Melissa Junge and Sheara Krvaric are attorneys and co-founders of Federal Education Group, PLLC, a law and consulting firm that works with states, school districts, and other educational organizations. They help school systems to leverage federal grants, find ways to do things that are permitted under federal law but not well understood, and help states and school systems avoid getting buried under federal reporting and compliance requirements. They’ll be writing about how to make ESSA programs, such as Title I, work better for students.

This week we are writing about three modest ways the U.S. Department of Education (ED) can help to make Title I more effective for students. Today, we address how ED could use existing ESSA authority to encourage coherent planning for low-performing schools. Planning may seem mundane, but, as we’ll discuss, it shapes the services schools deliver to students as well as how schools spend federal funds.

ESSA requires some high-poverty, low-performing Title I schools to develop two different plans for improving student outcomes. Each plan has its own requirements, which can be hard to coordinate. This can lead to unaligned services and spending.

The first plan is known as a schoolwide plan and is required of any Title I school that operates a schoolwide program (an option that lets most Title I schools spend Title I funds on systemic school improvements rather than just targeted services for certain students).

The second plan is a comprehensive support and improvement (CSI) plan and is required for certain low-performing schools identified by the state through its accountability system. Essentially, CSI plans are school improvement plans for a state’s most struggling schools.

While the law encourages schools to coordinate these two plans “if appropriate,” in practice, coordination is difficult for a few reasons.

First, each plan has its own compliance rules, which are easiest to satisfy when the plans are developed separately. For example, the plans must be developed by different entities (ESSA requires schools to develop schoolwide plans and districts to develop CSI plans), they must include different things (each plan has its own required topics which, while related, do not always match up), and they must be developed in different ways (over different time periods and with potentially different stakeholders).

Second, in practice, the plans are often reviewed by different state offices that have different roles and expectations. States are required to monitor schoolwide plans as part of their general responsibility to verify that schools and districts meet Title I requirements, which is usually done by the state’s Title I office and typically focuses on legal compliance. States have more direct responsibilities for CSI plans. States must review and approve each school’s CSI plans under Title I’s accountability rules. This is often done by a state’s school improvement office that considers qualitative issues like whether the plan meets school needs and is educationally sound.

Because schools and districts tend to write plans based on the expectations of the state office that will review them, a school’s schoolwide and CSI plans may end up looking substantially different from one another. When that happens, student services tend to get fragmented. Fragmentation looks different from situation to situation, but we have seen cases where schoolwide and CSI plans describe different interventions for students with the same needs, interventions that are not aligned to each other, divergent professional development approaches, and the like.

This is not only potentially detrimental for students, it can be expensive. Generally speaking, a school must spend regular Title I funds consistent with its schoolwide plan, and if a school receives Title I school improvement funds (different from regular Title I funds), it must spend them consistent with its CSI plan. If a school’s plans are not aligned, it might drive ineffective spending.

Some states are aware of this disconnect and have encouraged alignment across plans or have tried to develop one planning tool to satisfy both sets of Title I requirements, but this has proved challenging given the separate compliance requirements for each plan.

To address this, ED could use authority it already has under ESSA to relieve schools and districts of the obligation to meet both sets of planning requirements. For example, if a district develops a CSI plan on behalf of a Title I school that operates a schoolwide program, ED could relieve the school of schoolwide planning requirements. This would permit a state’s lowest performing schools (CSI schools) and their districts to focus on developing and implementing one plan for improvement.

Generally, a state would have to ask ED for this kind of relief on behalf of its districts and schools, but ED could encourage requests. For example, ED could publicize the option to request relief from planning requirements, give examples of situations that would qualify for such a request, articulate a clear review and approval process for requests, and make a commitment to approve reasonable requests unless there are compelling reasons not to.

We do not suggest that ED should grant relief from any of ESSA’s requirements lightly, but in this case, encouraging a coherent planning approach for the lowest performing Title I schools could encourage coherent services and spending, and may help to make Title I more effective for students.

Next up, paperwork (it’s more interesting than it sounds) . . .

—Melissa Junge and Sheara Krvaric