Federal Identifications

ESSA identifications are at the school level. Schools may have multiple identifications. Schools identified within each of these categories are required to complete certain actions to exit the category:

• Comprehensive Support and Improvement (CSI): Schools identified for CSI have overall performance (summary score) in the bottom 5% of all schools in the state receiving Title I, Part A funds, or they have a graduation rate below 67%, or both. Identifications for CSI are normally made every three years. The first schools were identified in 2018-19.
• Targeted Support and Improvement (TSI): Schools identified for TSI have one or more student groups that is performing in the bottom 10% of the state. Identifications for TSI are normally made annually.
• Additional Targeted Support and Improvement (ATSI): Schools identified for ATSI have one or more student groups that is performing in the bottom 5% of all schools in the state receiving Title I, Part A funds. Identifications for ATSI are normally made every three years. The first schools were identified in 2018-19.

Note: CSI and ATSI identifications are normally made every three years. Schools identified at the start of an identification cycle form a cohort and remain part of that cohort until exit criteria are met.

Determinations regarding LEA compliance with IDEA are made annually at the district level. The categories are:

• Meets requirements and purposes of IDEA
• Needs assistance in implementing the requirements of IDEA
• Needs intervention in implementing the requirements of IDEA
• Needs substantial intervention in implementing the requirements of IDEA

LEAs meeting criteria for “Needs Assistance” for two years in a row, as well as those meeting criteria for “Needs Intervention” or “Needs Substantial Intervention, are required to complete certain actions to correct noncompliance with IDEA and exit the category.

In making LEA determinations, DPI uses a point-based system with a combination of compliance indicators and results indicators. Compliance indicators focus on the following:

• Racial disproportionality in special education identification and discipline
• Timely evaluation of students referred for special education
• Transition between birth-to-three programs and the LEA
• Post-high school transition planning for students with IEPs
• Correction of noncompliance with IDEA, and timely and accurate data

Results indicators focus on rates (percentages) for students with IEPs in the following areas:

• Graduation
• Drop-out
• Mathematics participation and proficiency
• English Language Arts participation and proficiency
• Education environment

For more details, visit the Determination of Compliance with IDEA Requirements web page. 

An examination of LEA data may reveal indicators of racial or ethnic disproportionality in identification, placement in particular educational settings, and/or discipline of students with disabilities. Districts meeting criteria for “Significant Disproportionality” in any of these categories are required to complete certain actions to exit the category. Criteria are below.

• Significant disproportionality in special education identification or one or more specific disability categories:
  • Minimum of 10 students within special education or a specific disability category or categories for a given race/ethnicity; minimum of 30 students (total enrollment) for given race/ethnicity,
  • Risk ratio of 2.0 or greater for this racial/ethnic group for the special education/specific disability category or categories (compared to all other students within the LEA),
  • Three consecutive years meeting above criteria, and
  • Failure to demonstrate reasonable progress in lowering the risk ratio for the group and category of analysis by 0.25 or more in each of the two prior consecutive years.
• Significant disproportionality in special education discipline and/or placement:
  • Minimum of 10 students within discipline category/environment code for a given race/ethnicity; minimum of 30 students with IEPs for given race/ethnicity,
  • Risk ratio of 2.0 or greater for this racial/ethnic group within the discipline category/environment code (compared to all other students with IEPs within the LEA/state),
  • Three consecutive years meeting above criteria, and
  • Failure to demonstrate reasonable progress in lowering the risk ratio for the group and category of analysis by 0.25 or more in each of the two prior consecutive years.
• Significant discrepancy in special education discipline:
  • In addition to the calculations for racial disproportionality in discipline detailed above, DPI is also required to determine if there is a significant discrepancy in the rate of suspensions and expulsions greater than 10 days among children of color with disabilities. This calculation uses a much smaller minimum cell size (two), and the criteria is a risk for each racial/ethnic group that is two standard deviations above the statewide mean.

Federal Identification Reports in SAFE

District joint federal notification packets, with ESSA and IDEA identification information, are housed in the SAFE (Secure Access File Exchange) system, which can be accessed via WISEhome. SAFE also provides districts with access to student outcome data and inquiry tools. For help accessing the system, visit the SAFE web page.

Joint federal notification packets contain the following reports:

• ESSA Accountability Report (school identifications) (preliminary in Dec, final in Mar) 
• LEA Determinations (IDEA) (preliminary in Dec, final in Mar) 
• District Summary—ESSA and IDEA (preliminary in Dec, final in Mar)
• Racial Equity in Special Education (IDEA Disproportionality) (final in Mar)  

Continuous Improvement Performance Report in WISEgrants

The Continuous Improvement Performance Report provides a data summary with both IDEA district-level and ESSA school-level identifications. The report includes all public schools within a district. This report is accessible to any WISEgrants user who has edit or view access to IDEA or ESEA grants. From the Reports menu, select “CIPR Data Report.”

Public Information

ESSA identification data and a partially redacted version of LEA determination data are made public in March/April. Disproportionality information is sensitive and is not made public.

• Public reports and the ESSA Identification Summary spreadsheet are available online via the ESSA Accountability Reports application.
• Information about ESSA identifications, including lists of identified schools, is available on the Federal Accountability webpage.

• LEAs with federal identifications can schedule a Microsoft Teams meeting with DPI staff through this Bookings link. Multiple staff with relevant expertise will attend, so you can have all your questions answered with one call.
• For questions about ESSA accountability calculations, contact DPI’s Office of Educational Accountability (OEA) at oeamail@dpi.wi.gov.
• For questions about ESSA school improvement and supports available to your district, contact your CESA’s Technical Assistance Network for Improvement representative or DPI Title I consultant.
• For questions about IDEA accountability calculations, school improvement, and supports for students with disabilities, contact the DPI Special Education LEA contact

Additional information about ESSA identifications, including identification timelines and explanations of reports and calculations, is available on the Federal Accountability webpage.

Though the specific requirements differ, essentially, schools and districts are asked to engage in a robust continuous improvement process to understand and address the issues that resulted in the identification. This may support and build on existing improvement efforts and does not have to involve creating an entirely new plan or process, depending on the unique situation.

Wisconsin’s continuous improvement framework conceptualizes improvement as a Plan-Do-Study-Act cycle, with an ongoing assessment of Readiness to ensure a foundation of systems and practices to support sustainability. Best practices for continuous improvement (many of which align with federal requirements) include the following:

• Assessment and shoring up of systems, such as data systems, necessary for supporting continuous improvement
• A deepening commitment to align activities and practices with values and beliefs around equity
• Authentic engagement and relationship building with families and communities
• Formation of a diverse, representative team of stakeholders to lead improvement efforts
• Collaboration with stakeholders to conduct a needs assessment and root cause analysis that
  • prioritizes the needs of students not benefiting from current practices, 
  • identifies the adult practices that are the root causes of undesired outcomes, and
  • includes an examination of resource allocation (financial, human, and other) to make sure resources are aligned with equity goals
• Collaboration with stakeholders to develop an improvement plan, including
  • selection of an evidence-based improvement strategy (program, practice, or strategy) that targets the greatest needs and is aligned to the identified root cause
  • creation of an action plan to implement it, usually on a limited scale at first
• Collaborative implementation of the plan, including
  • training and supports for all those involved and
  • regular monitoring and adjustment to ensure faithful implementation
• In collaboration with stakeholders, reflection on data (student outcome, adult practice) in larger ways to assess progress and determine the best direction for the next cycle, which may include scaling up successful practices

The Resources and Supports for Continuous Improvement page offers more tools and resources to help leverage identification data and federal requirements for continuous improvement.

Targeted Support and Improvement (TSI) Required Activities (summary)

• Stakeholder Involvement: ESSA requires stakeholder involvement in planning. At minimum, schools must engage teachers (including those for general and special education, and English learners), school administrators, other school staff, students (if age-appropriate), and families (including representatives of specific student groups present in the school).
• Improvement Planning: Each identified school must develop a targeted support and improvement plan and submit it to the LEA for approval. At minimum, the plan must:
  • Be informed by indicators defined in the ESSA State Plan (e.g., identification data contained in the ESSA Accountability Report) and address each student group for which the school has an identification and
  • Include one or more evidence-based improvement strategy that meet ESSA Tiers of Evidence 1, 2, or 3.
• Implementation: Each identified school must submit materials as requested to the LEA for monitoring purposes.
• Exit Criterion: A school automatically exits the category when it no longer meets the criteria for identification.
• Monitoring: Improvement planning and implementation for TSI schools is monitored by the LEA, and materials are submitted to the LEA. LEAs should create any needed processes and deadlines to ensure school improvement activities are aligned with ESSA requirements. LEA activities are monitored by the DPI through ESEA consolidated monitoring. 

Additional Targeted Support and Improvement (ATSI) Required Activities (summary)

• Stakeholder Involvement: ESSA requires stakeholder involvement in planning. At minimum, schools must engage teachers (including those for general and special education, and English learners), school administrators, other school staff, students (if age-appropriate), and families (including representatives of specific student groups present in the school).
• Improvement Planning: Each identified school must develop a targeted support and improvement plan and submit it to the LEA for approval. At minimum, the plan must:

  • Be informed by indicators defined in the ESSA State Plan (e.g., identification data contained in the ESSA Accountability Report) and address each student group for which the school has an identification,

  • Include one or more evidence-based improvement strategy that meet ESSA Tiers of Evidence 1, 2, or 3, and
  • Include identification of resource inequities (which may include a review of LEA-level and school-level budgeting) to be addressed through implementation of the improvement plan.
• Implementation: The school must implement the improvement plan. The LEA monitors implementation.
• Exit Criteria: Schools may exit the category after two years if they meet the three exit criteria below. Schools that do not exit after six years become identified for CSI. 

1. The school no longer meets the criteria for identification (for the identification year and the current year).
2. The school demonstrates sustained progress toward state long-term improvement goals, with the two most recent intervals (for which enough data is available) either both showing improvement or both exceeding identification-year scores.
3. The school demonstrates evidence that sustained and sustainable high-quality improvement planning and practices, targeting the identified subgroup(s), are in place. (The LEA determines whether or not the school has met this criterion.)

• Monitoring: Improvement planning and implementation for ATSI is monitored by the LEA, and materials are submitted to the LEA. LEAs should create any needed processes and deadlines to ensure school improvement activities are aligned with ESSA requirements. LEA activities are monitored by the DPI through ESEA consolidated monitoring. 

Comprehensive Support and Improvement (CSI) Required Activities (summary)

• Stakeholder Involvement: ESSA requires stakeholder involvement in planning. At minimum, schools must engage teachers (including those for general and special education, and English learners), school administrators, other school staff, students (if age-appropriate), and families (including representatives of specific student groups present in the school).
• Improvement Planning: Each identified school must develop a comprehensive support and improvement plan, which must be submitted to the DPI for approval via WISEgrants. At minimum, the plan must:
  • Be informed by indicators defined in the ESSA State Plan (e.g., identification data contained in the ESSA Accountability Report),
  • Include a school-level needs assessment,
  • Include one or more evidence-based improvement strategy that meet ESSA Tiers of Evidence 1, 2, or 3, and
  • Include identification of resource inequities (which may include a review of LEA-level and school-level budgeting) to be addressed through implementation of the improvement plan.
• Implementation: The school must implement the improvement plan. Implementation is monitored by the DPI.
• Exit Criteria: Schools may exit the category after two years if they meet the three exit criteria below. Schools that do not exit after four years are subject to more rigorous interventions. 

1. The school no longer meets the criteria for identification (for the identification year and the current year).
2. The school demonstrates sustained progress toward its long-term improvement goals, with the two most recent intervals (for which enough data is available) either both showing improvement or both exceeding identification-year scores.
3. The school demonstrates evidence of systems, structures and/or procedures that ensure sustained and sustainable high-quality improvement planning and practices are in place.

• Monitoring: Improvement planning and implementation for CSI is monitored by DPI, and materials are submitted to the DPI. DPI assigns a specific consultant to support each school identified for CSI.
• Funding: Funding is available each year of identification. More information is available on the CSI Grant Opportunities page.

Schools identified under ESSA must, at a minimum, engage the following groups in planning:

• Teachers, including those for general and special education, and English learners
• School administrators
• Other school staff
• Students (if age-appropriate)
• Families (must include representatives of specific student groups present in the school)

Additional groups may also need to be included depending on local context. Consider the following:

• Community health organizations
• Community-based organizations, including early childhood programs and providers and libraries
• Neighborhood representatives, including neighboring and local businesses
• Local and relevant environmental organizations
• Tribal Government representatives: Tribal Chairs or Presidents (or their designees), Tribal Council representatives, Tribal Education Directors and staff
• Government entities, including state agencies, counties, and municipalities
• Adjunct school services such as before and after school child care providers and community recreation centers
• Relevant institutions of higher education
• Workforce investment boards and other job-related agencies
• Faith-based communities

• LEAs that “need assistance” or "need intervention" may not reduce their maintenance of effort obligations, unless the reduction is by less than half of the increased amount (the “50% Adjustment” rule).
• LEAs that “need assistance” for two or more years are asked to engage in continuous improvement that includes a goal related to the data in the determination. 
• LEAs that "need intervention" are supported through continuous improvement per the direction of DPI.

Required Activities for LEAs with Determinations of Needs Assistance (two or more years), Needs Intervention, Needs Substantial Intervention (summary)

• Improvement Planning: The LEA must engage in improvement planning that meets requirements. The Data Inquiry Journal, a planning template, is available in WISEdash for districts. Other free and/or low-cost improvement planning options are available to districts.
• Minimum Requirements:
  • Identify areas in which the LEA needs assistance.
  • Identify and implement professional development, instructional strategies, and methods of instruction that are based on scientifically sound research.
  • Review and select, as appropriate, sources of technical assistance that address the areas in which the LEA needs assistance.
  • Plan for addressing the area for concern within a specified period of time.
  • Comply with special conditions on grant under IDEA Part B.
• Exit Criteria: No longer meeting criteria for identification

Required Activities for LEAs with Significant Disproportionality (summary)

• Improvement Planning: The LEA must submit an improvement plan that meets requirements to DPI annually. The Data Inquiry Journal, a planning template, is available in WISEdash for districts. Other templates are also acceptable, as long as they meet minimum requirements. Submit materials through WISEgrants.
• Minimum Requirements:
  • Identify factors contributing to the significant disproportionality.
  • Review and, if appropriate, revise policies, practices, and procedures used in identification or placement in particular education settings, including disciplinary removals, to ensure that the policies, practices, and procedures comply with the requirements of IDEA, Part B.
    • Newly identified districts and districts receiving a new area of identification may need to complete a Special Education Disproportionality - Procedural Compliance Self-Assessment (PCSA). Information about the process is available on the Special Education Disproportionality – Procedural Compliance Self-Assessment page.
  • Implement comprehensive coordinated early intervening services (CCEIS) and carry out activities that include professional development and educational and behavioral evaluations, services, and supports.
    • Districts identified with significant disproportionality are required to budget and spend 15% of their IDEA funds on comprehensive coordinated early intervening services (CCEIS) 34 CFR § 300.646 (b)(2) and § 300.226. (Note: this is different from the ordinary CEIS set-aside, which is optional.)
    • CCEIS budgets must address root cause factors identified through continuous improvement planning.
    • Districts must flag students in district-level student information system as part of the CCEIS requirement.
    • CCEIS WISEgrants Guidance
  • Address the factors contributing to the significant disproportionality. Address any policy, practice, or procedure identified as contributing to the significant disproportionality, including a policy, practice or procedure that results in inappropriate identification of a racial or ethnic group.
• Exit Criteria: No longer meeting criteria for identification