In early June, the Ohio Department of Education (ODE) released an updated draft of its ESSA plan for public comment. The department had initially intended to submit its plan earlier this spring, but after heavy pressure, state officials decided to delay submission until September. The most important part of the document is its description of the state’s proposed school accountability and intervention policies. We believe that Ohio’s plan does a good job meeting both federal and state requirements.

Still, Ohio should aim for excellence, if not perfection. Allow me to identify three improvements worthy of consideration before ODE submits its plan to the U.S. Department of Education. These are sections that ODE could likely tweak without running afoul of federal or state law.

Eliminate the Chronic Absenteeism indicator (Title I, Part A: Improving Basic Programs Operated by LEAs—Indicators; lines 428-512)

ODE proposes using Chronic Absenteeism as a new report-card measure to comply with ESSA’s requirement for an indicator of School Quality or Student Success. This is a mistake. While related to student learning, absenteeism is not itself an outcome measure, which should form the basis of school accountability. Attendance should be viewed more akin to an “input” measure, like student demographics; as the Ohio Auditor of State writes, “attendance is merely an input over which schools have minimal control.” In addition, to maintain the integrity of the indicator, a robust process may need to be in place to verify schools’ attendance data. Audits of attendance data have revealed unintentional errors or intentional manipulation of records under what the Auditor has called an “honor system” of district attendance reporting. A recent Plain Dealer article notes that the district with Ohio’s highest chronic absenteeism rate claims an error was likely made in the data. For these reasons, ODE might consider other options to comply with ESSA’s School Quality indicator, such as using only its Prepared for Success component (for high schools) or perhaps data from its Achievement component (such as “indicators met” which would cover almost all schools).

Identify the bottom 5 percent of schools for “comprehensive support”—and no more (Title I, Part A: Improving Basic Programs Operated by LEAs, Subpart 4; lines 224-233).

ESSA requires states to identify a minimum of 5 percent of schools as low-performing and in need of comprehensive support—i.e., some form of state intervention. Ohio should affirm that it will identify, per the federal minimum requirement, the bottom 5 percent of schools. But ODE should also make clearer how it plans to identify comprehensive schools—the draft only refers to the use of the summative rating system. It does not indicate whether the total number of points earned by a school, or whether the overall A-F letter grades themselves will lead to identification of comprehensive schools. ODE should use the point system that drives the A-F ratings, not the summative ratings. That’s because the number of F-rated schools may exceed the 5 percent target. Using the points system, however, would allow ODE to identify just the bottom 5 percent. By limiting the number of comprehensive-support schools, the state could better focus its resources on the organizational changes necessary to improve Ohio’s lowest performing schools. It may also discourage state policymakers from lowering the bar just to have fewer schools assigned F’s and placed under state oversight.

Eliminate the Watch category of schools from the ESSA Plan (Title I, Part A: Improving Basic Programs Operated by LEAs, Subpart 4; lines 319-337).

Under ESSA, Ohio must identify two groups of schools as in need of improvement (“comprehensive” and “targeted” support schools). But ODE’s plan goes beyond these categories and identifies a third group of low-performing schools called “watch” schools. The basis for this identification is found in state, not federal, law, and ODE may not need to include Watch schools in its plan to comply with ESSA. In the coming days, Ohio lawmakers should consider eliminating or modifying the state law that allows ODE and the State Board to identify Watch schools and subject them to school improvement plans. Under federal law, Ohio must already intervene in schools with low-performing subgroups, i.e., “targeted” support schools. The Watch category goes further—perhaps a step too far—by identifying even more schools for intervention based on subgroup performance. It’s unlikely that ODE has the capacity to support in a meaningful way so many schools for improvement.


ODE’s ESSA plan should simply describe how it intends to meet federal requirements within the state accountability framework. In the areas noted above, ODE could dial back or clarify its compliance with ESSA before submitting the plan to federal officials. Each of these suggestions has the potential to reduce the administrative burdens—while maintaining accountability for outcomes—and free Buckeye educators to focus on students. 

Policy Priority:

Aaron Churchill is the Ohio research director for the Thomas B. Fordham Institute, where he has worked since 2012. In this role, Aaron oversees a portfolio of research projects aimed at strengthening education policy in Ohio. He also writes regularly on Fordham’s blog, the Ohio Gadfly Daily, and contributes analytic support for…

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