Antoinette S. Mitchell, Ph.D.
State Superintendent of Education
1050 First Street, NE
Washington, DC 20002

Attn: ESSA Waiver Public Comment

Dear Superintendent Mitchell,

We, the undersigned education and civil rights advocacy organizations, write to offer comments on the Office of the State Superintendent of Education’s (OSSE) proposed ESEA waiver request. At a time when many states are pursuing politically motivated waivers that risk undermining essential federal equity guardrails, we believe that OSSE’s proposed temporary pause of its state accountability system represents a strategic use of the ESEA waiver authority that will serve District of Columbia (DC) students by providing stability in school ratings and identification for support while transitioning to a new assessment system.

First, OSSE’s decision to transition to Smarter Balanced assessments demonstrates DC’s commitment to high quality assessments aligned with rigorous academic standards, while also providing schools with aligned interim assessments and educator support. Despite the resulting disruption to longitudinal and growth data, this switch is also a clear response to stakeholder feedback to adopt a new assessment system that will better support data informed decision making.

In response, OSSE has developed a clear waiver request to address temporary data gaps, particularly calculating academic progress. As OSSE states in its request — reflecting the views of DC stakeholders — measuring growth is essential for providing families and policymakers with data about how students are progressing in their learning over time. Including growth in state accountability systems alongside achievement also provides a fairer measure of school quality by giving schools credit for the progress students make from year to year, particularly when schools have large numbers of students that are starting the year far below grade level. This information can be used to determine where to target resources and supports to ensure students are making adequate progress towards proficiency against academic standards.

Given the focus on growth in DC’s accountability system, OSSE’s decision to request waiving school ratings and identification for a single year shows a strong commitment to maintaining a stable and reliable signal of school quality across DCPS and DC charter schools. In particular we believe that this waiver represents a thoughtful approach because it:

1. Limits the pause to a single year. While ESSA Section 8401(d)(1) allows states to apply for waivers for up to four years, OSSE has proposed pausing their accountability system for only one year to enable growth to be accurately calculated using their new assessment. This will ensure that students in schools that need additional supports are promptly identified following this transition year.
2. Prioritizes stability and predictability. Given the substantial weight of growth in DC’s accountability system, calculating school ratings (and using those ratings to identify schools) without growth data would likely be confusing and disruptive — especially for school leaders. Ratings could change dramatically from previous years when growth was included, so pausing them will both reduce possible swings in scores and allow educators and school leaders to adjust to the new assessment system during the transition year.
3. Maintains school improvement supports. OSSE makes clear that pausing ratings will not mean pausing meaningful supports for schools. Instead, state staff will continue to support its current cohort of identified schools via its renewed school improvement framework, with a focus on those schools that have not yet met state exit criteria. The waiver will also ensure that currently identified schools receive ongoing financial support via Section 1003 school improvement funds.
4. Maintains a commitment to transparency. During the waiver period, OSSE will continue to report all data (other than growth, which can’t be calculated) on the DC School Report Card site and will share state assessment results with parents during the pause year–which should happen before the start of the following school year. This continued reporting will ensure school leaders and families have access to essential data needed to identify and support student needs.

Thank you again for the opportunity to provide comments on OSSE’s proposed ESEA waiver. We believe this waiver will enable DC students and educators with a smooth transition to a new, rigorous assessment system, while maintaining public transparency and essential supports to low-performing schools. We welcome the opportunity to engage further with OSSE about this waiver request and the transition to Smarter Balanced.

Sincerely,

All4Ed
Center for Strong Public Schools
DC Public Education Fund
Education Forward DC
EdTrust
ElectED DC
EmpowerK12
Federal City Council
National Center for Learning Disabilities
National Parents Union
PAVE (Parents Amplifying Voices in Education)
Thurgood Marshall Academy PCHS
UnidosUS