Does the proposed model adequately prioritize both traditional academic outcomes, as well as skill development?

We are writing to provide feedback on Indiana’s proposed A-F school accountability system regulations. While the proposal includes several positive elements, the system as currently designed contains several elements that would undermine its transparency, fairness, and effectiveness through ratings that obscure student achievement and turn a blind eye to inequities. We urge the Department to address these critical issues before finalizing these regulations to ensure the system truly serves Indiana’s students and communities.

The proposed system demonstrates several commendable features that reflect sound educational priorities. Providing a summative A-F rating provides stakeholders with an accessible overview of school performance, enabling parents and communities to quickly understand how well schools are meeting student needs. Additionally, the student success indicators chosen by the Department could create a more holistic view of school performance, including attendance to ensure students are engaged; science and social studies achievement to combat curriculum narrowing; and advanced coursework enrollment in middle and high school, along with the alignment of diploma seals with accountability metrics, to reinforce the importance of college and career readiness.

However, despite these strengths, we have several concerns about the proposed system that demand correction before implementation.

How will the proposed model better prepare students for personal and professional success?

The ultimate goal of strong accountability systems is to honestly and accurately identify the lowest performing schools in the state, so that these schools can receive the additional support and resources they need to improve student performance. The proposed regulations make no mention of how the state will use its new A-F ratings to identify schools for state support. Given the Department’s simultaneous efforts to use only this system of accountability and to reallocate school improvement funds, we have strong concerns about Indiana’s systemic efforts to support the highest-need schools in the state.

The proposed system completely fails to examine performance across student groups. The regulations make no mention of either including student group performance in school ratings or identifying schools for support based on performance for student groups. In doing so, Indiana would effectively abandon its responsibility to ensure equitable outcomes for all students. Without group accountability, achievement gaps will go unnoticed and unaddressed. The state, districts, and schools will lack the imperative to focus on underserved populations, perpetuating inequities.

The inclusion of English language proficiency as one option among multiple indicators obscures how well schools are serving English Learners. Schools that don’t meet targets for students learning English can earn the same score in the proposed system as students who do. This approach hides how well the Indiana schools are meeting the needs of English Learners, particularly troubling given simultaneous efforts to allow federal funding dedicated to English Learners to be diverted to other uses.

Is the proposed model simple and easy to understand?

The proposed definition of “above expectations” in academic proficiency undermines academic rigor by allowing students to also achieve this designation by meeting individual growth targets, meaning students performing below grade level can be classified alongside truly proficient peers, despite needing additional support to meet standards.

This approach eliminates consistent academic achievement standards, sends mixed messages about what constitutes success, and could prevent schools from getting support they need to ensure all students can meet grade-level expectations.

The point calculation system creates problems with the transparency and actionability of school ratings. The final scores are ultimately meaningless because proficiency scores are multiplied by how many other indicators schools support students to meet, meaning there is no clear rating for each indicator.

For instance, fourth grade students scoring “approaching expectations” on the state assessment could each have different scores  — 40, 60, 80, or 90 points — based on the number of targets the student also meets, including attendance, growth, and college and career readiness. Schools could similarly earn the same score for students with different achievement levels.

And success indicators could differ for each student. Two students at “approaching expectations” scoring 60 could have achieved different indicators, while a student earning a school 60 points could be at any achievement level.

This complexity doesn’t just obscure achievement: it also makes it difficult to understand performance on success indicators — holistic measures Indiana has worked hard to develop through meaningful engagement  — making the system impossible for stakeholders to understand or use effectively for school improvement.

How can the proposed model be improved?

To address these concerns and create a truly transparent, fair, and effective accountability system, we recommend that Indiana:

• Develop clear criteria for identifying the lowest performing schools in the state, both for all students and for individual student groups
• Implement student group accountability to ensure schools remain focused on meeting the needs of all students
• Create a standalone English Learner progress indicator to ensure transparency in serving Indiana’s nearly 100,000 English Learners, 10% of Hoosier students.
• Establish clear and consistent academic measures that consider achievement and growth separately
• Adopt a criterion-referenced growth measure that allows all students to demonstrate progress toward grade-level standards
• Simplify the point system to create meaningful and comparable ratings that stakeholders can understand by creating standalone metrics for each of the holistic school quality and student success metrics, including ninth grade on-track
• Use graduation rate as a distinct, weighted component rather than a variable multiplier

Indiana has an opportunity to develop a robust accountability system that drives meaningful school improvement while maintaining focus on equity and transparency. However, the current proposal requires substantial revision to achieve these goals. We urge the Department to address these fundamental design flaws before finalizing its regulation in December to ensure the system serves all Indiana students effectively.

Additional feedback/comments

The reliance on Student Growth Percentile introduces additional concerns. As a normative measure, SGP ensures that not all students can demonstrate growth simultaneously, creating artificial limits on the recognition of improvement. Since growth is measured only relative to other schools’ growth, schools that improve won’t receive credit if other schools improve more, while schools that don’t make sufficient progress may not see this reflected in SGP if other schools made even less progress. Since SGP requires setting growth targets after spring assessments are scored, growth targets cannot be known in advance, making it impossible to set clear expectations or track progress throughout the year. Most importantly, by only comparing students to one another, SGP doesn’t consider whether students are making adequate progress towards proficiency.

While on-track metrics are valuable, the current proposal equates credit completion with academic achievement, creating a potentially misleading picture of student readiness, masking serious academic needs as students move through high school.

Using graduation rate as a multiplier of a school’s final rating rather than its own indicator with a set weight can result in an inequitable impact on high school ratings. Graduation rates can drastically influence ratings — far more than any other individual metric — and represent a different weight for every school, creating unfairness: a high school with a 90% graduation rate would see no change to its school rating, while another with a graduation rate of 89% could see its score drop an entire letter grade.

Please share any questions below. Note: the proposed new accountability model is still in draft form and will continue to be improved, based on public feedback, between now and December.

Thank you for the opportunity to provide feedback. We stand ready to support efforts to strengthen this important initiative and would welcome the chance to discuss these concerns further.

Sincerely,

All4Ed
Council of Parent Attorneys and Advocates
EdTrust
National Center for Learning Disabilities
National Parents Union