study shows that only 58 percent of college students enrolled in 2004 received a degree by 2010. Nevertheless, those students who did not graduate still earned more income than those who never enrolled in college. In addition, college dropouts make $8,000 more than high school graduates. This figure includes factoring in the cost of the student’s additional education. Matthews concludes by stating, “Dropping out of college is unquestionably a worse economic bet than finishing it. But the evidence suggests that starting and not finishing is much better than never starting at all.”

Listen:

Are There Jobs Out There for Recent Grads?
NPR Tell Me More

One of the biggest concerns for recent college graduates is whether or not they will obtain a fair paying job after spending countless hours and thousands of dollars on higher education. Recent numbers indicate 175,000 new jobs were obtained last month. However, the number of unemployed individuals increased by 7.6 percent. This is because more people entered the labor force. If you’re a recent college grad, you’re still in better shape than those who do not hold a college degree. Surveys show that the salaries of offers for new graduates are up about 5 percent. Additionally, college grads have an unemployment rate of 3.8 percent as compared with high school dropouts who have an unemployment rate of over 11 percent.

Discuss:

Minn. Program Will Offer a Tuition Break Based on Scores on a Standardized Test, Dan Berrett
The Chronicle of Higher Education

In order to motivate students Minnesota State University at Moorhead created a program called “Up2U” that encourages their students to academically achieve and complete college by providing financial incentives through a transfer tuition reduction. In order to receive this deduction the following conditions must be met: 1) The student must enroll full-time in the fall at the college and maintain a GPA of 2.0 for their first four semesters; and 2) During their fourth semester the student will take the new version of the Collegiate Learning Assessment or CLA, which is a standardized test of critical thinking. If students have the same GPA and score well on the assessments they will see their tuition reduced by three-quarters of the full cost. Those opposed to “Up2U” are concerned the program will encourage “teaching to the test” and will alter the current curriculum.

Higher Ed Watch readers, what do you think? Is one test a good predictor of a student’s understanding of the material and critical thinking abilities? Given that the Collegiate Learning Assessment is a test of critical thinking, how could it alter curriculum? Would it even be possible to teach to this test?

Tomorrow morning, the Senate Health, Education, Labor and Pensions Committee will markup the Strengthening America’s Schools Act, the latest ESEA reauthorization proposal from Chairman Tom Harkin (D-IA). Ed Money Watch and Early Ed Watch have already recapped many of the changes proposed to accountability for schools and educators, as well as Title I and early learning programs. But we have yet to weigh in on the alternative proposal offered by the Committee’s Republican members, led by Ranking Member Lamar Alexander (R-TN).

Here are the three biggest differences between the two bills:

1. No love for Common Core. Alexander’s bill – the Every Child Ready for College or Career Act – includes detailed language to explicitly prohibit the U.S. Department of Education from exercising any direction, preference, or control over state’s academic content standards (like the Common Core State Standards) or achievement standards (i.e. cut scores that determine what it means to be college- and career-ready). This also has big implications for education data and reporting – more on that below.

Clearly concerned with federal overreach, this level of specificity around the Department’s role should appeal to critics of the common standards, claiming they are step one toward a “federal curriculum” or “national school board.” But Alexander is silent on a specific timeline or transition to college- and career-ready standards and tests – another increasingly divisive issue. Harkin’s bill would allow states a one-year “pause,” requiring implementation by the 2015-16 school year, even though both Common Core consortia say they will deliver their assessments on-time in 2014-15.

2. A mini-backpack for Title I funds. Another sharp contrast with the Harkin proposal: states could allocate Title I funds to districts based only on their number of eligible children – and federal funding could then follow the child to any public school in the district. Similar to a Romney campaign proposal (but on a smaller scale, without the option to use Title I funds to attend out-of-district public schools or private schools, or to pay for tutoring), it is unclear how many states would take advantage of this provision. How would it work in districts that lack other public school options – in particular, rural districts or districts where the overwhelming majority of schools are low-performing? Funding fights are always messy – how would school and district administrators respond to the change? The Alexander bill would also eliminate maintenance of effort requirements, meaning that states and districts would not be penalized for spending less on education from year to year, another potential sore spot for local school leaders.

3. States: choose your own accountability adventure. Unlike the Democrats’ bill, Every Child Ready for College or a Career would not require performance targets for schools. As Politics K-12 predicted, this was a major partisan sticking point between Harkin and Alexander. And transparency – rather than accountability – is the key policy lever in the Republican proposal. States can choose to differentiate between schools as they see fit.

Further, the Senate Republican proposal would prohibit the Department from specifying, defining, or prescribing any measure that states include in their accountability systems. Presumably, this means states could choose how they want to define everything from adequate student growth, to a cut score for college and career readiness, to how they define graduation rates. Would this undermine data comparability between states, including efforts to report a uniform graduation rate?

Alexander’s bill also doesn’t require states to identify any set percentage of Title I schools for improvement, leaving both identification and intervention entirely up to states (with the exception that students be allowed to transfer if their schools are identified). Given states’ history with setting rigorous goals and expectations for schools (as this new Education Sector report reminds us), Alexander’s bill would effectively set federal education policy back twenty years – to the 1994 Improving America’s Schools Act.

Finally, Alexander’s bill would not require states to develop teacher or principal evaluation systems, but they could use Title II funds for these purposes. And unlike Harkin’s proposal, states could partner with for-profits, as well as nonprofit organizations or higher education institutions, to implement their plans for preparing, training and improving the quality of teachers and school leaders. Because the bill also eliminates the “highly qualified teacher” provision, states would not have to report, whether teachers are distributed equitably between Title I and non-Title I schools – another blow for accountability and a big difference between the Alexander and Harkin proposals.

The bottom line? Alexander’s bill doesn’t actually require states to do anything. And that’s a problem. As Chad Aldeman also notes in his smart take on the Alexander bill, Every Child College or Career Ready relies on assurances from states that they will implement rigorous and high-quality standards, assessments, and accountability systems. As Aldeman writes: “There are no serious standards for these things and, even if there were, there would be no way to verify state assertions.” If a plan is a poor substitute for policy, then an assurance as policymaking is downright laughable.

To help keep both draft bills – along with No Child Left Behind and the Obama administration’s waiver policy – straight, download this side-by-side cheat sheet to use during the markup. You can click also click on the image below to enlarge it. And of course, the always-helpful Politics K12 team has another side-by-side comparison that features the House Republican plan. 

Follow along with us tomorrow, and stay tuned to Ed Money Watch for continuing coverage.

Yesterday, Sen. Tom Harkin (D-IA), Chairman of the Senate Health, Education, Labor, and Pensions Committee, released yet another attempt to reauthorize No Child Left Behind: the Strengthening America’s Schools Act of 2013 (SASA). NCLB, due for a Congressional rewrite since 2007, has few remaining fans. But all previous reauthorization bills, including a bipartisan effort from Sen. Harkin and Mike Enzi (R-WY) last Congress, have failed miserably. While every Democratic Senator on the Committee signed off on the new draft legislation, Harkin could not sway key Republicans. Sen. Lamar Alexander (R-TN), the Ranking Member on the Committee, plans to offer his own reauthorization legislation later this week, with partisan bills also expected from the House Education and Workforce Committee later this month.

Given the partisan nature of the Harkin bill and Congress in general, the odds for a successful reauthorization are more dismal than ever. Insiders agree: the latest Whiteboard Advisors tracking survey found that 87 percent of edu-insiders believe reauthorization will occur after January 2015. Add 37 states and Washington, D.C. with NCLB waivers into the mix, and there is little real pressure from the administration or from state and local policymakers to rewrite the law – especially a bill that would increase the role of the federal government and take away some of the flexibility states received in their waiver plans (more on that below).

Harkin’s bill is scheduled for a Committee markup next Tuesday. In the meantime, here are some of the key provisions we’re watching within Title I – the bill’s largest program – as well as areas for excitement and concern. Education Week, New York Times, and Huffington Post also offer excellent recaps of the proposed legislation.

Timeline and Interaction with NCLB Waivers

States, regardless of waiver status, must immediately begin implementing college- and career-ready assessments and reporting disaggregated student achievement data for any subgroup larger than 16 students. Otherwise, there is a two-year transition period to establish a baseline for performance targets and to identify schools for improvement based on the accountability provisions in SASA. This is a no-brainer: any reauthorization at this point cannot dismantle states’ NCLB flexibility overnight.

What’s far more interesting, however, is that Sen. Harkin is borrowing some ideas from the Department when it comes to waivers. Under SASA, state Title I plans become the new NCLB waivers – subject to Department-approval, including peer review, every four years. Any significant changes to standards, assessments, performance targets, or accountability would fall under the review and revision process. 

What’s brilliant (and quite welcome for education policy wonks) is that this provision eliminates the possibility that the next federal education law gets trapped in reauthorization limbo like NCLB. And it gives Congress more oversight over the renewal/waiver process, since it’s authorized explicitly in the law. Another welcome provision is that the bill requires states’ plans to include how they are improving access to full-day kindergarten if they fund it and to report the distribution of effective teachers – data currently unavailable to most parents, researchers, and policymakers.

Academic Standards

Under SASA, states would have to adopt college- and career-ready academic content standards in reading, math, and science by January 2015. States would also need to adopt achievement standards in all three subjects and, unlike previous bills, demonstrate that they are aligned with credit-bearing academic coursework, without need for remediation, in the state’s public colleges and universities. Without alignment to actual postsecondary standards, states’ new K-12 standards would be college- and career-ready in name-only. While the draft bill could go further, this is a move in the right direction.

The proposed legislation also weighs in on the growing backlash to the Common Core standards. SASA reiterates that the Department of Education cannot “mandate, direct, or control a State’s college and career ready academic content.” Finally, Sen. Harkin would require any state that uses Title I funds for early childhood education to develop early learning guidelines for preschool programs and early grade standards for students in grades K-3. These standards would be required to address multiple domains of learning, including social-emotional development and approaches to learning (ability to persist at a challenging task, work with others, make decisions) and align with the state’s college- and career-ready standards. While this could help encourage states to address the specific needs of its youngest students and how they learn best, it should be a requirement for all states, though, and not just those who use their Title I dollars for preschool programs.

Assessments

Not a lot has changed as far as the NCLB testing schedule, but SASA would require states to administer college- and career-ready assessments by the 2015-16 school year – with assessments subject to a technical review by the Department. This provision has big implications for both the Common Core consortia and other competitors, like ACT. And Bellwether’s Andy Smarick recently revealed that the Department is also revising its review process, so this issue will emerge regardless of an NCLB reauthorization.

Another big change in the Harkin bill is that assessments must measure whether students are performing on grade level, as well as identify the specific grade level at which the student is performing. In other words, states would be allowed to administer computer-adaptive tests that adjust to students’ abilities, using items at the 4th or 5th grade level for advanced 3rd grade students and simpler items aligned to 1st or 2nd grade standards for those that are below-grade level. By allowing states to accurately measure students’ abilities, teachers would have much better information to help students improve and stay on target to postsecondary readiness. Given the importance of grade-level reading and a growing number of states that retain students based on it, this provision is sorely needed.

School Accountability

Like the administration’s NCLB waivers, Harkin’s proposal for accountability includes aggregate and disaggregated measures of student achievement and growth and establishes annual targets for school performance. But unlike the waivers, SASA defines what sufficient academic growth is: a rate of growth by which students would be performing at grade level within three years or by the end of a grade span (like high school). Given that some states’ waivers include growth models that don’t actually measure individual student growth, a better definition is overdue. However, states would also be allowed to submit alternative growth models to the Department for approval, so any sub-par models in the waivers could, theoretically, still be used.

Annual targets can also be carried over from states’ NCLB waivers or approved by the Department anew. States on the latter track would set goals, based on 2014-15 data, which aim for all schools to be performing similarly to schools at the 90^th percentile over a “reasonable” amount of time and expect greater progress for lower-performing subgroups. Alternatively, these states could submit an “equally ambitious” set of goals for Department approval. On their face, these targets sound even more rigorous than those in states’ waivers. However, it’s hard to judge how difficult these targets would be without greater clarity on what, exactly, “reasonable” and “equally ambitious” mean. Notably, states’ goals cannot recognize a GED or other equivalency as a high school diploma, and super-subgroups would be eliminated in any new goals states develop.

But the most important – and welcome – change between SASA and states' waivers is that these targets actually matter beyond school report cards. As research shows, serious interventions – or the threat of them – could be the difference between schools improving or stagnating. Harkin’s bill would require state accountability systems to identify and intervene in focus and priority schools, along with schools failing to meet the same performance goals for two consecutive years. The Harkin bill is also more explicit about what happens to focus and priority schools if they do not improve than most state waivers: focus schools become priority schools after six years, while priority schools are subject to state takeover, restart, or closure if they are re-identified as a priority school after three years.

Too Much of a Good Thing

Sen. Harkin’s bill suffers in two areas: defining school improvement strategies and school report cards. In defining what schools must do to improve and what school data must be reported to parents, every Democratic Senator’s favored approach or data point appears to be included, leaving a jumbled mess of burdens and requirements for states, districts, and schools.

School improvement strategies – in addition to the specific provisions of the transformation, turnaround, whole school reform, restart, and closure models – must include over 15 common elements, from professional development, to improving coordination and access to early learning, to data-driven instruction, to positive behavioral interventions and supports. While these are all important factors to consider (and New America has written about the need to include preschool and the early grades in school turnaround), it’s a vague and inordinately long list to tackle in three years, especially if state and district capacity for school improvement is lacking.

SASA’s treatment of school report cards is even worse. After stating that school report cards must be “concise” and “easy to understand,” the draft bill includes over twenty data points that must be reported for all schools (NCLB required less than five). But there are actually far more than twenty – it could be hundreds. That is because nearly every data point must be reported by grade and all must be disaggregated by subgroup, and then cross-tabulated between subgroups. This data should be publically available. But does it all need to be reported in one place, where it could easily overwhelm parents and families? Ironically, despite all the data that must be included, there are still missing pieces – particularly enrollment in full-day and half-day kindergarten and chronic absenteeism.

There is a lot more (believe it or not) in the legislation, so New America will continue to cover the Strengthening America’s Schools Act on and the markup on Ed Money Watch and Early Ed Watch in the days ahead. Stay tuned.

Although the deadline for all students to achieve proficiency in math and reading has been lifted in most states by No Child Left Behind (NCLB) waivers, 2014 test anxiety is high as ever. That’s because the 2014-15 school year is the first time 45 states and Washington, D.C. will be fully implementing the Common Core State Standards – including new tests that will be used as part of high-stakes accountability systems for schools and, in many cases, teachers and students. But when the time comes, will states stay the course? Practical concerns along with escalating political arguments already threaten the emerging system of common standards and assessments.

As I wrote previously, Alabama became the first state to exit the Common Core test consortia, opting instead to administer ACT-based assessments. By 2014, Alabama will likely not be alone in its choice. ACT is a well-established player that has spent decades building an organization with a reputation for providing valid, reliable assessments. Conversely, the state consortia are upstarts, attempting to build next-generation assessments and a precarious, multi-state structure to support and sustain the effort simultaneously. Naturally, states are left with many unanswered questions. How much will the new tests costs, and what are the technical requirements? Will the tests accurately reflect a student’s readiness? And will the assessments even be completed on time? In his smart take on the issue, Bellwether Education Partner’s Andy Smarick writes, the ACT “is the ‘Plan B’ that many states – concerned about the reliability and cost of the consortia-developed tests – have been looking for. It enables a state to remain committed to tough standards and rigorous assessments without putting all of their eggs in the basket of a fragile multi-state entity.”

But this kind of pragmatic concern isn’t the only threat to the common standards. While the Common Core is a state-led initiative (I repeat, the Common Core is a state-led initiative), the effort has been supported by private and corporate philanthropy and by the federal government. Specifically, the requirement to adopt the common standards to compete for Race to the Top funding is at the heart of increasingly polarized and politicized arguments against the Common Core. In their words, “Obamacore” amounts to a “nationalized curriculum” and “leftist indoctrination” that has been “forced on state governments” and “imposed on the children of this nation.”

Reasonable individuals easily dismiss most of these arguments. But reasonable arguments are often overshadowed, especially when national politicians and parties start getting involved. Just last week, the Republican National Committee adopted an anti-Common Core resolution, echoing these same divisive arguments.  And President Obama frequently touts that his administration “convinced almost every state to develop smarter curricula and higher standards, all for about 1 percent of what we spend on education each year” – adding credibility to their claims.

The problem may be about to get worse. As noted in our Key Questions on the Obama Administration’s 2014 Education Budget Request, federal funding for the assessment consortia is set to expire before the tests are fully launched. To provide continued support, President Obama’s latest budget includes a $9 million competitive grant initiative that could finance some of their ongoing work. The other $380 million of the “Assessing Achievement” program would provide states with formula grants for their current assessment programs, although leftover funds could go toward Common Core implementation.

However, a significant change would occur in fiscal year 2015: Assessing Achievement formula funding would be available “only to States that have adopted college- and career-ready standards that are common to a significant number of States” (emphasis added). While Race to the Top included a similar requirement, that program was a competition, where states could opt-out. NCLB waivers also require states to adopt college- and career-ready standards, but they do not have to be common ones. The Assessing Achievement program would mark the first time federal formula funding – typically available to all states – required adoption of common standards. If enacted, this requirement will undoubtedly add fuel to the “Obamacore” fire. On the heels of the president’s budget request, Sen. Chuck Grassley (R-Ia) is calling for the federal government to eliminate all Department of Education funding that supports or prioritizes the Common Core – and he doesn’t even mention the Assessing Achievement program.

What can we make of these threats to the Common Core? To date, most of its political detractors have been contained outside of the mainstream and have had little success gaining traction or passing legislation to reverse Common Core adoption. Will the RNC resolution, Grassley’s letter, or potential changes in federal funding have a greater impact?

On the other hand, the pragmatic concerns about how the new standards and assessments will be implemented are just that – pragmatic. Few could fault Alabama’s decision to choose the ACT over PARCC and SmarterBalanced. All three of the developing testing systems could prove to be a great improvement over current assessments, measuring competencies better aligned to postsecondary work and providing more useful information to students, their teachers, parents, and policymakers.

The important difference between the practical and political critiques is that states deciding to use the ACT system are not necessarily backing away from their commitment to the Common Core altogether. Yes, the assessment consortia should do as much as possible to allay the concerns of wavering states. And yes, policymakers and stakeholders should closely monitor all of the emerging for-profit and non-profit ventures to ensure their assessments, curricula, textbooks, and other resources accurately reflect the new standards. But in the end, any damage done to the Common Core from these pragmatic objections to the consortia is far less severe than what would happen in the unlikely, but not out of the question, case that “Obamacore” goes mainstream. Common Core supporters would do well to distinguish between the two. 

Texas has joined Pennsylvania, Wyoming, and 46 other states (including Washington, D.C.) in seeking waivers from No Child Left Behind (NCLB). With Nebraska and Montana sitting out, Vermont and North Dakota withdrawing, and California flat-out rejected, the pool of non-waiver states continues to shrink. But despite jumping on the waiver bandwagon, Texas breaks the mold in many respects.

Although the Lone Star State’s refusal to adopt the Common Core is one important distinction from other waiver winners, this wasn’t the detail I was most keen to uncover in their formal request. Texas’ plan to implement their own college- and career-ready standards and assessments actually stood out as one of the stronger points of their waiver, and other non-Common Core states, like Virginia and Minnesota, have successfully applied. Rather, Texas had originally considered asking the Department of Education for leeway to redesign the federal Title I funding formula – a provision that would have gone well beyond the flexibility granted to other states and a demand that would have undoubtedly made Texas’ waiver dead on arrival. To their credit, Texas officials removed this request, bringing their final proposal much closer to what the Department is offering.

But does this mean Texas’ waiver will be a hit with the U.S. Department of Education? Not so fast. While the proposal has strong points – like working with higher education to gain buy-in for college- and career-ready standards and articulating a plan to pilot teacher evaluations and scale them statewide – Texas’ proposed system of school accountability and improvement is not among them. In fact, Texas’ waiver could significantly undermine efforts to hold schools accountable for the performance of individual student subgroups.

Texas’ request is complicated by the fact that its state accountability system, which has operated in parallel to NCLB, is undergoing a significant overhaul, with many provisions yet to be finalized. Because Texas would like to fit its existing system into the waiver requirements, the state simply excluded these half-baked provisions from its request. Therefore, Texas’ waiver omits critical details, including how student progress will be measured, what annual performance targets will be, how each component within accountability will be weighted, and how focus and priority schools will be selected. Further, the application doesn’t even include Texas’ proposed framework, burying the information in attachments and hyperlinks.

For those that do seek out the information, Texas’ new performance index leaves a lot to be desired. Similar to other states, Texas plans to use a combination of four indices for accountability: student achievement, student progress, achievement gap closure, and postsecondary readiness. But the state does not specify how the index would translate into specific interventions, i.e. focus and priority schools.

Even more worrisome is how student subgroups and academic subjects will be treated across the four indices. While some states created “super-subgroups,” Texas took a different approach: ignore subgroups altogether.  Within the student achievement index, only the all students group is considered, with proficiency rates combined further across all subject areas. Yet for measuring student progress, subjects are considered separately and all traditional subgroups count– with the exception of low-income students, who are only considered within the performance gap closure index. But the gap closure measures do not consider English Language Learners or special education students. Finally, within the postsecondary readiness index, only racial subgroups are considered on one measure (advanced proficiency rates), while all subgroups (except low-income students) are considered for graduation rates. Texas does not provide a rationale for picking and choosing which indices apply to which subgroups.

Texas could also be plagued by an issue that cropped up in other waivers: annual performance targets. Texas’ targets would be based on the goal of cracking the top ten states nationally on college and career readiness by 2020 – a novel approach worth considering. But it’s unclear how the state could judge itself against others to define the annual targets. Texas is not a Common Core state, and existing national measures, like the SAT or ACT, would only apply to high schools. If the proposed readiness index were used instead, the ranking would be based on Texas assessments, students graduating with advanced Texas diplomas, and graduation rates. Using these measures, Texas would be number one by default – no other state has similar data.

Given these issues, I am doubtful that the Department could approve Texas’ request in its current form. There are simply too many unanswered questions and missing details. That said, Texas’ request is strong enough in other areas to allow for productive negotiations with the Department. With additional assurances and information from the Lone Star State, along with some give and take, NCLB flexibility could reach deep in the heart of Texas by the 2013-2014 school year.

While many education advocates prepare for the looming sequester on March 1, the education policy news in D.C. wasn’t all bad this week. The nation is now on track – for the first time– to reach a 90 percent high school graduation rate by 2020, according to the fourth annual Building a Grad Nation report. Released at the Grad Nation Summit, hosted by America’s Promise Alliance, the report analyzes trends in the national graduation rate, which increased from 71.7 percent in 2001 to 78.2 percent in 2010, and celebrates the significant advances states have made.

States’ progress has accelerated since 2006, thanks in part to an outsized 2.7 percentage point increase in the graduation rate between 2009 and 2010. The recent gains are also largely due to improved graduation rates for Hispanic students (10.4 point gain) and for black students (6.9 point gain). Two states – Wisconsin and Vermont – have already hit the 90 percent mark, and eighteen more are on pace to meet it by 2020.

Notably, these gains come at a time when many states also increased high school requirements and when schools faced heightened accountability measures under No Child Left Behind. In 2012, nine states required students to pass end-of-course exams to graduate, compared to only two in 2002. Six more states required students to take end-of-course exams in 2012, but did not require a passing score. States are also continuing to raise the bar with adoption of the Common Core and other college- and career-ready standards.

Further, Grad Nation reports that over a million students are no longer attending dropout factories, compared to 2002, and the overall number of dropout factories fell by nearly 600 schools. Dropout factories are high schools where twelfth grade enrollment is 60 percent or less then ninth grade enrollment three years earlier. Again, the beneficiaries of this trend were mostly minority students: in 2002, almost half of America’s black students attended a dropout factory, but in 2011, only a quarter did so – a fifty percent decline.

While celebrating the achievements of the last decade, the report also cites the challenges that lie between today’s status quo and the 2020 goal. Over twenty states are not on pace to achieve a 90 percent graduation rate. More troubling, persistent achievement gaps remain. In 30 states, at least one-third of students with disabilities fail to graduate. The same is true for English Language Learners in 33 states, black students in 20 states, and Hispanic students in 16 states. In many cases, the proportion of students failing to graduate in these subgroups is much higher.

Another challenge lies within the data. The 78.2 percent mark was determined using the Averaged Freshman Graduation Rate (AFGR), rather than the 4-year Adjusted Cohort Graduation Rate – the uniform methodology states and the federal government agreed to use in 2008. The Cohort Rate will enable a more consistent measure of graduation rates and allow states to more precisely identify schools and strategies that are preventing dropout. But there are technical questions about how to calculate the new rates. After the switch to the Cohort Rate in 2012, the difference between the old and new calculation methods was over five percentage points in nine states. Without a consistent measure, it is unclear how far and how fast states will need to improve to meet the 2020 goal.

Because of these lingering challenges, it is incredibly important for states and the federal government to remain vigilant in reporting accurate data and holding schools accountable for graduation rates, especially for at-risk students. As Ed Money Watch previously reported, many states have backtracked on commitments to graduation rate accountability in their waivers from No Child Left Behind – giving schools equal credit for students that take longer than four years to graduate, or counting GEDs and other non-diplomas. Further, many states are not holding schools accountable for – or even reporting – other measures that are critical early warning indicators of dropout, like chronic absenteeism.

With increased attention on students’ preparedness for college and careers after graduation, schools cannot forget about supporting students who are struggling just to finish their high school degree. To help, U.S. Secretary of Education Arne Duncan announced a new grant competition to place more AmeriCorps volunteers in the nation’s lowest-performing schools. While admirable, this is hardly a comprehensive solution. Federal and state lawmakers must do more and consider both goals – preventing dropout and increasing college and career readiness – equally when creating policies to measure and improve student achievement in our nation’s high schools.

On June 9, 1904, Harvard's president, Charles W. Eliot, wrote a letter to Charles Francis Adams Jr. A former railroad executive, Adams was a member of the college's Board of Overseers and, as a grandson of John Quincy Adams, a multigenerational Harvard legacy. The two men were quarreling over the question of raising tuition to ease a financial crisis. Wrote Eliot: