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 Title I receiving schools in the state and/or they have a graduation rate below 67%. Identifications for CSI are made every three years, starting 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 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 Title I receiving schools in the state. Identifications for ATSI are made every three years, starting in 2018-19.

Note: CSI and ATSI identifications are made every three years. The group of schools identified at the beginning of a three-year cycle form a cohort based on the year. A school will be grouped with that cohort year 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.

• 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 Secure Home. This system also provides districts with access to student outcome data and inquiry tools. For help accessing the system, visit the SAFE web page.
• Disproportionality reports, which are released in the final joint federal notification packet but not the preliminary one, are in the same location in SAFE. Go to “Joint Federal Notification Package ESSA/IDEA,” select the correct school year in the dropdown menu, and access the “Racial Equity in Special Education” report under “District Summaries.” A sample report is available here: IDEA 2019 Racial Equity in Special Education
• 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 reports and the ESSA Identification Summary spreadsheet are available online via the ESSA Accountability Reports application.

More information about identifications is available on the Federal Accountability (ESSA) web page. The following documents provide more information about identifications:

• ESSA-IDEA Federal Accountability Key Points
• ESSA Accountability Overview handout
• Accountability Crosswalk (federal identifications versus state report cards)

If you have further questions about identifications—for example, how they are made or how to understand your district’s data—the following contacts can help you find answers:

• For questions about ESSA accountability calculations, contact the DPI’s Office of Educational Accountability (OEA) at oeamail@dpi.wi.gov.
• A list of accountability trainers by CESA and District are available on the Accountability Resources page. These trained staff support schools and districts.
• 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.

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
  • focuses on the effects of adult practices on student outcomes and
  • prioritizes the needs of students not benefiting from current practices
  • 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
  • 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) to assess progress and determine the best direction for the next cycle, which may include scaling up successful practices

The resource section of this page contains key documents and tools to help leverage identification data and federal requirements for continuous improvement.

Note: LEAs with ESSA-identified schools must respond to additional LEA Plan Questions within WISEgrants. The questions and rubric for key points to address in the response are found in the LEA Plan Roadmap.

To support required activities, CSI Planning Grants are available in the first year, and CSI Implementation Grants are available annually thereafter. These are formula-based grants. Implementation grant budgets must reflect implementation of the evidence-based improvement strategy from the school improvement plan. More information is available on the Grant Opportunities page.

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

• Improvement Planning: For each identified school, the LEA must ensure that a comprehensive school improvement plan that meets requirements is submitted annually to DPI through WISEgrants. LEAs may give WISEgrants access to CSI-identified schools so they can upload their own materials.

  There is an extended planning period before any initial plan is due. An approved plan may be resubmitted in subsequent years as appropriate, accompanied by relevant information about progress and adjustments.

  Schools are required to develop a comprehensive improvement plan that modifies practices, policies, and/or professional development. At minimum, the plan must:

  • Include a school-level needs assessment,
  • Identify an evidence-based improvement strategy (defined as a practice, program, or strategy) that meets appropriate evidence requirements and addresses identified needs, 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.

ESSA requires stakeholder involvement in planning. Information about representative improvement teams and ESSA stakeholder requirements are outlined in DPI’s Continuous Improvement Process Criteria and Rubric, available in the resource section of this page.

Note: Using the Data Inquiry Journal, available in WISEdash for districts, and the Resource Inequity Tool, available in SAFE, typically satisfies the minimum planning requirements above, provided the chosen evidence-based improvement strategy also meets requirements.

• Implementation: For each identified school, the LEA must ensure that evidence of implementation of the approved school improvement plan is submitted annually to DPI.
• Exit Criteria: Schools may exit the category after two years and must exit no more than four years after identification; more rigorous interventions apply after four years. Schools meet exit requirements when they:
  • No longer meet the criteria for identification,
  • Demonstrate sustained progress toward their long-term improvement goals, and
  • Demonstrate evidence of systems, structures and/or procedures that ensure sustained and sustainable high-quality improvement planning and practices are in place.

Note: LEAs with ESSA-identified schools must respond to additional LEA Plan Questions within WISEgrants. The questions and rubric for key points to address in the response are found in the LEA Plan Roadmap.

Improvement planning and implementation for TSI schools is monitored by the LEA. Evidence demonstrating completion of required actions is monitored by DPI through ESEA consolidated monitoring.

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

• Improvement Planning: Each identified school must submit a school improvement plan that meets requirements to the LEA.
   
  Schools are required to develop a school-level targeted support and improvement plan for each student subgroup whose data triggered a TSI identification. The plan may include modification in practices, policies and/or professional development focused on improving student learning. It may include a school-level needs assessment, but this is not required. At minimum, the plan must:
  • Identify an evidence-based strategy (defined as a practice, program, or strategy) 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.

ESSA requires stakeholder involvement in planning. Information about representative improvement teams and ESSA stakeholder requirements are outlined in DPI’s Continuous Improvement Process Criteria and Rubric, available in the resource section of this page.

• Implementation: Each identified school must submit materials as requested to the LEA for monitoring purposes.
• Exit Criteria: A school automatically exits the category when it no longer meets the criteria for identification.

Note: LEAs with ESSA-identified schools must respond to additional LEA Plan Questions within WISEgrants. The questions, as well as a rubric with key points to address when responding to them, are found in the LEA Plan Roadmap.

Improvement planning and implementation for TSI schools is monitored by the LEA. Evidence collected by the LEA to demonstrate completion of required actions is monitored by DPI through ESEA consolidated monitoring.

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

• Improvement Planning: Each identified school must submit a school improvement plan that meets requirements to the LEA.

  Schools are required to develop a targeted support and improvement plan for each student subgroup whose data triggered an ATSI identification. The plan may include modification in practices, policies and/or professional development focused on improving student learning. It may include a school-level needs assessment, but this is not required. At minimum, the plan must:

  • Identify an evidence-based improvement strategy (defined as a practice, program, or strategy) 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.

ESSA requires stakeholder involvement in planning. Information about representative improvement teams and ESSA stakeholder requirements are outlined in DPI’s Continuous Improvement Process Criteria and Rubric, available in the resource section of this page.

• Implementation: Each identified school must submit materials as requested to the LEA for monitoring purposes.
• Exit Criteria: Schools may exit the category after two years and must exit no more than four years after identification; more rigorous interventions apply after four years. Schools meet exit requirements when they:
  • No longer meet the criteria for identification,
  • Demonstrate sustained progress toward their long-term improvement goals, and
  • Demonstrate evidence of systems, structures and/or procedures that ensure sustained and sustainable high-quality improvement planning and practices are in place.

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 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 areas in which the LEA needs assistance.
  • Identify and implement professional development, instructional strategies, and methods of instruction that are based on scientifically based 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.
    • More information is in this CCEIS memo from the DPI Special Education team (7-30-19).
  • 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

ESSA—CSI: Monitored by DPI, materials submitted to DPI.

ESSA—TSI, ATSI: Monitored by the LEA, materials submitted to the LEA. DPI periodically reviews documentation. Since the identification data does not go directly to the schools, it is important for the LEA to pass along the relevant identifications and data.

IDEA—LEA Determinations and Disproportionality: Monitored by DPI, materials submitted to DPI.