sedseal1                                                                                                 

 

John sig6THE STATE EDUCATION DEPARTMENT / THE UNIVERSITY OF THE STATE OF NEW YORK / ALBANY, NY 12234

TO:

EMSC Committee

FROM:

John B. King, Jr.

SUBJECT:

Policy Issues Concerning Graduation Rates – Part V: 

Establishing a Graduation Rate Goal and Annual Targets for Accountability

DATE:

December 9, 2009

STRATEGIC GOAL:

Goals 1 and 2

AUTHORIZATION(S):

 

 

SUMMARY

 

Issue for Decision

What graduation rate goal and annual targets for the 2009-10 and 2010-11 school years do the Regents want to establish for New York State and submit to the United States Department of Education (USED) for approval?

Procedural History

              In October 29, 2008, the United States Department of Education (USED) issued regulations that require each state to report graduation rates using a common “four year adjusted graduation rate” beginning with assessment results for the 2010-11 school year and to use this rate for accountability purposes beginning with 2011-12 school year results.  The regulations also require that states submit to USED for peer review the State’s proposed annual goal and targets beginning with 2009-2010 school year results.

              At their June 2009 meeting, the Regents began a series of discussions regarding policies related to graduation that included discussion of the graduation rate goal and targets that the Regents should establish to meet this Federal requirement. These policy discussions continued at the Regents meeting in July, September, October, and November.  At the Regents meeting in October, the Regents decided that New York would adopt the four year adjusted graduation rate for accountability purposes beginning with 2011-2012 school year results and would continue to use New York’s current graduation rate definition as New York's transitional graduation rate for 2009-10 and 2010-2011 accountability determinations. In October, the Regents also decided to apply to USED to use a five year extended graduation rate in conjunction with implementation of the four year adjusted graduation rate beginning with 2011-12 school year assessment results.

Policy Questions

1.           What is the percentage of students in an accountability group that schools and districts must graduate from high school or be at risk of not making adequate yearly progress (AYP)?

2.           If the “all students” group is below the specified graduation goal, how much annual progress must the group make in order to still make AYP for 2009-10 and 2010-11 school year results?

3.           Should there be a minimum graduation rate (floor) for the “all students” group below which a school or district should not make AYP in 2009-10 and 2010-11 even if the school or district is achieving the annual performance target with that group?

4.           Do the Regents want to establish an aspirational graduation rate goal and a separate graduation rate goal for accountability purposes?

 

Policy Recommendations

The Board of Regents should:

1.           Set for NCLB accountability purposes a graduation goal that 80% of an accountability group graduate from high school within the specified number of years.

2.           Establish a progress target for the 2009-10 and 2010-2011 school years that schools and district below the graduation rate goal achieve a 20% gap reduction for the "all students" group.

 3.          Not establish a minimum graduation rate (floor) for accountability purposes until New York begins with 2011-12 school year results to use a five year extended year graduation rate.

4.           Set an aspirational graduate goal that 95% of each school's and district's "all students group" graduate within five years and publicize on school and district report cards whether this goal has been achieved.

Staff predict that if these recommendations are adopted, the percentage of schools not making AYP will more than double from six to about 15% percent in the 2009-10 and 2010-11 school years.  The Regents are not required to establish targets for the 2011-12 school years and beyond at this time, and staff recommend that they not do so. However, were this goal and these targets to remain in place when New York must begin to hold schools and districts accountable for the graduation rates of disaggregated groups beginning with the 2011-12 school year, we predict that approximately one quarter of New York's schools might not make AYP.

The attached reported provides additional background information, policy considerations, and further detail on staff recommendations and the rationale for each recommendation.

With the concurrence of the Board of Regents, staff will prepare a submission to USED based on these policy recommendations.


Establishment of Graduation Rate Goal and Targets for the 2009-10 and 2010-11 School Years

Background Information

In September 2009, USED informed state education agencies that by January 15, 2009, states are required to submit information to USED for peer review concerning the graduation rate goal and annual targets that the state proposes to use to determine adequate yearly progress (AYP). 

USED has indicted that states must provide the following information:

 

 

Accountability determinations about schools and districts are based upon whether or not the school or district has met the graduation rate goal established by the state, or, alternatively, whether or not the school or district has met the established annual graduation rate target.  The annual target establishes the degree of continuous and substantial improvement the student accountability groups that have not yet reached the graduation rate goal must make each year toward the goal.  If the school or district has not met either the graduation rate goal or the annual target, the school or district has not made Adequate Yearly Progress (AYP) and if this occurs for two consecutive years, the school or district is identified as in need of improvement. 

              The federal regulations also require that the new state graduation rate goal and targets beginning with 2011-12 school year results apply to all NCLB disaggregated student groups and accountability determinations be based upon whether or not the school or district has made AYP for each of those student groups as well as for the aggregate “all students” group.  The accountability groups are: All students, Asian, Black, Hispanic, Native American, White, English language learners, Low-Income and Students with Disabilities.

                            In New York State, for purposes of school and district accountability, the definition of a   high school graduate includes students who complete high school with a local diploma, Regents diploma or Regents diploma with Advanced Designation.  Students who receive a General Equivalency Diploma (GED) or an individualized education program (IEP) diploma are not considered graduates for this purpose. Passage of Regents Competency Tests (RCTs) to meet the requirements for a local diploma was completely phased-out for general education students after the 1998 cohort.  In order to receive a local diploma, students in the 1999 - 2004 cohorts (students who entered 9th grade in September 1999, 2000, 2001, 2002, 2003 or 2004)  had to earn at least 22 units of credit and had to pass five required Regents exams with scores of 55 or higher.    

              In 2005, the Regents enacted regulations that would phase-out the local diploma for general education students.  The phase-out will be complete with the 2008 cohort (students who entered 9th grade in 2008).  This means that general education students in the 2008 cohort will be required to pass all required Regents exams with scores of at least 65.   

              The phase-out of the local diploma works as follows:

 

 

 

 

 

               The Individuals with Disabilities Education Act (IDEA) requires states to set measurable and rigorous targets for improvement in the percentage of students with disabilities graduating with a regular diploma.  In March 2009, the Federal Office of Special Education Programs (OSEP) issued its requirements for the IDEA State Performance Plan stating that each state’s targets for improvement must be the same as the annual NCLB graduation targets.      This requirement has significant implications for the decisions the Regents will make on the State’s annual graduation targets for all students.  The graduation rate annual targets for students with disabilities must be rigorous, yet achievable.  Department staff are seeking clarification from USED regarding the use of the local diploma for determining AYP once the local diploma is a degree that will be granted only to students with disabilities.

Policy Considerations

              New York State’s current four-year graduation rate goal for accountability purposes is 55% and the annual graduation rate target is a 1% increase for schools and districts below the goal.  Schools and districts that do not meet the goal or target for two consecutive years have not made Adequate Yearly Progress (AYP) and are identified as in need of improvement.

              New York State’s current four year graduation rate is 71% and the five year rate is 74%, which is substantially better than the accountability goal of 55%.  This means that at present, as long as a school or district has met the goal or target for the “all students” group they have made AYP even if the disaggregated groups have not met the goal or target.   At present, 94% of schools (976 schools) and 98.5% of districts (659 districts) are making AYP based on the aggregate graduation rate or target.  Sixty-five schools and four districts are not making AYP based on the graduation rate indicator.   

              Most schools in New York State make AYP on the graduation rate indicator because their graduation rate for the “all students” group exceeds the current New York goal of 55 percent.  Relatively few schools depend upon making AYP by demonstrating an annual improvement in their graduation rate because AYP decisions are now made based on a school or district’s aggregate graduation rate, not on the graduation rate for student groups (i.e., students with disabilities, English language learners, etc.).   When New York begins disaggregating the data for graduation rate accountability beginning with 2011-12 school year results, more schools and districts will likely not meet the graduation rate goal for one or more disaggregated groups and will have to demonstrate that they have met the annual targets in order to make AYP. 

              In judging the targets established by states, USED has indicated that it will consider how long it would take a school or district to achieve the state graduation rate goal if the school or district were to make the minimum required gain each year.  For example, if a school had a graduation rate of 50% for a group and the state had a graduation rate goal of 80% and a minimum improvement target of 1% per year, it would take this school 30 years to achieve the goal if it made the minimum required gain each year.  USED is not likely to approve such a target.  However, the more rigorous the graduation rate targets established the greater number of schools and districts that will not make AYP and therefore be identified for improvement.

             

              Department staff had originally intended to recommend that the Regents adopt not only a graduation goal and annual targets for use with the transitional graduation rate to be used for 2009-10 and 2010-11assesment results but also annual targets to use beginning with the 2011-2012 school year assessment results when New York will adopt the Federal four-year adjusted cohort graduation rate, a five year extended graduation rate, and use the graduation of disaggregated groups to make accountability determinations.  The intent of recommending that the Regents establish these targets now was to give the field significant advance notice of the graduation standards that would be applied to districts and schools. However, staff are now recommending that the Regents at this time only establish annual targets for 2009-10 and 2010-11 school year assessment results because:

 

 

Policy Recommendations

1.           What is the percentage of students in an accountability group that schools and districts must graduate from high school or be at risk of not making adequate yearly progress (AYP)?

Recommendation:  Department staff recommend that the Regents establish a goal that 80 percent of students in an accountability group graduate from high school.  For 2009-10 and 2010-11 school year assessment results this goal would be applied to the four year transitional graduation rate cohort for the "all students" group only.  Beginning with 2011-12 school year assessment results, this goal would be applied to both the four year adjusted graduation rate and five year extended graduation rate for all accountability groups (i.e. the "all students" groups, major racial/ethnic groups, English language learners, low-income students. and students with disabilities).

Rationale: 

The purpose of establishing a graduation rate goal is to determine which schools and districts must show improvement with an accountable group or risk not making AYP and becoming identified for improvement. Continued failure of a school or district to make AYP leads to a series of increasingly intensive interventions that could ultimately lead to a school being required to close or transform. Thus a graduation rate goal that is too low fails to demand that schools and districts show improvement in addressing unacceptable graduation rates among particular groups of students while a graduation rate that is set unnecessarily high will result in SED and districts having to divert resources from higher priority schools to lower priority ones. In addition, overly ambitious goals place schools at risk of having to undertake interventions that may at best effect positive change for only a small percentage of students and at worst are disruptive to educational programs that are generally successful with most students.

The USED in its recently released Race to the Top and School Improvement Grants applications called upon states to identify as persistently lowest achieving any secondary school in the state that has a graduation rate for the "all students" group below 60 percent for a number of years. Thus 60 percent appears to serve as a minimum floor for what the graduation rate of a school should be. An 80 percent graduation rate represents the midpoint between a graduation rate of 100 percent and this sixty percent floor.  An 80 percent graduation rate goal would also be a challenging standard for many schools and districts  Department staff estimate that based on preliminary 2005 four year graduation rate cohort results, only 58% of schools would meet this standard.  The remaining 42% of schools would be required to demonstrate annual progress or would not make AYP.

Statewide only the White student group on the 2004 graduation cohort had an annual graduation exceeding 80 percent and only the White and Asian students groups exceeded 80% on the 2003 five year graduation rate cohort.  By contrast, other groups had a five year graduation rate for the 2003 cohort that ranged from a low of 40 percent for English language learners to a high of 62 percent for Native Americans. In addition, because of the phase out of the local diploma, students who graduate in future years will face more challenging standards, and the change from the transitional cohort to the federal four adjusted rate cohort will require additional students to have to be counted as non-graduates at the school and district level. When all of these factors are taken into account, we estimate that beginning with 2011-12 assessment results more than half of the schools in the state would need to show progress with one or more accountable groups on the four year adjusted graduation or the five extended year graduation rate in order to make AYP.  By contrast, we estimate establishing a standard of 70% would reduce to approximately 40% the number of schools that would need to demonstrate progress with one or more groups while establishing a standard of 90% would require more than 75% of schools to show progress. 

We conclude that an 80% graduation rate goal for accountability purposes strikes the correct balance between rigor and realism.  Initially, this goal will focus attention on those schools with low "all students" graduation rates and over time require the majority of New York's high schools and districts to demonstrate progress with their groups that demonstrate the lowest graduation rates.

2.           If the “all students” group is below the specified graduation goal, how much annual progress must the group make in order to still AYP for 2009-10  and 2010-11 school year results?

Recommendation:

Staff recommend that schools and districts be required to close the gap between the current cohort's graduation rate and the prior year cohort's graduation rate by 20%.  If, for example, a school's 2004 four graduation rate was 50%, then the school would be required to have a graduation rate of 56% for the 2005 cohort in order to make AYP.  In this case the gap would be 30% (80% - 50% = 30%) and the required gain would be 6% (30% X 20% = 6%).  We also recommend that all gap reduction targets be rounded up to the nearest whole number so as to ensure that any progress target require a gain of at least 1%.

Rationale:

A 20% gap reduction is difficult to obtain but possible to achieve for schools and districts. The majority of schools that had graduation rates of less than 80% on the 2004 graduation rate cohort and improved their graduation rate on the 2005 cohort were able to make a 20% gap reduction. Similarly, modeling by SED staff showed that more than 75% of schools that needed to show a gain for one or more accountability groups on either the 2003 five year extended rate cohort or the 2004 four year adjusted rate would have been able to make a 20% gap reduction on one or both of these cohorts for all such groups and would therefore have made AYP.

Staff recommend the use of a gap reduction methodology as opposed to setting a fixed progress target that all schools must achieve (i.e. all schools must show an increase of 2 percent) because the gap reduction methodology requires schools that are farthest from the goal to show a greater absolute gain while requiring all schools to close the gap by an equal amount. For example, if the goal is 80% and a 20% gap reduction is used, a school starting at 40% would be required to show an 8% increase while a school at 70% would be required to show a 2% increase. In both cases, however, schools are being required to demonstrate the same 20% gap reduction.

3. Should there be a minimum graduation rate (floor) for the “all students” group below which a school or district should not make AYP in 2009-10 and 2010-11 even if the school or district is achieving the annual performance target with that group?

Recommendation: 

The Regents should not begin to set a minimum graduation rate until schools and districts become accountable for the performance of disaggregated groups beginning with 2011-2012 school year results.

Rationale:

While staff believe that all schools and districts should be accountable for students achieving certain minimum graduation rate levels for all groups of students, staff does not feel it is appropriate for a minimum floor to be established while New York is using the transitional graduation rate for 2009-10 and 2010-11 school year assessment results. First, because New York lags its graduation rates for accountability purposes by one year, New York will be using for the 2009-2010 school year the performance of the 2005 graduation cohort through August 2009.  This means that schools and districts are in essence faced with a retroactive change in graduation rate standards.  While New York must establish its goal and targets retroactively in order to meet USED requirements, New York is not required to impose a minimum floor retroactively upon schools and districts. In addition, a minimum floor would likely have the most adverse effect upon schools that serve high risk populations such as transfer alternative high schools and special act school district schools. Staff believe it would be more appropriate to establish a minimum graduation rate floor once New York begins with 2011-12 school year assessment results to use a five year extended year graduation rate, which provides a fairer measure for schools that serve at-risk populations.

 4.          Do the Regents want to establish an aspirational graduation rate goal and a separate graduation rate goal for accountability purposes?

Recommendation:

Staff recommend that the Regents set an aspirational goal that 95% of the "all students" group in schools and districts graduate within five years of first entry into grade nine and indicate on school and district report cards whether this aspirational goal has been achieved.

Rationale:

The Board of Regents is committed to having the vast majority of high school students in New York graduate from high school prepared for post-secondary education and the world of work.  While an 80% graduation goal is appropriate when applied to disaggregated groups and as a cut-point for determining which schools and districts may need intervention if progress is not made, all schools and districts should be striving for a higher graduation rate. However, we believe a 100% aspirational goal is unrealistic as we recognize that a small percentage of students have such severe disabilities or life circumstances that prevent them even with appropriate instruction from being able to graduate within five years of first entry into grade nine  Staff therefore recommend that the Regents set an aspirational goal of 95% graduation of the "all students" group within five years of a student's first entry into grade nine and indicate on school and district report cards whether this goal has been achieved.

Under the phase-out of the local diploma enacted by the Regents in 2005, students with disabilities continue to have the option of receiving a local diploma if they pass one or more of the required Regents examinations with a score of 55 or higher.