October 12, 2017
The Honorable Betsy DeVos
Secretary of Education
Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202
Dear Madam Secretary:
Re: Stakeholder Comments on the Texas State Plan for Implementation of the Every Student Succeeds Act
The signatories to this letter are local, regional and statewide disability organizations in Texas that have significant concerns with the submitted proposal of the Texas State Plan to implement the Every Student Succeeds Act and have found the proposal to be inadequate in meeting the federal guidelines for ESSA. ESSA implements many improvements to our education system. Most notably, it advances equity by upholding critical protections for America’s disadvantaged and high-needs students and maintains an expectation that there will be accountability and action to effect positive change in our lowest-performing schools, where groups of students are not making progress, and where graduation rates are low over extended periods of time. The disability community was grateful and hopeful for the opportunity to provide feedback on the draft plan and provided detailed comments to address the requirements of ESSA. We were disappointed to learn that the comments gathered from parents, advocates, and the disability community were not incorporated into the submitted proposal and the plan remained relatively the same as the submitted draft. No explanation was provided.
The changes made by the Texas Education Agency (TEA) to the final submission consisted of changes in tense and spelling, updated statistics, technical corrections, and similar housekeeping improvements. The changes do not reflect any of the detailed and substantive input submitted by stakeholders in the disability community, whose goal in providing recommendations to the draft plan was to assist TEA in meeting the federal guidelines for ESSA and to provide guidance for TEA in fully addressing the needs of children with disabilities.
As many members in the disability community have noted (see attached detailed comments), the draft and submitted state plans appear to be a collection of current program descriptions rather than a cohesive and coherent plan for ESSA implementation. Rather than take advantage of the opportunities afforded states under ESSA to make substantive system wide changes and improve existing programs, the Texas plan indicates an intention to maintain the status quo by repurposing the existing strategic plan. Therefore, the goals and purpose of ESSA are secondary in the Texas state plan, which disregards the stated intent of ESSA and diminishes Texas’ opportunity for this act to provide substantive policy changes that would benefit all students (especially those with disabilities).
We are confident that the promises made to all students by ESSA will be better met by incorporating meaningful stakeholder input into the Texas State Plan. We strongly recommend that the Texas State Plan for Implementation of the Every Student Succeeds Act be sent back to TEA for further work.
Thank you for your dedication to improving the public education system of the United States. We would be pleased to speak with you further to share our concerns at your convenience.
Easterseals Coalition Serving Texas
(Easterseals North Texas, Greater Houston, Central Texas, and Rio Grande Valley)
Coalition of Texans with Disabilities (CTD)
Senior Policy Specialist
Decoding Dyslexia — TX
Disability Right Texas (DRTX)
Down Syndrome Association of Central Texas (DS ACT)
Family to Family
National Down Syndrome Congress
Ricki Sabia, J.D.
Senior Education Policy Advisor
National Down Syndrome Congress
National Alliance on Mental Illness — Texas
Public Policy Director
Rio Grande Legal Aide
The Arc of Texas
Texas Autism Society
Texas Council for Developmental Disabilities (TCDD)
Texas Down Syndrome Advocacy Coalition (TxDSAC)
Texas Legal Aid
Texas Parent to Parent
Texans for Special Education Reform (TxSER)
cc: Mike Morath, Commissioner, Texas Education Agency
NDSC comments — www.advocacyinstitute.org/ESSA/StatePlanAnalysis/TX.ESSAdraft.NDSC.AI.Comments-8-10-17.pdf
TxSER comments — not available