GAO Report on ESSA implementation: Most Plans Fall Short, Responsibility for Monitoring and Oversight is Diffuse and Muddled


February 1, 2024

Even though the Every Student Succeeds Act (ESSA) was signed into law more than 8 years ago, the casual observer might be surprised to learn that we know precious little about its implementation. That’s why a GAO report published on Tuesday is so important and potentially valuable. Which is not to say that it offers easy answers. Far from it.

The study is limited to those schools that are identified under ESSA as in need of “Comprehensive Support and Improvement (CSI),” basically those schools the Act sees as in need of the most intensive attention. For those schools, the GAO study focuses on 3 ESSA requirements for their improvement plans, namely that they:

  1. are based on a needs assessment;
  2. identify resource inequities, and, 
  3. include evidence-based interventions.

Keep in mind that there are other plan requirements but that GAO chose, somewhat wisely, to focus on these 3. There’s a lot to dig into, more than we have space to do justice to in this space, but here are our top 5 takeaways from the study:

  1. Most States Are Out of Compliance. According to GAO, only 42% of school improvement plans address all 3 elements on which they focused; in other words, well over half did not. On an A-F scale, that’s inarguably a failing grade. Also, keep in mind that the GAO study is merely binary i.e., whether or not a plan addressed the element in some way. There is much less in the GAO report on how well the elements are addressed but the information that is there is fairly damning.
  1. Plan Elements Around Resource Equity Are Particularly Bad. Only about half (52%) of all school improvement plans addressed resource inequities. And only a small subset of these addressed the kind of resource inequities that many of us had in mind when the law was written. For example, only 13 percent of plans evaluated whether district or school funding was equitably distributed despite the fact that other provisions in ESSA were designed to make those determinations easier. As the GAO understatedly pointed out: “[p]lans that do not evaluate school-based resource inequities may not identify important ways in which the educational system is under-serving some student groups or schools.”
  1. Ensuring Interventions Are Evidence-Based Is Easier Said Than Done. Much was made at the time of the requirements in ESSA that school improvement efforts be “evidence-based.” But it’s not quite panning out as intended. According to the GAO, many of the school leaders they interviewed cited the “evidence-based” requirements of the law as the most difficult to interpret and implement. GAO postulates that the U.S. Department of Education’s (ED) “What Works Clearinghouse” could serve as an alternative or supplement to ESSA’s evidence-based criteria but, long story short, even ED has reservations about “What Works’” validity and not a single principal interviewed by GAO was aware of “What Works” as a possible resource.
  1. Responsibility for Monitoring and Enforcing ESSA is Diffuse and Muddled. The title of the GAO report is literally “[U.S. Department of] Education Could Enhance Oversight of School Improvement Activities.” The report clearly makes the case that state and district oversight is not cutting it when it comes to the basics, namely a more equitable distribution of education resources and well-informed changes in school policy and practice. The response from ED to GAO’s recommendations for better oversight are, shall we say, nuanced. ED doesn’t pointedly refute them and pledges to do added oversight beginning this year. But, at the same time, GAO reports, for example, that “Education officials…emphasized that states—rather than Education—have primary responsibility for assuring school and district compliance with ESEA requirements.” (emphasis added).
  1. We Need to Rethink Our Expectations for Who Does What When It Comes to Accountability. It’s pretty clear from the GAO report that 1) States and districts are meeting neither the letter nor the spirit of the law when it comes to school improvement; and, 2) ED cannot be relied upon to ensure ESSA compliance in a systematic way. This isn’t entirely ED’s fault. Even if ED accepts all of GAO’s recommendations, we are still looking at a system that relies on a sampling of states and districts rather than scrutinizing all of the more than 5,000 schools that GAO reports are under CSI, and that doesn’t include the schools that are identified for support and improvement under other criteria in the law.

Federal policy is a blunt instrument. When it comes to bright-line policies like requiring statewide assessments in grades 3-8 or the disaggregation of data, monitoring and compliance is relatively easy compared to more complicated policies like defining “needs assessments” or ensuring that interventions in thousands of schools are “evidence-based.” Advocates need to rethink accountability by being clear-eyed about what we can reasonably expect from each level of government and being strategic about which levers of government we pull in trying to dramatically improve outcomes for our nation’s most at-risk students.