Stephanie Valentine, PRA Coordinator
Strategic Collections and Clearance Governance and Strategy Division
U.S. Department of Education
400 Maryland Avenue SW, Room 6W208B
Washington, DC 20202-8240

RE: Agency Information Collection Activities; Comment Request; Implementation of Title I/II-A Program Initiatives ( Docket ID ED-2021-SCC-0129 )

Dear Coordinator Valentine,

On behalf of The Education Trust, an organization dedicated to closing long-standing gaps in opportunity and achievement that separate students from low-income backgrounds and students of color from their peers, thank you for the opportunity to comment on the request by the U.S. Department of Education (“the Department”) for comments regarding the Department’s draft information collection request on the implementation of Title I and Title II-A Program Initiatives under the Every Student Succeeds Act (ESSA). The Department, including the Institute for Education Sciences (IES), plays a critical role in collecting data and monitoring implementation of critical federal programs, including those authorized under ESSA, that are intended to address opportunity gaps.

We appreciate the Department’s continued support for collecting information on the experiences and needs of states, school districts, school leaders, and teachers, as well as whether critical federal programs are stimulating educational equity as intended. These surveys are intended to provide data about the impact of the primary federal law governing K-12 education, and our feedback is intended to ensure that the data collected is comprehensive, actionable, and centered around the policies and practices that impact students from low-income backgrounds, students of color, students with disabilities, English learners, students experiencing homelessness, and other underserved groups of students.

First, we commend the Department for maintaining its focus on tracking how states and school districts are utilizing the flexibility provided by ESSA, as well as updating these surveys to reflect the challenges that have been exacerbated and created by the COVID-19 pandemic. In particular, we support the robust set of questions aimed at identifying the evidence-based strategies and practices being implemented to accelerate student learning in the face of unfinished instruction.

One important area on which the surveys fall short, however, is that they fail to appropriately collect information about efforts to diversify the teacher workforce. The need to provide a strong and diverse teacher workforce for all students is as urgent as ever, particularly as school and district leaders develop plans to address unfinished learning and help students catch up after the COVID-19 disruptions. A growing body of research shows that having access to teachers of color benefits all students — and can be particularly transformative for students of color . Yet, only 21% of teachers in the U.S. are teachers of color. Moreover, the lack of diversity of the teacher workforce relative to the student population (more than half of all students in the national public school population identify as a person of color) is one driver of inequity in education, even as states and districts continue to invest in strategies to increase the racial diversity of their workforces.

Finally, we strongly encourage IES to publish the results and any related analysis from these surveys in a way that helps illuminate different practices between schools and districts with varying percentages of students from low-income backgrounds, students of color, students with disabilities, and English learners.

In addition to the broad comments above, we offer the attached recommendations in response to the Department’s draft state, district, principal, and teacher surveys.

We are happy to respond to any questions that you may have regarding the contents of this letter and the attachments; please contact Reid Setzer, Director of Government Affairs, at rsetzer@edtrust.org . Thank you for your consideration.

Sincerely,

The Education Trust

Attachment 1: Recommended Revisions for Implementation of Title I/II-A Program Initiatives – District Survey

Please find below recommendations for revisions to current questions in the District Survey. Underlined text represents additions.

Throughout survey – definitions: In each relevant definition section, amend the definition of “Comprehensive Support and Improvement (CSI) schools” to include the third group of CSI schools that states are required to identify under ESSA – those with chronically underperforming subgroups – as follows:

• “Comprehensive Support and Improvement (CSI) schools are those in the bottom 5 percent of all Title I schools, and schools with graduation rates below 67 percent, and schools with chronically underperforming subgroups, as defined under ESEA for federal accountability.”

Question 0-6: Break this question into two questions, requiring states to separately identify whether any of their low-performing schools are designated for Targeted Support and Improvement (TSI) or Additional Targeted Support and Improvement (ATSI).

Questions 1-1 to 1-3: To the greatest extent possible, the Department should align these questions and response options with those provided in the School Pulse Panel Data Collection . It should define “most” as “more than 50%” of students to ensure the collection of comparable information across school districts.

Questions 1-5 to 1-8 and 1-13 to 1-14: Amend the response options (under “Professional Development [PD] Topic”) as follows:

• (a): Separate “Curricula, standards, and subject matter content” into three options — “Curricula and instructional materials;” “Standards;” and “Subject matter content.”
• (d): Amend this option as follows: “Other specific evidence-based strategies to help students catch up or accelerate learning (not focused on use of technology).”
• (g): Separate “Engaging students and families,” so information on the engagement of students and families can be collected separately — “Engaging families;” and “Improving classroom management or relationships with students” (this option is included in a similar question in the School Survey).
• Add two new topics: (1) “Restorative classroom management practices or other alternatives to punitive practices (e.g., suspensions, expulsion)” (this option is included in a similar question in the School Survey), and (2) “Conducting assessments and using data on student progress to inform instruction.”

Question 1-9: Add the following two response options (under “Topic”):

• “Engaging with families of students with disabilities”
• “Supporting the social, emotional, and mental health needs of students with disabilities”

Question 1-10: Add the following response option (under “Topic”):

• “Engaging with families of English learners”

Questions 1-5 to 1-14: In general, the professional development opportunities and experiences of school leaders are underemphasized in this survey. We recommend duplicating questions 1-5 to 1-14 to focus on school leaders, in addition to retaining the current questions focused solely on teachers. In addition, for questions related to the professional development and support offered to school leaders, we suggest adding the following topics:

• “Master scheduling”
• “Supporting inexperienced or low-performing teachers”
• “Providing feedback to teachers and evaluating them”
• “Connecting with community-based organizations.”

Question 1-15: Add the following two areas, which are included in other parts of the survey as well:

• “Culturally responsive practices”
• “Implicit bias”

Question 1-22: We appreciate the Department’s effort to collect data on which programs districts are using to recruit and hire teachers of color. We recommend revising option (d) to include a broader set of alternative programs:

• (d): “Alternative Certification programs (e.g., Teach for America, Urban Teachers, TNTP, other AmeriCorps programs)”

Question 1-25: Consistent with prior questions and responses focused on district support for professional certifications (e.g., National Board Certification), add “National Board Certification” as an option in the list of “Source(s) of Information” used to inform how the district defines teacher quality or effectiveness.

Question 1-26: Because the experiences of students from low-income backgrounds and students of color are not synonymous, the responses to this question should be broken into separate options, as follows:

• “The examination revealed that low-income students tended to …”
• “The examination revealed that students of color tended to …”

Questions 1-27 and 1-28: Add another response option (under “Action Taken”) to include an additional option for school leaders that is parallel to existing action (g) for teachers:

• “Offering more professional development for principals/school leaders in schools with lower levels of teacher quality or effectiveness compared to other schools.”

Additional Question: As noted in the attached letter, a growing body of research shows that having access to teachers of color benefits all students and many state and local efforts to diversify the workforce can be supported with funding under Titles I and II-A. Therefore, after Question 1-28, there should be an additional question about the actions taken by the district to address the lack of diversity in the educator workforce (similar to existing question 1-27 about teacher quality and effectiveness).

• Additional Question: “What actions has your district taken to diversify the teacher workforce in the past 12 months?”
• Actions Taken: (Districts required to select “Yes” or “No” for each action).
  • a) “District set a clear, numeric goal for increasing the racial diversity of the educator workforce”
  • b) “District developed a task force, advisory group, or role within the LEA to examine, create, and monitor strategies to increase the racial diversity of the workforce”
  • c) “District Invested in Grow Your Own programs or teacher academies to increase the diversity of the workforce”
  • d) “District partnered with teacher preparation programs to ensure targeted recruitment and hiring”
  • e) “District invested in cultural competence and anti-bias trainings for hiring managers and school leaders”
  • f) “District invested in residency models to support and prepare candidates of color”
  • g) “District invested in opportunities for teachers of color to grow and develop in their abilities and qualification for leadership roles, including targeted PD and cohort models”
  • h) “Others:”

Additional Question: After the proposed new question above, there should be an additional question about the primary actions taken by the district to address the lack of diversity in the educator workforce (similar to existing question 1-28 about teacher quality and effectiveness).

• Additional Question: “What actions were the primary ways in which your district has taken action to diversify the teacher workforce in the past 12 months?”
• Actions Taken: (Districts required to select up to three responses).
  • a) “District set a clear numerical goal for increasing the racial diversity of the educator workforce”
  • b) “District developed a task force, advisory group, or role within the LEA to examine, create, and monitor strategies to increase the racial diversity of the workforce”
  • c) “District Invested in Grow Your Own programs or teacher academies to increase the diversity of the workforce”
  • d) “District partnered with teacher preparation programs to ensure targeted recruitment and hiring”
  • e) “District invested in cultural competence and anti-bias trainings for hiring managers and school leaders”
  • f) “District invested in residency models to support and prepare candidates of color”
  • g) “District invested in opportunities for teachers of color to grow and develop in their abilities and qualification for leadership roles, including targeted PD and cohort models”
  • h) “Others:”

Questions 2-9 and 2-13: In addition to identifying whether CSI schools and Title I schools are required to use the listed instructional planning resources, the Department should also require school districts to identify whether TSI schools are also required to use such resources.

Question 3-2: We appreciate the Department’s focus on collecting information about the implementation of the statewide assessments required under Title I. As drafted, however, question 3-2 and the related skip logic do not recognize that, beyond the waiver of statewide assessments granted by the Department to Washington, DC, several other states (e.g., California ; New Mexico ) did not require all school districts to administer statewide assessments last school year (2020 – 2021). Therefore, the Department should add this response option to question 3-2: “The district did not administer the state ELA and math assessments for last school year (2020 – 2021).”

Questions 3-15 and 3-42: In addition to identifying whether CSI schools, other low-performing schools, and Title I schools received additional resources, the Department should also require school districts to identify whether TSI schools received additional resources.

Question 3-17: As noted in the attached letter, we strongly support the Department’s deep focus on collecting information on unfinished learning. Within this question, we recommend two amendments to the list of strategies provided:

• (a): To identify whether schools are implementing evidence-based tutoring strategies , clarify that “small groups of students” means fewer than five students — “Provide tutoring to individual students or small groups of fewer than five students.”
• Consistent with other related questions, add the following response option: “Provide more math or English language arts (ELA) instruction than usual (e.g., “double-dosing” with two periods of math or ELA).”

Question 3-19: To assess whether all students have access to tutoring, we recommend adding another option:

• “All students in the school are required to meet with a tutor.”

Question 3-20: Though evidence shows that both paraprofessionals and teachers can be effective tutors, these are distinct groups, and information about who is conducting tutoring should recognize their different professional backgrounds and training. Therefore, we suggest that sub-question (a) be separated into two questions:

• “Approximately what percentage of tutors are paraprofessionals?”
• “Approximately what percentage of tutors are current or former teachers?”

Questions 3-27 and 3-28: Add a response option (under “Features of Elementary and Middle School Summer Programs;” “Features of Extended Learning Time”) that recognizes that students learn best where their identity is affirmed :

• “Students participated in culturally reflective or identity affirming activities.”

Additional Questions: Research shows that expanded learning time , including expanded learning time offered in the summer or during the school year (e.g., after- or before-school programs, a longer school day, a longer school year) can be effective for all age groups, types of students, and subject matter.

Given that, we recommend the Department ask questions 3-27 and 3-28 about programs offered to high school students (in addition to elementary and middle school students).

Questions 3-29 and 3-30: Similar to the recommendation above to add questions about the expanded learning time programs offered to high school students, we recommend that the Department align the programs listed for K-8 students and high school students (i.e., add “Summer programs,” and “Extended learning time during the school year” for high school students).

Question 3-32: Given the inequitable impacts of COVID-19 and related school closures, we appreciate the Department’s efforts to collect information on whether Black and Latina/o students were given priority for programs intended to accelerate learning. We recommend the Department also seek information on whether Native students were given similar priority through an additional option:

• “Native American students”

Question 3-53: Add two response options (under “School Improvement Topics”):

• “Scheduling staff and students effectively”
• “Recruiting and retaining diverse teachers”

Question 3-57: For the first time under federal law, ESSA requires states and districts to report per- student school spending information. We appreciate the Department’s focus on whether districts are using this information to examine and address inequities. We suggest the Department define “meaningful differences” (e.g., differences greater than 5% or 10%) in the response options to collect information that is comparable across school districts.

Attachment 2: Recommended Revisions for Implementation of Title I/II-A Program Initiatives – School Survey

Please find below recommendations for revisions to current questions in the School Survey. Underlined text represents additions.

Throughout survey – definitions: Section 1 defines “Novice teachers” as those in their first, second, or third year of teaching. We recommend the Department ensure the definition for “novice teacher” used here aligns with the definition that the Department uses in other circumstances (e.g., the Civil Rights Data Collection collects data on teachers in their first or second year of teaching).

Throughout survey – definitions: In each relevant definition section, amend the definition of “Comprehensive Support and Improvement (CSI) schools” to include the third group of CSI schools that states are required to identify under ESSA — those with chronically underperforming subgroups — as follows:

• “Comprehensive Support and Improvement (CSI) schools are those in the bottom 5 percent of all Title I schools, and schools with graduation rates below 67 percent, and schools with chronically underperforming subgroups, as defined under ESEA for federal accountability.”

Questions 1-3 and 1-4: Amend the response options (under “Professional Development (PD) Topic”) as follows:

• (a): Separate “Curricula, standards, and subject matter content” into three options — “Curricula and instructional materials;” “Standards;” and “Subject matter content.”
• (d): Amend this option as follows: “Other specific evidence-based strategies to help students catch up or accelerate learning (not focused on use of technology).”
• (g): Separate “Engaging students and families” to ensure that information on the engagement of students and families is collected separately — “Engaging families;” and “Improving classroom management or relationships with students” (this option is included in a similar question in the School Survey).
• Add two new topics: (1) “Restorative classroom management practices or other alternatives to punitive practices (e.g., suspensions, expulsion)” (this option is included in a similar question in the School Survey), and (2) “Conducting assessments and using data on student progress to inform instruction.”

Question 2-11: We appreciate the Department’s focus on collecting information about the implementation of the statewide assessments required under Title I. We recommend the Department amend the answer options so it can identify which schools administered the state-mandated academic assessment in the spring or summer of 2021 versus the fall of 2021. This difference in timing likely has significant implications for how the results of the assessments were used in planning for this school year (2021 – 2022). The revised answers should be as follows:

• “Yes, our school administered the state-mandated academic assessments for ELA or math during spring or summer of 2021.”
• “Yes, our school administered the state-mandated academic assessments for ELA or math during fall of 2021.”
• “No, our school did not administer the state-mandated academic assessments for ELA or math during spring, summer, or fall 2021.”

Additional Question: One primary purpose of the statewide assessments required under Title I of the ESSA is to provide parents and families with information about their student’s progress against grade level standards. Therefore, we recommend the Department ask schools to identify how they communicated about the results of these assessments with parents and families.

• Additional question: “Prior to or during the 2021 – 22 school year, how did your school communicate state-mandate academic assessment results from last year (administered in the spring, summer or fall of 2021) to parents and families?”
• Answer options (check all that apply):
  • a) “Mailed results to families”
  • b) “Offered families online access to their student’s results (e.g., via an online student portal)”
  • c) “Instructed teachers to share results with parents and families”
  • d) “Our school district sent results to parents and families”

Question 3-8 (option a) and 3-11 (option j): As noted in the attached letter, we strongly support the Department’s deep focus on collecting information about unfinished learning. Within this question, we recommend two amendments to the list of strategies provided:

• To identify whether schools are implementing evidence-based tutoring strategies , clarify that “small groups of students” means fewer than five students — “Provide tutoring to individual students or small groups of fewer than five students.”

Question 3-14: To assess whether all students have access to tutoring, we recommend adding another option:

• “All students in the school are required to meet with a tutor.”

Question 3-23: Though evidence shows that teachers, paraprofessionals, and trained and supported instructional aids can be effective tutors, these are distinct groups, and information about who is conducting classroom instruction and tutoring should recognize their different professional backgrounds and training. Therefore, we suggest that the “Features of Elementary/Middle School Summer Programs” highlighted in options (a) and (b) be broken into separate options:

• (a): “Offered classroom instruction by teachers or paraprofessionals.”
• Additional question: “Offered classroom instruction by paraprofessionals.”
• (b): “Offered one-on-one or small group tutoring by teachers, paraprofessionals or instructional aids.”
• Additional question: “Offered one-on-one or small group tutoring by paraprofessionals or instructional aids.”

Questions 3-23 and 3-24: Add a response option (under “Features of Elementary and Middle School Summer Programs;” “Features of Extended Learning Time”) that recognizes that students learn best where their identity is affirmed :

• “Students participated in culturally reflective or identity affirming activities.”

Additional Questions: Research shows that expanded learning time , including expanded learning time offered in the summer or during the school year (e.g., after- or before-school programs, a longer school day, a longer school year) can be effective for all age groups, types of students, and subject matter. Given that, we recommend the Department ask question 3-23 about programs offered to high school students (in addition to elementary and middle school students).

Questions 3-25 and 3-26: Similar to the recommendation to add questions about the expanded learning time programs offered to high school students, we recommend that the Department align the programs listed for K-8 students and high school students (i.e., add “Summer programs,” and “Extended learning time during the school year” for high school students).

Question 3-28: Given the inequitable impacts of COVID-19 and related school closures, we appreciate the Department’s efforts to collect information on whether Black and Latina/o students were given priority for programs intended to accelerate learning. We recommend the Department also seek information on whether Native students were given similar priority through an additional option:

• “Native American students”

Question 3-43: Add two response options (under “School Improvement Topics”):

• “Scheduling staff and students effectively”
• “Recruiting and retaining diverse teachers”

Attachment 3: Recommended Revisions for Implementation of Title I/II-A Program Initiatives – Teacher Survey

Please find below recommendations for revisions to current questions in the Teacher Survey. Underlined text represents additions.

Question 1-3: Add the following two response options (under “Topic”) :

• “Engaging with families of students with disabilities”
• “Supporting the social, emotional, and mental health needs of students with disabilities”

Question 1-4: Add the following response option (under “Topic”):

• “Engaging with families of English learners”

Questions 1-7 to 1-9: Amend the response options (under “Professional Development (PD) Topic”) as follows:

• (a): Separate “Curricula, standards, and subject matter content” into three separate options — “Curricula and instructional materials;” “Standards;” and “Subject matter content.”
• (d): Amend this option as follows: “Other specific evidence-based strategies to help students catch up or accelerate learning (not focused on use of technology).”
• (g): Separate “Engaging students and families” to ensure that information on the engagement of students and families is collected separately — “Engaging families;” and “Improving classroom management or relationships with students” (this option is included in a similar question in the School Survey).
• Add two new topics: (1) “Restorative classroom management practices or other alternatives to punitive practices (e.g., suspensions, expulsion)” (this option is included in a similar question in the School Survey), and (2) “Conducting assessments and using data on student progress to inform instruction.”

Question 3-16: Given the inequitable impacts of COVID-19 and related school closures, we appreciate the Department’s efforts to collect information on whether Black and Latina/o students were given priority for programs intended to accelerate learning. We recommend the Department also seek information on whether Native students were given similar priority through an additional option:

• “Native American students”

Attachment 4: Recommended Revisions for Implementation of Title I/II-A Program Initiatives – State Survey

Please find below recommendations for revisions to current questions in the State Survey. Underlined text represents additions.

Throughout survey – definitions: In each relevant definition section, amend the definition of “Comprehensive Support and Improvement (CSI) schools” to include the third group of CSI schools that states are required to identify under ESSA — those with chronically underperforming subgroups — as follows:

• “Comprehensive Support and Improvement (CSI) schools are those in the bottom 5 percent of all Title I schools, and schools with graduation rates below 67 percent, and schools with chronically underperforming subgroups, as defined under ESEA for federal accountability.”

Questions 1-1 to 1-4: Amend the response options (under “Professional Development (PD) Topic”) as follows:

• (a): Separate “Curricula, standards, and subject matter content” into three separate options — “Curricula and instructional materials;” “Standards;” and “Subject matter content.”
• (d): Amend this option as follows: “Other specific evidence-based strategies to help students catch up or accelerate learning (not focused on use of technology).”
• (g): Separate “Engaging students and families” to ensure that information on the engagement of students and families is collected separately — “Engaging families;” and “Improving classroom management or relationships with students” (this option is included in a similar question in the School Survey).
• Add two new topics: (1) “Restorative classroom management practices or other alternatives to punitive practices (e.g., suspensions, expulsion)” (this option is included in a similar question in the School Survey), and (2) “Conducting assessments and using data on student progress to inform instruction.”

Question 1-11: Teacher preparation programs play an important role in efforts to recruit, support, and graduate new teachers of color. Therefore, we recommend adding response options (under “Type of Information”) that assess whether the state uses candidate diversity to evaluate the effectiveness of programs:

• “The racial and ethnic diversity of the program’s graduates who earn certification”
• “The racial and ethnic diversity of the program’s graduates placed in teaching jobs”
• “The rates of retention in the profession of the program’s graduates who are teachers of color”

Additional Question: After question 1-12, insert an additional question to identify whether states are reporting information about the racial and ethnic diversity of the state’s teacher preparation programs.

• Additional Question: “Within the past 12 months, has your state reported information about the racial and ethnic diversity of the teachers they prepared to traditional and alternative preparation programs that the teachers attended or to the public using information listed in [question 1-11]?”
• Response Options (“Type of Information”): For each, require states to select “Yes” or “No.”
  • “State reported information about diversity to traditional preparation programs”
  • “State reported information about diversity of traditional preparation programs to the public [If available, please provide link to report]:”
  • “State reported information about diversity to alternative preparation programs”
  • “State reported information about diversity of alternative preparation programs to the public [If available, please provide link to report]:”

Question 1-18: Because the experiences of students from low-income backgrounds and students of color are not synonymous, the responses to this question should be broken into separate options. In each instance, replace, “The examination revealed that low-income students and students of color tended to….” with two separate questions as follows:

• “The examination revealed that low-income students tended to …”
• “The examination revealed that students of color tended to …”

Question 1-19: Add the following response options (under “Action Taken”):

• “State assisted districts with less-qualified or less-effective teachers and those with greater teacher shortages to hire teachers earlier”

Additional Question: As noted in the attached letter, a growing body of research shows that having access to teachers of color benefits all students, and many state and local efforts to diversify the workforce can be supported with funding under Titles I and II-A. Therefore, after Question 1-19, there should be an additional question about the actions taken by the district to address a lack of diversity in the educator workforce (similar to existing question 1-19 about teacher quality and effectiveness).

• Additional Question: “What actions has your state taken to diversify the teacher workforce in the past 12 months?”
• Action Taken: (States required to select “Yes” or “No” for each action).
  • a) “State set a clear numerical goal for increasing the racial diversity of the educator workforce”
  • b) “State developed a task force, advisory group, or role within the LEA to examine, create, and monitor strategies to increase the racial diversity of the workforce”
  • c) “State Invested in Grow Your Own programs or teacher academies to increase the diversity of the workforce”
  • d) “State partnered with teacher preparation programs to ensure targeted recruitment and hiring”
  • e) “State invested in cultural competence and anti-bias trainings for hiring managers and school leaders”
  • f) “State invested in residency models to support and prepare candidates of color”
  • g) “State invested in opportunities for teachers of color to grow and develop in their abilities and qualification for leadership roles, including targeted PD and cohort models”
  • h) “Others:”

Questions 2-13 and 2-21: In addition to identifying whether CSI schools and Title I schools received written guidance, individualized support, or group professional development on the following topics, the Department should also require states to identify whether TSI schools received these resources.

Question 2-14: The current response options include responses that would violate federal law (e.g., canceling statewide assessments in 2021–2022). Therefore, the Department should remove the following option:

• “N/A Assessment Was Not Administered”

Question 2-18: We support the Department’s commitment to ensure that all states report on statewide assessment participation rates, as required under ESSA, and appreciate the Department’s probing questions about whether states will report participation rates disaggregated by instructional setting. To ensure this data is useful in identifying whether individual groups of students in different instructional settings were able to participate in the state-mandated academic assessments, and consistent with ESSA’s existing requirement that participation rates be disaggregated, we recommend the Department add response options to capture whether states are disaggregating by both instructional setting and student group:

• “Participation rate by instructional setting (e.g., percentage of students learning in remote or distance, hybrid, or in-person classes), disaggregated for each student group”
• “Percent proficient or advanced by instructional setting (e.g., percentage of students learning in remote or distance, hybrid, or in-person classes), disaggregated for each student group.”

Question 2-19: One primary purpose of the statewide assessments required under Title I of the ESSA is to provide parents and families with information about their student’s progress against grade level standards. Therefore, we recommend the Department ask states to identify whether they provided written guidance, individualized support, or group professional development to districts and schools about using results to inform and support parents and families:

• Additional option: “How to use state-mandated academic assessment data to provide opportunities for families to be involved in students’ academic progress.”

Question 3-62: As noted in the attached letter, we strongly support the Department’s deep focus on collecting information about unfinished learning. Within this question, we recommend the Department amend option (g) to better identify whether states are implementing evidence-based tutoring strategies by clarifying that “small groups of students” means fewer than five students:

• (g): “Provide tutoring to individual students or small groups of fewer than five students.”

Question 3-65: Given the role that states play in monitoring and enforcing federal and state requirements, it is important to differentiate when states “require” versus “recommend” action. Therefore, we recommend that this question be amended to require states to: (1) identify on which student groups the state required placing priority for strategies to catch up on or accelerate learning and (2) identify on which student groups the state recommended placing priority for strategies to catch up on or accelerate learning.

Question 3-73: Given the disparate impacts of COVID-19 and access to online learning for students of color, students from low-income backgrounds, students with disabilities, English learners and other underserved groups, we recommend the Department require states to disaggregate by student group the percentages of students in the state who are enrolled full time in online schools.

Question 3-96: For the first time under federal law, ESSA requires states and school districts to report per-student school spending information. We appreciate the Department’s focus on whether states are using this information to examine and address inequities. We suggest the Department define “meaningful differences” (e.g., differences greater than 5% or 10%) in the response options, so it can collect information that is comparable across states.