As our advocate partners know well, students of color and students from low-income backgrounds are significantly more likely to attend schools with fewer resources than their White, more affluent peers. Two key resource equity provisions within the Every Students Succeeds Act (ESSA) — resource allocation reviews and school improvement plans — are designed to focus school improvement efforts on both identifying and addressing resource inequities in the nation’s lowest-performing schools.

It is no surprise that these key provisions were overlooked —  we and our fellow advocates who follow ESSA implementation have been concerned about this since before the pandemic. Now is the time for state policymakers to refocus on faithfully implementing federal law, and the US Department of Education is rightly urging states to move in that direction with the release of a Dear Colleague letter that makes recommendations based on its monitoring of resource allocation reviews and school improvement plans.

While much of the focus on federal accountability requirements is connected to specific outcome measures for rating schools and the school identification process, the goal of federal accountability is to drive school improvement by addressing longstanding resource inequities. This letter stresses the importance of resource equity in the school improvement process; however, the Department’s guidance contains recommendations, not requirements, so strong state advocacy is necessary to ensure states adopt and effectively implement them.

This letter (1) provides recommendations about how states should define vague terms in ESSA, (2) frames the purpose of accountability as identifying and addressing resource inequities, and (3) reinforces the important role of states in supporting schools and districts.

  • Defining Vague Federal Requirements
    • While federal law requires states to conduct resource allocation reviews in districts with a significant number of identified schools, it allows states to define “significant,” meaning states can set the bar high enough to effectively eliminate this requirement. Advocates should encourage states to align their definition of “significant” with ED’s recommendations by setting both a percentage and number threshold for what is considered “significant,” and having low thresholds to ensure that both large and small districts are eligible to get this important state support.
    • ESSA is similarly silent on what types of resources should be included in resource allocation reviews. ED’s letter encourages states to embrace an expansive definition of “resources” and recommends that states look beyond funding and review equitable access to other resources, including experienced educators, rigorous course work, and high-quality early learning opportunities. These recommendations are directly aligned with the Alliance for Resource Equity framework, so advocates should encourage states to use this framework as a foundation for state allocation reviews.
  • Accountability for Continuous School Improvement
    • The Department’s letter makes clear that resource allocation reviews and school improvement plans for identified schools are tools to hold states, districts, and schools accountable to students attending schools that aren’t receiving the resources they need to adequately meet the needs of all students. Allocation reviews and improvement plans can both help schools identify and address resource inequities in a way that supports and encourages continuous improvement. To support this work, advocates should work with states to adopt the practices outlined in the letter, particularly the following:
        • Aligning the timing of resource allocation reviews with timelines for school identification — which allows districts to use the results to inform their improvement plans.
        • Ensuring that resource equities are both identified and addressed in state-developed school improvement plan templates and reviews.
        • Following up with districts to provide support in addressing identified inequities.
        • Engaging stakeholders — including educators, students, and families — in conversations as a part of the allocation review process to support implementation strategies that address identified inequities and publicly report the results of allocation reviews.
  • Strong State Role in Supporting School Improvement
    • States can and should be doing more to support the implementation and success of school improvement plans. Advocates should encourage states to support districts and schools with guidance around identifying and addressing resource inequities in alignment with the Department’s recommendations, including a list of types of resources to examine, with accompanying data sources and/data tools and lists of evidence-based strategies to address inequities.
    • Most importantly, while schools and districts develop and implement school improvement plans, this letter reminds states that, under ESSA, they are required to provide technical assistance to identified schools and monitor the implementation of improvement plans. Given the absence of strong federal oversight, advocates should use this letter to encourage states to provide more robust monitoring in compliance with federal requirements, with a focus on addressing resource inequities. This monitoring could include:
        • systematic reviews of improvement plan implementation that prioritize the schools and districts with the most need;
        • dedicated staff to support identified schools through site visits, regular calls with school and district leaders, or on-demand technical assistance; or
        • connections to external resources or experts, such as those outlined in the Department’s letter.

The goal of federal accountability — especially since the passage of ESSA — is to ensure that states, districts, and schools focus on reversing decades of systemic inequitable access to high-quality learning opportunities. We know from our recent work on the Future of Assessments that our current system is not fully living up to this promise. The guidance and recommendations outlined in the Department’s letter can help states leverage federal accountability to drive equity through fairer school resource allocation and, ultimately, produce more equitable outcomes for all students. But, for this to happen, we need states to implement these recommendations.