Letter to State Board of Education on Accountability Frameworks

Dear Mr. Chairman and Members of the State Board of Education:

As a coalition of 22 organizations working with and on behalf of Colorado students and their families, we would like to comment on the Colorado Department of Education’s recent release of mock district accountability reports for the 2016-17 school year. Specifically, we are concerned about the replacement of disaggregated subgroups in school and district accountability systems with a “combined subgroup” (often called a “super subgroup”) that aggregates the performance results of English learners, students of color, students with disabilities, and students eligible for free/reduced price lunch – subgroups that are currently accounted for separately in the frameworks.

While we appreciate CDE’s proposal to disaggregate student subgroup data in achievement (not just growth, as was the case in previous frameworks), as well as the Department’s commitment to ensuring transparency of subgroup performance data in reporting, we strongly encourage CDE to reconsider the adoption of a combined subgroup for accountability purposes, which would have significant implications for educational equity. Below, we detail our significant concerns with this policy change.