Michigan Department of Education Submits Proposed Revisions to State ESSA Plan; Autism Alliance of Michigan Comments

Public Comment on Proposed Revisions to the Michigan ESSA Plan

Dear Superintendent Dr. Michael Rice:

The Autism Alliance of Michigan (AAoM) respectfully submits our comments
related to the proposed revisions to the Michigan ESSA Plan.

AAoM is a statewide nonprofit with a mission to lead efforts to raise
expectations and expand opportunities for those touched by autism across
the lifespan. We have been engaged in systems change across Michigan
since 2009. One of our core pillars focuses on education; raising expectations for ALL students with disabilities in accessing high-
quality, inclusive education that has results
(e.g., graduation rates, post-
secondary opportunities) on par with their neurotypical peers.

Summary of proposed amendments related to Question 1:

  • Resetting long-term goals and measures of interim progress, also
    known as School Index targets, to use data from 2021-22.
    Existing targets reflected pre-pandemic performance and are set
    to expire after the 2024-25 school year. Refreshing the targets
    with 2021-22 data reflects the impact of the pandemic on
    Michigan’s students.

Updating the schedule of identifying schools for support.

  • Updating supporting data for the School Quality/Student success
    measures. Existing data supporting these measures dates to
    almost a decade ago. Refreshing the plan with more recent data helps to show how these measures continue to be valid post-pandemic.

QUESTION 1. Michigan’s statewide accountability system: Please provide
any comments you have related to the proposed amendments to Title I, Part
A, Section 4, pages 9 to 53. Connects also to Appendix A, pages 135-142.

Our comments focus on the proposed long-term goals and measures of
interim progress as well as the current subgroup (‘n size) in use.

Academic Achievement
According to the table presented on pages 20-21 of the proposed
amendments, the long-term goal for students with disabilities in 2030-32 is
as follows:

ELA: 56.31%
Math: 43.94%

The measurements of interim progress proposed in Appendix A for students
with disabilities as follows:

ELA: 28.18%
Math: 20.62%

ELA: 32.20%
Math: 23.95%

These measures of interim progress differ dramatically from the targets that
the Michigan Dept. of Education (MDE) submitted to the U.S. Department of
Education’s Office of Special Education Programs in its 2022 IDEA Part B
State Performance Plan/Annual Performance Report (SPP/APR) (available
at https://sites.ed.gov/idea/files/MI-B-SPP-FFY20.docx) which lists
proficiency targets for students with disabilities taking the regular
assessment in 2025 as follows:

Grade 4: 18.20%
Grade 8: 25.30%
High School: 15.40%

Grade 4: 17.50%
Grade 8: 10.00%
High School: 6.70%

We note that while the goals and interim targets for students with disabilities
in the Michigan ESSA plan include students with disabilities who take the
state’s alternate assessment, the vast majority of students with disabilities
participate in the state’s general assessment (with or without
accommodations). Given this, the proficiency rate of students with
disabilities in the alternate assessment has little impact on the overall
proficiency rates, goals, and interim targets.

These vastly differing targets present a number of problems as follows:

  1. In both data reporting and target setting in the SPP/APR, states have
    been instructed to “use the same data as used for reporting to the
    Department under Title I of the ESEA, using EDFacts file
    specifications FS175 and 178.” However, it would appear that the
    MDE has not followed this requirement.
  2. The SPP/APR targets are the targets used to measure and
    determine the implementation of the IDEA by local educational
    agencies (LEAs) in the state on an annual basis. Therefore, while the
    ESSA plan provides much more ambitious targets, LEAs are not
    judged on achievement of those goals for students with disabilities.

We also wish to point out that ESSA requires states to annually access at
least 95% of all students and every student subgroup. Assessment
participation is one of the seven components within Michigan’s School
“Index identification” system. However, Michigan has failed to meet this
requirement for students with disabilities in recent years, making proficiency
on state assessments less than reliable.

Four‐year adjusted cohort graduation rate (ACGR)
The long-term goal for the ACGR for students with disabilities (shown on
page 24 of the proposed amendments) is 93% for 2031-2032, an increase of
36 percentage points over 10 years.

Achieving this goal would take the formulation and execution of an
aggressive plan to dramatically improve the ACGR for students with
disabilities given the following realities:

  • Michigan’s ACGR for students with disabilities has improved a mere
    7 percentage points during the 10-year period from 2010 to 2019,
    going from 52% in 2019-2020 to 59% in 2019-2020. In fact, the
    ACGR for Michigan’s students with disabilities dropped to 57% in
    2020-2021 and 58% in 2021-2022, netting an improvement of just 6
    percentage points over 12 years. Given this, it would appear highly
    unlikely that the rate of improvement would more than triple over the
    ten years from 2021-2022 to 2031-2032.
  • Michigan has one of the highest graduation gaps between students
    with disabilities and students without disabilities in the United States.
    In 2020-2021, the gap was 26.6 percent compared to 18.1
    percentage points nationwide. Only 4 states had larger gaps (ID, MS,
    NY, SC). (See Building a Grad Nation Annual Update 2023,
    Appendix K)

Minimum N‐Size
Michigan’s amended ESSA plan indicates that the state will continue to use
a minimum n-size of 30 in calculating the subgroup metrics for identifying
schools for comprehensive, targeted and additional targeted support.

We are concerned that use of this rather large n-size is resulting in a
significant number of schools escaping accountability, particularly for the
“students with disabilities” subgroup. Given that this n-size has now been in
use for several years, there should be ample data available regarding the
number of schools that do not meet the n-size for student subgroups.

Therefore, we request that MDE publish a report on the impact of the current
n-size so that the public can be aware of the number and percentage of
schools that fall outside of the identification system

Thank you for the opportunity to comment.

Please feel free to contact Colleen Allen, President & CEO of the Autism
Alliance of Michigan with any questions or concerns: