Monday, May 14, 2012

Development and Implementation of Title III Accountability

Complete Report

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Title III, Section 3122(a), requires states to establish accountability systems to monitor state and district performance in supporting ELs’ English language proficiency development and mastery of challenging academic content. Under these accountability systems, states must set three performance objectives known as Annual Measurable Achievement Objectives (AMAOs), and then hold Title III–funded districts accountable for meeting those performance objectives every year. Title III districts that do not meet their AMAOs for two or four consecutive years are subject to state actions and support. The three AMAOs are defined as follows:

1. Annual increases in the number or percentage of students making progress in learning English (AMAO 1)

2. Annual increases in the number or percentage of students attaining English proficiency (AMAO 2)

3. Making AYP for limited English proficient children as described in Title I, Section 1111(b)(2)(B), of ESEA (AMAO 3)

As of 2009–10, nearly all states (48 and the District of Columbia) had revised their AMAOs since putting them into place, and most states (26) had instituted new AMAOs within the last two years.

In the early years of Title III implementation, states had limited data, guidance, and infrastructure to inform the development of their AMAOs. As a result, in the years following states’ initial implementation of AMAOs, these Title III objectives were refined and revised as states made improvements to their ELP assessment system, acquired additional years of ELP test data, and gained access to new guidance and research. As of 2009–10, officials in nearly all states (48 and the District of Columbia) reported that they had revised their AMAOs at least once, and officials in 17 of those states indicated that they had revised their AMAOs multiple times. The nature of these revisions varied, ranging from small adjustments in AMAO targets to a complete overhaul in how the state defined and calculated its AMAOs. An important implication of such widespread revisions is that states’ criteria for meeting AMAOs may differ from one year to the next; thus, it would be inappropriate to compare those AMAO performance results across years.

Due to variation in how states defined and measured their AMAOs, AMAOs in one state were not comparable to AMAOs in another state.

While all states and the District of Columbia base AMAO 1 and 2 determinations on students’ ELP assessment results,10 states’ numeric targets and definitions of “progress” and “proficiency” for these AMAOs have varied across states since Title III was enacted. One source of this variation stems from differences in states’ ELP assessments; yet, even states that shared a common ELP test employed different approaches for making AMAO determinations (Boyle et al. 2010).

In addition, several studies have documented differences in how states determine adequate yearly progress (AYP) under Title I, which serves as the basis for AMAO 3 (e.g., Taylor et al. 2010). As a result, differences in how states have defined their three AMAOs precludes comparisons of performance from one state to another, and different states may designate more or fewer Title III districts for accountability actions and support depending on the rigor of their AMAOs.

Only 10 states met their state-level AMAOs for the 2008–09 school year, but at the district-level, 55 percent of Title III districts nationwide reported meeting their AMAOs in 2008–09.

According to annual state performance reports, only 10 states met all three of their state-level AMAOs for 2008–09.11 These states constitute a diverse set and include states with large numbers of ELs, states with small numbers of ELs, states with growing EL populations, and states with a long history of serving ELs. Among Title III districts that reported an AMAO status for 2008–09, about half (55 percent) indicated that they had met all three AMAOs in the 2008–09 school year. However, altogether, these districts served less than half of the nation’s EL population (39 percent); thus, the majority of ELs were enrolled in districts that did not meet all three of their AMAOs in 2008–09. Of the three individual AMAOs, Title III districts were least likely to report meeting AMAO 3, making AYP for the EL subgroup, in 2008–09 (64 percent of Title III districts, compared with 89 percent that reported meeting AMAO 1 and 82 percent that reported meeting AMAO 2).

Based on 2008–09 data, about one-third of Title III districts, which collectively served about one-half of the nation’s EL population, reported missing at least one of their AMAOs for two (22 percent) or four (11 percent) consecutive years, subjecting them to accountability actions under Title III.

Among Title III districts that could report their Title III accountability status for 2008–09 (89 percent of Title III districts), 22 percent reported missing AMAOs for two consecutive years, and 11 percent reported missing AMAOs for four consecutive years.12 These districts accounted for approximately 50 percent of the nation’s Title III-served ELs. Indeed, Title III districts with larger numbers of ELs were more likely than districts with smaller EL populations to indicate that they were designated for improvement actions under Title III after missing AMAOs for two or four consecutive years. About half (51 percent) of Title III districts that served more than 1,000 ELs reported missing AMAOs for either two (30 percent) or four (21 percent) consecutive years whereas 20 percent of Title III districts that served 150 ELs or fewer reported missing AMAOs for two or four consecutive years (16 percent and 5 percent, respectively).

In 2009–10, all states with Title III districts that had missed AMAOs for two consecutive years (46 and the District of Columbia) reported requiring those districts to develop an improvement plan, and most states with Title III districts that had missed AMAOs for four consecutive years reported requiring such districts to make instructional changes (18 of 24 states as well as the District of Columbia).

A chief function of Title III accountability systems involves building capacity and stimulating activities to improve EL services among Title III districts that repeatedly miss their annual performance objectives. To this end, states must require any Title III district that misses its AMAOs for two consecutive years to

In 2009–10, officials in 74 percent of Title III districts reported that all teachers serving ELs were fully certified for their positions. However, officials in more than half of Title III districts reported difficulty recruiting some categories of EL teachers.

Ensuring that teachers of ELs—including ESL teachers, bilingual teachers, and mainstream classroom teachers—have the appropriate qualifications and expertise to teach ELs is a central capacity-building role of states and districts. One of the main mechanisms for carrying out this role is through certification requirements. Overall, in 2009–10, 49 states and the District of Columbia offered an ESL certification or endorsement, and in 41 of these, such certification was required for teachers who specialize in EL instruction. In another three states this certification was recommended. In five states, ESL certification was not required, although the states did offer such certification or endorsements.

Among Title III districts, 74 percent reported that all teachers of ELs were fully certified for their positions, and in only 7 percent of districts were more than 10 percent of teachers not fully certified for their positions. However, it appears that “full certification” is not equivalent to “adequate expertise” from the perspective of district EL administrators: among those surveyed, 73 percent reported that “lack of expertise among mainstream teachers to address the needs of ELs” was a moderate or major challenge. Furthermore, officials in 54 percent of Title III districts reported difficulty hiring secondary content area teachers with training to provide instruction for ELs.

In 2009–10, 87 percent of Title III districts reported implementing at least one strategy to recruit and retain highly qualified teachers of ELs.

The most frequently reported strategy to support teachers of ELs was the provision of financial incentives to pursue advanced course work, such as stipends for course work or paid release time for professional development (43 percent of Title III districts). In addition, about one-third of Title III districts established partnerships with universities (35 percent), and another third developed teacher induction programs specifically for teachers of ELs (32 percent). Fewer districts (12 percent) reported financial incentives to recruit teachers, such as signing bonuses or housing incentives.


Overall, the findings presented in this report suggest that states and districts are implementing the provisions of Title III but challenges remain as states and districts strive to put the law into practice across a wide range of educational contexts.

—Title III districts vary considerably in the criteria they use to determine which students are considered ELs, meaning that a student who is identified as an EL according to one district’s practices may or may not be identified as such according to another district’s practices (even within the same state), raising implications for state and local EL funding levels, accountability, and service delivery for this subpopulation.

—State ELP standards and assessments have provided new tools and data to guide the instruction of ELs, but many states are still working to revise and improve these tools. Educators may still need additional support in meeting the needs of ELs in the classroom, and educators interviewed in this study expressed some concerns about the validity of content assessments for ELs. Some of these educators also perceived that the administration of assessments can come at the cost of lost instructional time for students and staff.

—States have established accountability systems that direct consequences and support to districts needing to improve EL outcomes; however, the performance objectives that underlie these systems vary considerably across states and have undergone considerable revision, complicating comparisons of performance across states and over time.

—States and districts indicated limitations in their capacities to support EL needs as they confronted challenges associated with insufficient funding for EL services, limitations in their data systems, shortages of staff with EL expertise, and a lack of information on proven programs for serving ELs.

Despite the challenges expressed here, Title III seems to have raised awareness of the needs of ELs, an historically overlooked population, as states, districts, and schools have engaged in increased efforts to accurately identify ELs, place them into instructional services that meet their needs, and assess and monitor their progress toward attaining proficiency in English and achieving state academic standards.