ERN DC – Letter to OSSE on Proposed Amendment to ESSA State Plan for Accountability

Blogs, Letters & Testimonials

July 7, 2022

Dr. Christina Grant, State Superintendent of Education
Office of the State Superintendent of Education
1050 First Street NE
Washington, D.C. 20002

Dear Dr. Grant,

We are pleased to submit a public comment to the Office of the State Superintendent of Education (OSSE) regarding its proposed amendment to the Every Student Succeeds Act (ESSA) State Plan for Accountability. OSSE must make bold changes and adopt new ways of thinking so that all our students recover from the COVID-19 pandemic and have a just and equitable public education in the District.

In February, 50 members of our community wrote a letter[1] urging you to adopt five recommendations that would improve accountability in our public education system, namely:

  1. Re-strategize and refocus outreach efforts to ensure that families in all eight wards know that the D.C. School Report Card and Transparency and Reporting (STAR) Framework is a tool they can use to help them make decisions about schools.
  2. Get buy-in from families and D.C. residents in all eight wards, particularly those furthest from opportunity, on how best to use the D.C. School Report Card and STAR Framework to serve their students better.
  3. Improve, but do not eliminate the single summative rating.
  4. Administer the district-wide annual assessment exam this spring.
  5. Get serious about innovation and school improvement.

We are pleased to see the adoption of the first four recommendations and look forward to seeing progress on the fifth. As OSSE considers advancing its proposed amendment to the ESSA State Plan for Accountability, we urge you to ensure all changes are equitable, accessible, and transparent. Therefore, we offer the following eight recommendations to improve the amendment:

  • Increase the weight of the “students with disabilities” student group
  • Increase the weight of students of color within the race/ethnicity student group, while holding them to high standards
  • Remove median growth percentile
  • Ensure D.C. has an effective statewide annual assessment
  • Incentivize the expansion of dual enrollment and dual credit as a school quality & student success indicator
  • Include structured literacy training for all educators in elementary schools
  • Provide clear information on school quality
  • Harness the accountability system to support schools

Guiding Principle #1 – Equity:

Increase the weight of the “students with disabilities” student group

We applaud many of the changes OSSE makes to the student groups, including changing the term “at-risk” to “economically disadvantaged[2]” and increasing the “economically disadvantaged” weight from 5% to 40%. With these changes, OSSE is demonstrating an understanding that our accountability system must prioritize and serve student groups who are furthest from opportunity, which is a step in the right direction. Because placing a greater emphasis on serving students furthest from opportunity is the right and smart thing to do, OSSE should also increase the weight of the “students with disabilities” subgroup. Students with disabilities experience the most significant challenges in public education in D.C, particularly students of color who are economically disadvantaged with disabilities. Students with disabilities have the lowest PARCC exam scores in ELA and Math[3] and the lowest graduation rates.[4] They also are more likely to be discriminated against, disciplined, and not attend college. We also know that the COVID-19 pandemic only exacerbated these inequities. OSSE should increase the weight of the students with disabilities subgroup by taking five points from the “all students” group and applying it to a new subgroup, “economically disadvantaged students with disabilities.”

Increase the weight of students of color within the race/ethnicity student group while holding them to high standards

Currently, OSSE proposes 15 percent for the race/ethnicity student group, divided evenly between all race/ethnicity student groups. Dividing evenly between all groups undermines the purpose of having the metric there in the first place. We recommend that OSSE keep the overall 15% weight but increase the weight of students of color within the race/ethnicity student group. OSSE must hold students of every race and ethnicity to the same high expectations while acknowledging the harmful impact that racism has on marginalized groups.

Remove Median Growth Percentile

We must hold all schools to high standards when preparing our students for life, school, and career. By using median growth percentage, OSSE focuses on how well a student is doing compared to their peers across the District and the country, rather than whether they are growing towards grade-level expectations. This change will likely hide where our problem spots are in public education by relying on relative, rather than absolute, growth. We recommend placing the entire growth weight in Growth-to-Proficiency and Approaching Expectations and removing Median Growth Percentile.

Ensure D.C. has an Effective Statewide Annual Assessment

Because there have been hundreds of years of racism, discrimination, and lowered expectations for students of color within our public education, it is vitally important that we have objective academic measures that can be reliably and validly measured within our accountability system. With that said, we are disappointed that OSSE appears to be moving away from the PARCC exam. We urge OSSE to keep PARCC,[5] or at least a high-quality statewide annual assessment with the following crucial features:

  • Culturally responsive
  • Offer Smarter Balance Assessment
  • Assess both problem-solving and critical thinking
  • Ensures student learning aligns with the Common Core standards
  • Offer numerous accommodations for students with learning challenges and disabilities
  • Make the data more useful for students and families[6] by providing rapid results — paired with the key academic standards we should focus on next with our students — along with access to resources explaining how parents can support

Guiding Principle #2 – Accessibility:

Incentivize the Expansion of Dual Enrollment and Dual Credit as a School Quality & Student Success Indicator

We support the addition of a dual enrollment indicator and would encourage the addition of dual credit. States across the country are moving away from a model which only affords students with dual enrollment courses for college credit towards a model which allows students to receive both high school and college credit for completing the course. Too few students get dual credit opportunities in D.C., and we are an outlier in this regard. By providing dual credit courses, students have more time to devote to other important college and career activities. They are more likely to treat dual credit courses as part of their core academic experience rather than an extra or supplemental enrichment activity. We also encourage OSSE to ensure all schools offer rigorous AP/IB opportunities.

Include Structured Literacy Training for All Educators in Elementary Schools

Because only 30% of students are proficient in reading by fourth grade,[7] we recommend that OSSE add a metric for schools that provide educators serving students K-5 with structured literacy training, which is shown to improve literacy for all students, particularly those with reading difficulties like Dyslexia. This training ensures that the District remains serious about ensuring every student can read on grade level. At the very least, this information should be published on the D.C. School Report Card.

Guiding Principle #3 – Transparency:

Provide Clear Information on School Quality

We believe it’s important for OSSE to identify struggling schools and support them. Currently, OSSE is considering removing the summative rating for schools and providing an “accountability calculation.” Regardless of whether the District moves away from STARS, we believe it is essential for parents and families to have a single transparent summative calculation for determining how well a school serves each student population across all metrics every year. Even more importantly, OSSE must clearly and effectively explain in an easy-to-understand and accessible manner how it arrived at that calculation and why.

Harness the Accountability System to Support Schools

ESSA requires states to set aside 7% of Title I funds for schools identified in need of support, and we do not know what happens with the funding. Further, it is unclear what happens to a school after three years of support. OSSE should make its action plan explicit so the public is aware and can play an active role in holding schools accountable for student success.

In closing, we urge you to adopt our key recommendations to incentivize equitable change within our public education. As always, we look forward to continuing to partner with you to ensure that all students have just and equitable opportunities in the District.

Jessica Giles
State Director, Education Reform Now D.C.

CC: Rep. Jessica Sutter, President, D.C. State Board of Education; Rep. Eboni-Rose Thompson, Vice President, D.C. State Board of Education D.C. State Board of Education


[1] February 23, 2022. “ERN D.C. Submits Letter to OSSE Superintendent on STAR Framework.

[2] Why changing the designation “at-risk” is necessary Source:

[3] PARCC exam, p. 12 source:

[4] 2020-2021 High School Graduation, source:

[5] April 18, 2022. “Artecka Brown: Why I’m one of the many parents who want the PARCC exam this year” Source cited:

[6] March 2022. “FAMILY GUIDE TO ASSESSMENTS: Questions to Ask About Your Child’s Assessment Results and Why They Matter” Education Reform Now, Source:

[7] 2019 National Assessment of Educational Progress