Educational equity and civil rights organizations submitted a joint public comment on Indiana’s revised proposed A-F school accountability system regulations
November 17, 2025 by EdTrust 
Public Comment on Indiana Accountability Regulations 2.0
We share Indiana Department of Education’s (IDOE) belief that holistic, non-test-based measures of student outcomes, in addition to growth and proficiency on statewide assessments, are essential for gaining a full picture of how systems are supporting students. However, we can only have this full picture if schools are held accountable for all these outcomes. Instead, IDOE proposes to count only a few indicators, with those indicators varying from student to student. This is significant because it makes it difficult to understand the meaning of a school’s rating and may result in schools holding some students to dramatically lower standards than others.
The IDOE’s proposed “menu” of success indicators varies substantially in terms of rigor, expectations, and objectivity. For instance, a middle school would earn the same number of points for a student whose math growth is at the 45th percentile as it would for a student whose growth is at the 65th percentile or higher, or for a student who attends school regularly. While all of these outcomes are important to measure, they are clearly not equal in rigor. Under the proposed system, schools can earn full credit for a student who meets any of three or more success indicators, regardless of their rigor, while any remaining unmet measures don’t impact the school’s rating at all.
While the proposed system includes both traditional academic and skill-based outcomes, it doesn’t adequately account for both. Instead, it allows some outcomes to be prioritized for some students and different outcomes for others. Given the longstanding inequities in access and expectations for students from low-income backgrounds, students of color, students with disabilities, and English language learners, we’re concerned that the proposed system will mask these inequities and allow them to go unaddressed.
We commend Indiana for continuing to report disaggregated data on student outcomes through its updated Indiana GPS dashboard. However, the proposed A-F system continues to have no accountability regarding how schools support the needs of specific groups of students, including students of color, students from low income backgrounds, students with disabilities, and English learners. The performance of these groups does not influence school letter grades, nor do the draft regulations describe how individual group data will affect school identification for support. In fact, the proposed system doesn’t provide any details on how schools will be identified for support and improvement — one of the core purposes of accountability systems. These missing elements in IDOE’s planned accountability system are likely to hamper the state’s ability to close longstanding opportunity gaps for its most vulnerable student populations. The regulations fail to guarantee that individual groups of students who are struggling academically will receive additional resources or supports, nor do they require the schools serving them to develop school improvement plans.
While English learner progress — the only student group outcome in the proposed system — is included as a student success indicator, schools won’t be held accountable for systemically failing to meet the needs of their English learners, because schools can receive full credit for student performance based on any three success indicators. This is particularly concerning given simultaneous efforts by IDOE to allow federal funding allocated by Congress to support English learners to be used for other purposes. In addition, English learner progress (ELP) is oddly minimized in the grade three framework, even though supporting English learners to become language proficient in the early grades is critically important. ELP only counts as a student success indicator for students who are at least “approaching” proficiency; for grade three students “below” proficiency, consistent attendance is the only success indicator that matters.
The proposed system also fails to hold schools accountable for ensuring all students are meeting grade-level standards. We believe that it’s important to measure students’ overall academic performance and their growth toward academic standards to fully understand whether schools are meeting the needs of their students.
However, in grades four to eight, the proposed system conflates the two by allowing student growth to replace achievement. While schools should get substantial credit for improving student knowledge and skills, this cannot take the place of measuring whether students are achieving on grade level. Doing so allows schools to shirk their responsibility of supporting all students to meet grade-level expectations.
This issue is even more pronounced in high school. Schools can earn full credit for supporting students without any objective, test-based measures, completely neglecting the students who need support the most in school ratings. In 10th grade, for example, a school can earn full credit for a student based solely on course completion (both regular and CTE courses) and attendance–all self-reported measures. The same applies in 12th grade, as changes to the draft regulations mean that performance on the SAT is no longer considered when determining whether all students are meeting expectations. Instead, much like in 10th grade, schools can earn full credit for students based on success measures that do not evaluate whether they can read and do math at the state’s grade-level academic standards.
Even more concerning, both the previous and current regulations only consider the outcomes of graduates in 12th grade, allowing high schools completely off the hook for students who fail to graduate with their class. A student who doesn’t graduate on time, regardless of how many success indicators they meet, doesn’t factor into a school’s A-F rating at all. This structure strongly discourages high schools from supporting their most at-risk students, as schools are not held accountable for those students who don’t graduate, or who don’t graduate on time.
While the proposed model is designed to be “student-centered” by providing a school a score for each individual student, the conflation of academic achievement and growth, along with the “menu” approach to success indicators, makes it difficult to understand what school letter grades actually say about school quality, even at the student level. Students with vastly different outcomes can earn the same score for a school. This lack of clarity makes it difficult for parents and families to determine whether their school is effectively preparing students for success or to make informed choices about where their children are most likely to succeed.
For instance, a middle school would earn full credit for a sixth grade student who earned above expectations on the state assessment, passed the state science and social studies exams, and earned an A in their advanced math class. Yet that school could also earn full credit for another sixth grade student who scored below grade level expectations on the state assessment but made substantial growth, attended school regularly, and passed the third grade reading assessment for the first time that year. Despite having vastly different outcomes, the school receives the same full credit for these students.
Not only would these students be held to wildly different standards, but it would also be much harder for system leaders to determine where schools and districts need to target resources and support, as two schools could receive very similar overall scores in the A-F system while having students who earned those points in very different ways. This confusion will also be compounded in elementary and high schools, where the grade three framework score will be averaged with the score for grades four and higher and where the grade 10 results will be averaged with the grade 12 results. It will be much harder for families and communities to understand whether schools are fully meeting the needs of all students.
Additionally, there is a lack of clarity in the current regulations around growth expectations for students. Student growth targets play a substantial role in determining schools’ scores in grades four to eight, as a student can move from the bottom (i.e., “below” expectations) to the top category (“above” expectations) by meeting their individual growth target. However, the regulations and supplemental materials don’t provide any information about how these growth targets are determined or how progress against them is measured.
Given the above concerns, we strongly urge IDOE to amend the proposed A-F system to:
Once the final accountability regulations are adopted, it will be essential to develop and execute a robust communication plan that clearly explains the various aspects of the model — not only to school and district leaders but also to families and communities. In particular, it will be important to provide clarity about how the indicator “menu” works to create a final score for schools and how growth — particularly the growth target — is calculated. Communication resources should provide clear talking points that local leaders can use to discuss these changes with community members.
Additionally, IDOE should develop clear guidance for school and district leaders about how they can use the new accountability system, along with other data such as Indiana GPS, to provide targeted supports for both individual students and underserved student groups. As part of this work, IDOE should develop and share state resources and technical assistance opportunities to support local leaders in this process. It will also be important to explain how IDOE plans to leverage accountability data to provide support for schools with the most need.
IDOE will also need to monitor district and school results carefully, as well as issue guidance and provide technical assistance to its district and school leaders, to prevent unintended consequences if the new A-F framework is adopted — in particular, to prevent gaming the point-based system to systematically steer certain groups of students, such as students with disabilities or students from low-income backgrounds, toward success measures that are perceived as less rigorous than others. When a school can get the same “credit” for a graduate who (1) earns an Enrollment, Enlistment, or Employment “Plus” seal, (2) earns college credit through dual enrollment, and (3) meets the college-ready English metric on the ACT as it does for a graduate who (1) doesn’t earn any diploma seals, (2) attends school regularly, (3) completes 150 hours of work-based learning, and (4) earns a credential of value, it could create perverse incentives to lower expectations and encourage certain students to forgo opportunities that would prepare them for a wider range of pathways beyond high school.
We appreciate the Indiana Department of Education for releasing the second draft of its A-F accountability system for public comment. Many of the undersigned groups expressed our concerns about the first draft of the proposed regulation in public comment, as well as through direct engagement with IDOE staff. While IDOE states that the goal of the proposed system is to ensure all students are learning a diverse set of skills needed for lifelong success, we continue to have substantial concerns that the amended regulations, in fact, undermine the state’s goal of supporting all students and compromise equity by allowing Indiana schools to hold students to dramatically different standards while ignoring the performance of individual groups of students despite persistent gaps in student performance across the state. We welcome the opportunity to connect with IDOE staff to discuss these concerns and recommendations as you work to finalize the regulations in the coming weeks.
Sincerely,
All4Ed
EdTrust
National Center for Learning Disabilities
National Parents Union
UnidosUS
