In April, the Ohio Department of Education and Workforce released an amended ESSA plan for public comment that proposes stronger state interventions in chronically low-performing schools. More assertive turnaround efforts couldn’t come soon enough for students attending such schools. But as news reports have covered, some education advocates have sharply criticized the amendment. If their complaints prevail and the department walks back its proposal (not yet finalized), low-performing schools will be allowed to continue poorly educating students without serious accountability or consequence.
As policy background, federal education law—the Every Student Succeeds Act (ESSA), the 2015 rewrite of No Child Left Behind—requires states to identify low-performing schools and undertake improvement efforts. Schools in the bottom 5 percent statewide or with graduation rates below 67 percent are placed in “comprehensive support and improvement” (CSI) status. Identified schools must create a state-approved improvement plan and are eligible for federal improvement grants. If CSI schools fail to improve within a certain timeframe (three years in Ohio), states must then implement “more rigorous interventions.”
While ESSA obligates states to help low-performing schools improve, the law does not prescribe how precisely to execute that assistance. In Ohio’s initial—and still current—ESSA plan, state officials mention things such as light-touch “supports” from regional educational service centers and vague “improvement reviews” for CSI schools—even for those subject to ESSA’s more rigorous interventions. Nothing, however, is mentioned about bolder efforts to more fundamentally restructure low-performing schools or permanently close them.
Not surprisingly, Ohio’s laid-back approach to ESSA-era school turnaround has proven ineffectual. In a 2025 study, American Institutes for Research/Rand Corporation researchers uncovered no discernible improvements in state exam scores and diminished attendance and graduation rates in Ohio CSI schools. In a necessary course correction, the ESSA amendment sharpens what intervention would look like in the state’s lowest performing schools. The department lists sixteen possible actions that it may require of CSI schools subject to more rigorous interventions. They include:
- Undergoing a comprehensive school redesign led by an approved education provider;
- Reopening with a new principal who is given authority to replace staff and restructure programs;
- Converting to a charter school that replicates practices of high-performing schools;
- Merging with a high-performing school operated by an approved charter operator;
- Contracting with an external education provider to run part or all of the school;
- Closing the school permanently.[1]
DEW’s tougher stance opens the door to actions that lead to better outcomes, yet the proposal received nothing but scorn from the public-school establishment. Canton City Schools superintendent Jeff Talbert asserted that DEW was pushing “unproven models that risk undermining public education and community control.” Teachers’ union boss Melissa Cropper bemoaned a lack of “stakeholder input” in objecting to the amended plan. The Cleveland Plain Dealer editorial board threw a fit, accusing DEW of “trying to sneak through” stronger interventions “through a waiver [sic] request” that is “almost certainly illegal.”[2]
The complaints are off the mark for several reasons.
First, DEW is not circumventing the political process. On the contrary, with its proposed amendment, the agency is more faithfully fulfilling its responsibilities under federal education law. Recall that ESSA demands that state education agencies escalate interventions when a CSI school continues to fail year after year. Here’s the text (emphasis mine):
The State educational agency shall establish statewide exit criteria for schools identified by the State for comprehensive support and improvement, which if not satisfied…shall result in more rigorous State-determined action, such as the implementation of interventions.
When local control does not produce acceptable results, federal law obligates state officials to intervene on behalf of students through “state-determined action” in low-performing schools. What DEW proposes upholds the law—not undermines it.
Second, the low-performing schools facing these tougher, “more rigorous” interventions have struggled to make sufficient improvements for multiple years. In the traditional district sector, 34 CSI schools have been in such status since 2018 (going on a decade), and another 9 CSI schools have been so identified since 2022. In the charter realm, 20 general-education charter schools have been identified for CSI since at least 2018.[3] Simply identifying these schools as low-performers and requiring some paperwork has not made a difference. DEW is right to ratchet up the pressure when they persistently underperform. And in the charter sector, sponsors should also play their part by closing poor performers. If they refuse, the state’s recently beefed-up automatic closure law may finally kick in.
Third, some have decried charter school mergers or takeovers as a possible intervention. But their concerns are more political theatrics than an evenhanded assessment of the merits. As research from Ohio and elsewhere reveals, high-performing charter networks deliver the equivalent of weeks and months’ worth of additional learning. Handing over the keys to a high-performing charter operator may in fact be the best recourse for the school, and the students who attend it.
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Every student deserves to attend an excellent school that prepares them for life after high school. Unfortunately, thousands of Ohio students attend subpar schools that rob them of opportunities for success. DEW’s ESSA amendment is a critical step toward fixing what ails these public institutions. Ohio policymakers should disregard the critics, dig in their heels, and start the hard work of turning around the state’s most troubled schools.
[1] Other possible interventions include mandatory instructional coaches, overhauling curriculum and teacher PD, comprehensive academic reviews by an external entity, and several other actions. CSI schools subject to “more rigorous interventions” would be required by DEW to implement one or more of the sixteen measures.
[2] The Plain Dealer misrepresented DEW’s proposal for state intervention in low-performing schools, which is an amendment to its ESSA implementation plan—not a “waiver” from federal law.
[3] This excludes 64 dropout-recovery charter high schools that almost by definition have low four-year graduation rates and result in CSI identification.