STATE OF CALIFORNIA

EDMUND G. BROWN JR., Governor

CALIFORNIA STATE BOARD OF EDUCATION
1430 N Street, Suite 5111
Sacramento, CA 95814
Phone: (916) 319-0827
Fax:
(916) 319-0175

May 26, 2017

CORE Districts
1107 9th St., Suite 500
Sacramento, CA 95814
Dear CORE Superintendents:
California is leading the nation in its redesign of public education. Since 2010, our state has
changed how and what public school students learn, how they are assessed, how schools
are funded and how school districts are measured and held accountable for improving
performance outcomes. This is groundbreaking work that would not be possible without the
support and collaboration of the state’s many valued partners, including the CORE districts.
While the State Board of Education appreciates CORE’s support and willingness to pilot new
ideas, we have concerns about CORE’s request that California seek an Every Student
Succeeds Act (ESSA) waiver to allow creation of an “Innovation Zone.” As we understand it,
districts volunteering to participate in this Zone would be evaluated by both the state’s
multiple-measures system – the California School Dashboard -- and CORE’s performance
metrics. The state has no issue with CORE’s system – many districts in the state have
developed Dashboards that include locally identified measures.
What remains of concern is the proposed use of CORE’s system to identify the 5 percent of
lowest performing schools within a district, as required by ESSA. A CORE/PACE analysis
included in CORE’s May 5 correspondence concluded that CORE’s system would likely
identify different schools than the state’s system and as a result “have huge implications
when used to identify schools for support and improvement.”
We are therefore concerned about the equity questions that would likely arise from the
creation of two accountability systems that would identify different schools for state support
and resources. Specifically, we are concerned about creating a system that could result in
students identified by the state as in need of support failing to receive that support. In the
course of our conversations with CORE staff over the past year and in your written
correspondence, we have heard no explanation of what your districts intend to do to meet the
needs of the students at such schools, in lieu of the additional support they would otherwise
have received.

 CORE Superintendents
May 26, 2017
Page 2

In addition, California is in the midst of engaging the public and partners in thinking through
what an ESSA state plan might look like and how it would fit into California’s accountability
system already underway. (The ESSA state plan public comment period opened May 22). At
the State Board’s May 10 meeting, which CORE representatives attended, SBE members
expressed a commitment to further developing the state’s plan for providing targeted
assistance to districts (rather than schools) based on the performance of student groups. In
light of the board’s May 10 discussion, CORE’s request seems premature. To the extent
California ultimately pursues an approach focused on districts, a waiver may be unnecessary
or be different from CORE’s current proposal.
Additionally, we have further questions about whether the proposed waiver will provide
meaningful and reliable information to inform state-level policy decisions:
First, as we understand it, the primary argument for the waiver request is that CORE’s use of
additional local measures for school identification will help the state learn whether those
measures should be incorporated statewide. As CORE staff have acknowledged in meetings
with SBE staff, CORE is not sure that it has picked the right measures.
Yet, based on CORE’s proposal, it is unclear how the state can draw definitive conclusions
about whether the use of CORE’s measures for school accountability are responsible for any
differences in outcomes. The schools using these measures will be located in districts that
chose to join the innovation zone pilot, and schools that are not using these measures will be
located in districts that have chosen not to participate in the pilot. The characteristics of the
districts themselves, including the selection bias inherent in an opt-in design, are a significant
confounding variable. The proposal does not explain how the proposed waiver will help the
state determine whether CORE’s indicators should be considered for incorporation statewide.
Second, the proposed waiver applies to ESSA’s school identification provision, which do not
take effect until the 2018-19 school year. It is unclear why allowing CORE to use some of the
proposed indicators for school identification will be helpful to the SBE’s ongoing work, in light
of this timeline and the specific characteristics of those indicators. For example, the SBE
already plans to incorporate a measure of individual student growth – one of the CORE
measures – into the Academic Indicator for the 2018-19 Dashboard release.
Similarly, CORE is able to compare school performance as measured by socio-emotional
learning and school climate surveys because its members have voluntarily chosen to
administer a common survey that addresses socio-emotional learning and a common set of
school climate surveys. The former is not a required metric under LCFF, and there is no
requirement for LEAs to use a common school climate survey statewide. It is unclear how
local measures based on the voluntary use of common survey instruments have a viable path
to being implemented as comparable indicators statewide.

 CORE Superintendents
May 26, 2017
Page 3

Third, CORE has not identified which of its member school districts would participate under
such a waiver. It is impossible to evaluate the request without some understanding of the
scope of its impact. Prior materials have noted that CORE’s members serve 1 million children
and that districts serving up to 1 million more students might opt in, which represents nearly
one-third of the state’s public school students.
In closing, we hope we have identified the outstanding questions and concerns with your
proposal and explained further why it is premature to incorporate any proposed waiver into
the draft ESSA state plan at this time. However, we will continue to review and study the idea
or others you may bring forward.
Sincerely,

Karen Stapf Walters
Executive Director, State Board of Education

cc:

Rick Miller, Executive Director, CORE Districts
Glen Price, Chief Deputy Superintendent, California Department of Education
Keric Ashley, Deputy Superintendent, California Department of Education