The nation’s new education law could offer a pivotal moment for students of color in Tennessee. But just how pivotal depends on the U.S. Department of Education’s guidance — and Tennessee’s state plan — in implementing the law.

The Tennessee Education Equity Coalition sent recommendations Thursday to top state and federal officials about education equity questions related to the Every Student Succeeds Act, or ESSA. The group, comprised of policymakers, educators, advocates and students, sent their recommendations to U.S. Secretary of Education John King, U.S. Sen. Lamar Alexander, and Tennessee Education Commissioner Candice McQueen.

The coalition consistently emphasized accountability — that districts shouldn’t be left to their own devices in deciding how to serve historically disadvantaged kids. Data is key, the group says.

“When districts and schools are not able to demonstrate an ability to advance achievement for all students — and particularly students of color who are also disproportionately economically disadvantaged — states and districts like ours must have strong regulatory guidance to intervene in ways that prioritize the needs of students over the comfort of adults,” the coalition said in its letters.

The recommendations are an outgrowth of feedback that King received from coalition members last month when he visited Nashville. The coalition also is helping the Tennessee Department of Education draft its new accountability plan in accordance with the federal law.

ESSA goes into effect this month and will be fully implemented in the 2017-18 school year. The new law, which replaces No Child Left Behind, narrows the federal government’s role — and elevates the role of states — in developing public education policy.

Here’s what coalition members say needs to happen for ESSA to work for kids of color:

On Accountability

What’s good:

  • The coalition commends that ESSA continues the federal requirement that schools administer standardized tests to at least 95 percent of students. “All students count, and all students must be counted,” the letter to King reads.

What still needs to be done:

  • If schools have below a set number of students in a subgroup, called the “N-size,” they don’t have to count those students for accountability purposes. The coalition says the ideal N-size of a subgroup should be 20 or smaller. “We know when you have a large ‘N- size’ an entire class size could not be counted,” explains Gini Pupo-Walker, the senior director of education policy for Conexión Américas and a founding coalition member. “And when students are not counted, we know from history, there is not the same urgency. It’s almost as though they don’t exist.”
  • Schools must receive district or state intervention if any subgroup of students is underperforming according to state goals for two consecutive years. “Otherwise students can languish for years in a school that is not serving them well,” says the group’s letter.

On Supporting English Learner Students

What’s good:

  • ESSA requires schools for the first time to report how English learners are faring on English proficiency exams. Also for the first time, English language learners are under the larger Title I umbrella, meaning all schools with high numbers of low-income students will have to think of specific plans to address English language learners’ needs — and have more federal funds to do so.

What still needs to be done:

  • The coalition says that states must set ambitious, long-term goals for English language proficiency. “If I am a teacher or a principal and I can see (an English language learner) has not reached proficiency in five, six, seven years, that should be a huge flag. It’s on everybody to make sure that child is moving forward,” Pupo-Walker said.
  • All Tennessee districts should have the same standards for determining when students require English language services, and when students are ready to exit programs.
  • States shouldn’t be able to group the test scores of students who exited English learner classrooms after becoming proficient with the scores of students still learning English, camouflaging the likely lower scores of the latter group.

On effective teachers

What’s good:

  • Tennessee already has made equity a state priority related to access to high-quality teachers.

What still needs to be done:

  • Both the Tennessee and federal governments need to ramp up focus on recruiting and retaining diverse teachers, by helping low-income students pay for teacher preparation. Tennessee must provide incentives to teacher preparation programs and districts to build supports for teachers of color, ranging from mentorship to financial incentives.

On access to resources

What’s good:

  • ESSA includes regulations that require districts to examine if academically struggling schools receive equitable resources. Districts must identify and evaluate gaps in resources between struggling and non-struggling schools.

What still needs to be done:

  • States must hone in on inequities, not only between schools but also within schools.