Slow Down, You Move Too Fast

I had the chance to provide testimony at the State Board meeting today on behalf of the Greater Cincinnati School Advocacy Network regarding concerns with ODE’s posted timeline for developing the State ESSA plan.  Below are the written comments, followed by feedback I provided to ODE in response to their request for electronic submission of ESSA ideas (which you can submit at:

Overall, the message was well received, and I feel confident that the process will slow down a bit.  Now the important part is making sure that interested voices from around the state are truly heard, and that ideas from practitioners in the field are listed to and incorporated into Ohio’s ESSA plan.  It’s the only way forward if the Department is serious about rebuilding trust between Columbus and the local school districts.

Ohio State Board of Education Comments

Greater Cincinnati School Advocacy Network

February 8, 2016

Good afternoon President Gunlock, Vice President Elshoff, and members of the State Board of Education.  My name is Keith Millard, and I serve as the Superintendent of the Batavia Local School District. Today I am here representing over forty school districts and Superintendents that are part of the Greater Cincinnati School Advocacy Network.

The passage of the Every Child Succeeds Act presents an opportunity to come together as an educational community in the State of Ohio in order to fix issues around testing and accountability that we all agree are plaguing our system.

The spirit of ESSA is to return control of educational policy to states and local boards of education, and for all stakeholders to have the opportunity to provide meaningful input in the crafting and development of state plans.

As the law must not be fully implemented until the 2017-2018 school year, there is time afforded to create a strategic engagement plan that will allow for all voices to be heard as Ohio shapes a plan that will significantly impact the next generation of school children across the state.

While we appreciate the urgency surrounding creating a plan to transition from ESEA to ESSA, we urge the State Board and the Department to not act with undue haste.  In our estimation, the timeline presented by the Department to the State Board in January for the development of a final plan is accelerated at a pace that far exceeds where other States are, and will not allow for the type of meaningful engagement that ESSA intends for, especially at the local level.

In researching ESSA implementation plans of other State Departments of Education, a timeline similar to the one presented to the State Board in January 2016 has not been found.  States such as Utah, Minnesota, Kentucky, New York, Texas, Florida, Virginia, and Arkansas either have no ESSA transition information listed on their Department websites or a scant mention that transition planning is underway.

In the timeline laid out by the Oregon Department of Education, a deadline for the completion of their preliminary draft plan is August 31, 2016, and this date is qualified by a statement that the date is ‘tentative pending submission date and guidance from the US Department of Education’.

The Vermont Agency of Education is proposing to spend a full year drafting their ESSA plan, with a target date of January 2017 for completing a submission draft for the US Department of Education.

The Wisconsin Department of Public Instruction, in a letter to the US Department of Education dated January 21, 2016, asks for clarification on the due date of ESSA plans, and proposes that plans should be due ‘no earlier than June 2017’.

Finally, In a letter to Deborah Spitz, the acting assistant US Secretary for Education, that was dated January 11, 2016, Peter Zamora from the the Council of Chief State School Officers also specifically asks for guidance on when state ESSA plans will be due to US Department of Education.

Given the ambiguity around the due date for ESSA plan submission, the fact that ESSA regulations will not be fully developed by the US Department of Education until October 2016, and the fact that many other states have yet to announce an ESSA transition timeline or have timelines that stretch into late 2016 or 2017, a recalibration of the timeline and engagement process for Ohio’s ESSA plan is in order.

For district superintendents, local boards of education, parents, and most importantly Ohio’s school children, it is critical that a robust engagement plan preclude any work on developing an initial draft of Ohio’s ESSA plan.

In a letter to Chief State School Officers dated February 2, 2016, John King, the Acting Secretary of Education, references numerous times that States AND Districts must work together in the development of a high quality assessment system, which is a critical component of State ESSA plans.

In Wisconsin’s January 21st letter to the US Department of Education, it states:

“(ESSA) provides us with an opportunity to explore different methods to tackle achievement gaps and ensure all students graduate college and career ready.  In order to take full advantage of this opportunity, State Education Agencies need to be able to have a comprehensive and transparent stakeholder engagement process.  Similarly, Local Education Agencies need to have the ability to plan and consult.”

Given the unique opportunity to craft a meaningful State plan that best represents and serves the needs of all Ohioans, the Superintendents of the Greater Cincinnati School Advocacy Network urge the following:

  1.  The new state superintendent must play an important role with ESSA, and the implementation timeline should be adjusted to allow for the State Superintendent to be named prior to major work beginning.
  1.  Superintendents, principals, teachers, school Boards, and parents must have the opportunity to provide input to the State’s ESSA plan.  We strongly recommend the Department break reauthorization tasks down into component groups similar to the ESSA State Plan Development Project laid out by the Oregon Department of Education, which includes local input in the areas of standards and assessment, accountability, school improvement, educator effectiveness, and communications.
  1. A comprehensive communications and outreach plan must be developed and shared, and include focus sessions and work groups that should be held throughout the State.
  1.  Local superintendents must play an integral part of the process in crafting the State’s ESSA plan.  As the conduits between the Department and our local communities, there is a wealth of knowledge about what works and what needs to be improved in State education policy.  We would urge that all work groups contain at least one local superintendent as part of their membership.
  1. Transparency and full, meaningful opportunities to participate in the ESSA development process.  We recognize the hard work and commitment to Ohio’s school children on the part of the Department, and stand ready to provide assistance in the complex task of developing Ohio’s ESSA plan.  To date, the only invited opportunity to provide feedback has come in the form of an email link in the February 1st edition of EdConnection to share ideas and questions.  It is critical that a robust engagement plan be created, shared, and implemented prior to the commencement of draft planning.  Furthermore, to build trust in the process, it is vital that the Department share at all phases exactly who has been part of the engagement process and who has provided feedback and input.

On the ESSA page located on the Department website, it states:

“Ohio is committed to involving educators, parents and other stakeholders as we explore new ways to ensure that all our students receive the education they need for bright futures.”

As a group, the Greater Cincinnati School Advocacy Network looks forward to partnering with the Department and the State Board as the State ESSA plan is developed, and again we urge a slowing down and expansion of the proposed ESSA timeline as well as the development and communication of a thorough and meaningful engagement plan which holds participatory activities across the State.

The opportunity presented by ESSA to return control of educational decisions to State and Local officials is one that must not be squandered.  By partnering with local boards of education, superintendents, and educators, the State Board and the Department have the chance to re-build bridges of trust and truly create an assessment and accountability system that works for the students of Ohio.

Thank you for your time and for your commitment to helping all learners in Ohio reach their maximum potential.


Comments sent to ODE’s ESSA email address on February 6, 2016
Please review the ESSA state development plan that has been produced by the Oregon Department of Education:

Furthermore, the timeline for the development of Ohio’s ESSA plan needs to be revised, and a comprehensive engagement plan which includes regional committees and meetings throughout the State must be developed and shared.
As USDOE has not released a due date for state ESSA plan submissions, and as many states have not even announced formal timelines for plan development and submissions, Ohio has the ability to back away from a July submission deadline and more throughly engage local superintendents, boards of education, and community members in the important task of Ohio’s ESSA plan development.
Finally, as the new State Superintendent will be the one responsible for the implementation of Ohio’s ESSA plan, it is critical that this person be involved from the very beginning of the development process.  Therefore, the time between now and when the new State Superintendent is named should be used exclusively for outreach and engagement, and the drafting of Ohio’s ESSA plan should not begin until after this appointment is made.
Thank you and I look forward to being a part of the process to help Ohio draft a plan that will orient all students in the State towards high degrees of college and career readiness.