Graphic showing several pushpins marking specific points on a chartJanuary 2017
A collaborative publication of the Center for Parent Information and Resources (CPIR) and The Advocacy Institute

Welcome to Section 5 of the Stakeholder Guide to the Every Student Succeeds Act (ESSA), which focuses on ESSA’s provisions regarding identification of schools in need of comprehensive support and improvement.

Not what you’re looking for?
See other sections of the guide.

The statewide accountability system (discussed in Section 4) must include a system for annual “meaningful differentiation” for all public schools based on all indicators for all students and each student subgroup. Beginning with school year 2018-2019, each state must identify one statewide category of schools for “Comprehensive Support and Improvement.” This category includes:

~at least the lowest-performing 5% of Title I schools in the state;

~all high schools failing to graduate one third or more of their students based on the four-year adjusted cohort graduation rate (ACGR) as defined at Section 8101 (25);

~any Title I school with chronically low-performing subgroup(s) of students that has not improved as a result of implementing a “Targeted Support and Improvement” plan over no more than 3 years (initial year of identification is determined by the state).

Following the initial identification of schools in need of Comprehensive Support and Improvement in the 2018-2019 school year, states must identify such schools at least once every 3 years.

Additionally, the state must identify schools for “Targeted Support and Improvement.” This category includes:

  • Any school with one or more consistently underperforming subgroups (beginning in the 2019-2020 school year and annually after that);
  • Any school in which one or more subgroups of students is performing at or below the performance of all students in the lowest performing schools.

Back to top

Parent Center Action Items

High School Identification. Under ESSA, the identification of high schools for “Comprehensive Support and Improvement” is based only on the four-year adjusted cohort graduation rate (ACGR) for all students. So, high schools could have a very low graduation rate for the students with disabilities subgroup (e.g., well below the 67% rate) but escape this identification if other groups are doing well enough to push the total graduation rate to two-thirds of all students or better. Stakeholders should carefully monitor the ACGR for the students with disabilities subgroup. The school could be identified as in need of targeted support and improvement based on a consistently underperforming subgroup.

States may adopt and set goals for extended-year cohorts (students who take longer than four years to earn a regular diploma). However, such goals must be more rigorous than goals for the four-year ACGR.

Alternate Diploma. ESSA allows states to count students with the most significant cognitive disabilities who both participate in the state assessment system via the alternate assessment on alternate academic achievement standards and meet the requirements of a state-designed alternate diploma to be counted as having earned a regular diploma in the four-year adjusted cohort or the extended-year cohort if the state adopts an extended-year ACGR. ESSA includes some criteria for such a diploma. Specifically, it must be:

“standards-based; aligned with the State requirements for the regular high school diploma; and obtained within the time period for which the State ensures the availability of a free appropriate public education under section 612(a)(1) of the Individuals with Disabilities Education Act (20 U.S.C. 1412(a)(1)”

The U.S. Department of Education has stated that, to its knowledge, no state currently has such a diploma. Stakeholders should take an active role in the development of such a diploma. Additionally, it must be clear that awarding a student with the most significant cognitive disabilities the alternate diploma allowed in ESSA does not constitute a change of placement and, therefore, does not terminate eligibility under IDEA. (Sec. 8002 (23))

Differentiated Improvement Activities. ESSA allows high schools to implement differentiated improvement activities if they predominately serve students who are significantly off track to accumulate sufficient academic credits or are returning to school after having exited without a diploma  (Sec. 1111 (d)(1)(C)(i). Since such schools may serve a disproportionate number of students with disabilities, stakeholders should seek to ensure that schools are still engaging in robust improvement activities that are proven to improve success rates for the students being served by these schools.

Small High School Exception. ESSA allows for high schools with a total enrollment of less than 100 students to forego implementation of improvement activities (Sec. 1111 (d)(1)(C)(ii). Stakeholders should seek to ensure that this provision does not result in high schools that serve high numbers of students with disabilities escaping implementation of improvement activities.

Consistently Underperforming Subgroup Identification for Targeted Support and Improvement. ESSA does not define the term “consistently underperforming” so it will be up to stakeholders to ensure that the methodology established by the state to identify schools for targeted support and improvement will be robust. Since students with disabilities are frequently performing far below both a school’s all-student group and other subgroups of students, it will be critical to safeguard against a methodology that would allow schools to escape identification for this subgroup of students. The methodology should be uniform across the state and across student subgroups. Stakeholders might request that the state provide estimates on the number and percentage of schools that would be identified using several approaches to operationalize “consistently underperforming.” ESSA federal regulations are expected to provide additional guidance on this important issue.

Development and Implementation of Comprehensive and Targeted Support and Improvement Plans. Schools identified for either Comprehensive or Targeted Support and Improvement must develop and implement activities spelled out in ESSA. Both the development and the implementation of these plans should include stakeholders, including parents. More specifically, parents who represent the subgroup(s) of students that lead to the school’s identification, particularly in schools identified for targeted support and improvement, should be among the stakeholders.

Equally important, the activities and interventions should be evidence-based and shown to improve performance for the particular group of students that lead to the identification. For information on evidence-based activities, strategies, and interventions, see the U.S. Department of Education’s non-regulatory guidance Using Evidence to Strengthen Education Investments, online at:

Public School Choice. ESSA includes a provision that allows a local school district to provide all students enrolled in a school identified for Comprehensive Support and Improvement the option to transfer to another public school in the district, unless such an option is prohibited by state law (Sec. 1111 (d)(1)(D)). Priority must be given to the lowest-achieving students from low-income families. Stakeholders should ensure that students with disabilities are provided with the same school choice options as their peers.

Back to top


Authorship | This guide has been produced in a partnership between the Center for Parent Information and Resources (CPIR) and The Advocacy Institute under a cooperative agreement from the U.S. Department of Education Office of Special Education Programs. The Center for Parent Information and Resources is a project of the Statewide Parent Advocacy Network, Inc.


Back to top

Index of Sections in the Stakeholder Guide to the ESSA

The Stakeholder Guide to the ESSA is presented in separate sections. Which section would you like to read now?

1 | Background, Structure of the ESSA, Implementation Timeline, State Plans, Stakeholder Engagement

2 | Academic Content Standards and Achievement Standards 

3 | Academic Assessments

4 | Statewide Accountability System 

5 | Identification of Schools in Need (You’re already here!)

6 | Annual Report Cards

7 | Conclusion and Resources

Back to top