One of the benefits of membership with the Texas Charter Schools Association (TCSA) is representation at the Texas Capitol. On Tuesday, November 14, 2017, TCSA’s Bruce Marchand appeared before the House Public Education Committee to advocate on behalf of public charter schools and students. Below is the testimony he provided to the Committee to support students and public charter schools impacted by Hurricane Harvey.
Interim Charge: Recommend any measures needed at the state level to prevent unintended punitive consequences to both students and districts in the state accountability system as a result of Hurricane Harvey and its aftermath.
Good morning Chairman Huberty and members of the Committee. My name is Bruce Marchand and I am the Director of Charter School Growth and Development of the Texas Charter Schools Association, or TCSA. TCSA represents 172 public charter holders and approximately 675 campuses that educate nearly 300,000 public charter school students.
Thank you for the opportunity to participate today on the discussion related to recommendations on measures needed to prevent unintended punitive consequences in the state accountability system as a result of Hurricane Harvey and its aftermath. While TCSA is a strong proponent of school accountability, we also recognize that the impact of Harvey on our public schools and students in those regions is unprecedented.
And, while we do not support a complete waiver from the state’s accountability system for this school year, we do encourage a state effort to recognize and make an accommodation in the academic accountability system for those schools and students impacted by Harvey.
Therefore, TCSA’s proposal is to exempt students, who are identified through TEA’s PEIMS crisis codes as students impacted by Harvey and other recent hurricanes, from the school’s district and campus accountability subset for the 2017-18 school year. Again, this is not a recommendation for exemption from testing, but simply the one-year exclusion of these impacted students from a campus and district or charter holder accountability subset.
TEA established PEIMS crisis codes to track students impacted by Harvey (5A-C) and any other hurricanes (06) – such as Irma and Maria to identify these affected students:
5A – This specific code indicates a student was enrolled or was eligible to enroll in an LEA impacted by Hurricane Harvey, and the student enrolled in a different LEA during the 2017-2018 school year.
5B – This specific code indicates a student was enrolled or was eligible to enroll in an LEA impacted by Hurricane Harvey, and the student enrolled in another campus in the same LEA during the 2017-2018 school year.
5C – This specific code indicates a student is identified as homeless because of Hurricane Harvey but has remained enrolled in their home campus during the 2017-2018 school year.
06- Indicates that a student enrolled in a Texas public school during the 2017-2018 school year as a result of being displaced from their residence by Hurricane Irma, Hurricane Maria, or any other hurricane labeled as such by the National Hurricane Center, other than Hurricane Harvey.
As for precedent, in 2006 students who were displaced by Hurricanes Katrina and/or Rita were tested in the state assessment system but their results were removed from the accountability subset, as noted in Appendix I of the 2006 accountability manual. As justification for this approach, I would refer you to a March 24, 2010 study conducted by Student Assessment Division at TEA that examined the performance of students who were identified in the 2005-2006 school year as being displaced by Hurricane Katrina or “Katrina students”. This study examined the performance of these displaced students for three years and found that in the first year after the storm that Katrina students tested in Texas (2006), the percentages of these students passing was far below the passing percentage of all Texas students in reading and mathematics.
Hurricane Harvey has caused similar conditions for Texas students. The living conditions as well as the educational programs of displaced students due to Harvey have been severely disrupted. Many schools have spent, and continue to spend, considerable resources addressing not only the academic needs of these students but also the socio-emotional needs brought about by students’ suffering and displacement.
In light of these circumstances, and the challenges faced by public schools in ensuring these students are mastering grade-level TEKS, and the evidence as noted in the Katrina study that many of these students may well perform below state standards in their tested areas as compared to their non-affected peers, it is logical that students who are identified by these specific PEIMS codes should be excluded in the 2017-2018 accountability subset for public schools. To be clear, the students would still test. It is important for schools to have the data necessary to assess the progress of students. Our recommendation is simply that testing results of these specific students, similar to what TEA has done in the past, be excluded in this school year’s rating.
With that I conclude my testimony, thank you again for the opportunity, and welcome any questions.
Immigration and Your Charter School: Protecting Rights of Schools and Students in an Age of Immigration Enforcement
This webinar will highlight best practices on matters pertaining to federal and state law enforcement agencies in light of new and anticipated rulings and interpretations of immigration enforcement practices.
Presented by Joseph Hoffer from Shulman, Lopez, Hoffer and Adelstein LLP
Wednesday, September 20th from 12 noon to 1 p.m.
Are you in? Online Tools to Engage Advocates
Public Charter Schools in Texas had a great victory in the 2017 Special Legislative Session. We attribute this victory to the thousands of advocates who spoke up and contacted their lawmakers this year, and in prior years. TCSA has been able to make significant gains for students as a result of these grassroots advocacy campaigns. Our fight is not over and we need you to join our efforts! Join us on this webinar to learn about the digital tools that TCSA has created to make sure all of our advocates are part of our advocacy efforts. Are you in? Text “countmein” to 52886* to get a sneak peek of our new tools and learn how you can make a difference!
Presented by Martha Fernandez from the Texas Charter Schools Association
Wednesday, October 18th from 12 noon to 1 p.m.
Fostering Success for Students in Foster Care
All of your students are special, but particularly those who are in the temporary or permanent custody of the State of Texas. Spend an hour learning Texas law and best practices for fostering the success of students in foster care. Charter school attorney and former TCSA General Counsel Denise Pierce will lead a rich discussion on issues pertaining to the admission, enrollment, and services for foster care students. Pierce will also touch on the thorny issues of confidentiality, special education, discipline, and on-campus access to these students by third parties such CPS case workers and police officers. Board members, central office administrators, special program directors, and campus administrators who attend this webinar will leave with information, insights and resources to make them better equipped for fostering success for students in foster care.
Presented by Denise Nance Pierce from The Law Office of Denise Pierce, P.C.
Wednesday, October 25th from noon to 1 p.m.
Update Your Personnel Handbook: Changes are needed due to new legislation
When was the last time you updated your Personnel Handbook? Chances are it has been too long! This webinar will help charter leaders understand the policy changes required as a result of Senate Bill 7, regarding electronic communication policies and impacts on TRS annuities. The webinar will address common charter school human resources questions, such as state leave days, and exempt and nonexempt employees under the Fair Labor Standards Act, to name a few.
Presented by Lindsey Gordon from the Texas Charter Schools Association
Wednesday, November 8th from 12 noon to 1 p.m.
HB 22: Preparing for Changes in 2018 Accountability System
Are you aware of all of the accountability changes that are coming in August of 2018? Join Dr. Paula Moeller as she discusses what will be measured within each of the three domains and how the Texas Education Agency will roll out the new accountability system with charter districts and campuses.
Presented by Paula Moeller from the Texas Charter Schools Association
Wednesday, November 29th from 12 noon to 1 p.m.
There is much to celebrate with the latest Texas Education Agency (TEA) academic accountability ratings that were released last week. More charter campuses than ever, 538 in all, achieved Met Standard or Alternative Standard accountability, while the number of charter holders meeting standard increased to 85 percent, a 4.8 percent increase over the years from 2013-2017.
The gap between the performance of ISDs and charters is closing rapidly as well. Using an “apples to apples” comparison that removes “not rated” campuses from the denominator for ISDs and charters, 91.4 percent of all charter campuses achieved Met Standard in 2017 while 95.7 percent of ISD campuses did the same, a 4.3 percent difference. That’s a great deal of improvement since the year 2013 when, using this same methodology, the Met Standard difference between charter and ISD campuses was 11.8 percent. The same improvement is seen comparing charter holders to ISDs, with a 6.7 percent difference in Met Standard ratings between the two groups in 2017, compared to an 11.2 percent difference in 2013.
The recently released Stanford University Center for Research on Educational Outcomes (CREDO) study confirms this improvement in performance indicators. The 2017 CREDO analysis of Texas charter school academic data reveals that Texas charter students gained about 17 extra days in reading each year compared to students in ISDs, with math performance about the same. This is significant as the 2013 CREDO study found that Texas charter school students were losing about 17 days of instruction in reading and 23 days in math compared to their ISD counterparts. Also noted in the most recent CREDO study is the fact that Texas charter schools educate more economically disadvantaged students (72 percent to 60 percent) as well as higher percentages of traditionally underperforming populations, including Hispanic and African American students.
Achievement at the highest levels is particularly noteworthy, as 40 charter campuses received all available academic distinctions this year, up from 32 campuses in 2016. This amazing accomplishment represents six percent of the 675 charter campuses evaluated and mirrors the performance of ISD campuses where 427 out of 6,904 campuses (6.1 percent) received all available distinctions.
So what’s in store for the future of Texas academic accountability? Most importantly, the implementation of HB 22 mandates that beginning in August 2018, all Texas ISDs and charter holders will be evaluated on three domains: Student Achievement, School Progress, and Closing the Gaps. Based on performance in those domains, a rating of A, B, C, D or F will be assigned to each domain as well as an overall letter grade for the ISD or charter holder. Campuses will begin to be evaluated on the A-F system beginning in 2019. In the meantime, Commissioner rules will need to be written to provide guidance on how the new accountability system will roll out. As we receive more information, we will keep you informed and provide the training and support you need to understand and successfully navigate this new system.
As each of you begin your new school year, please know that the Texas Charter Schools Association is here to support you in every way to provide you, your students, staff, and parents with the highest level of quality support and advocacy. Please let us know how we can help you to accomplish your mission for success as we all work together every day to provide a quality public school choice option to the students of Texas!
Last week, the Texas Charter Schools Association (TCSA) held its quarterly Member Council Meeting (MCM) with about 40 participants representing member charter schools from across the Lone Star State.
TCSA’s Executive Director David Dunn opened the meeting with brief remarks and was followed by MCM Chair, Kathleen Zimmermann, who welcomed members to Austin. Dunn shared some great news for the charter section with the release of the newest CREDO study, Charter School Performance in Texas, which found that student at charters are outperforming their peers at school districts. Most notably, students are gaining an additional 17 days of learning in reading and have closed the gap in math. Additionally, Hispanic student in poverty at charters are also faring better in both reading and math as compared to their school district counterparts. TCSA issued a press release featuring these findings, which has resulted in news stories by the Houston Chronicle, the San Antonio Express-News, El Paso Inc., and ED Week.
Following Dunn’s welcome remarks, TCSA Board Member Lori Fey addressed members and provided an update on the Executive Director Search. Fey is the Chair of the Search Committee and is working with Bellwether Education Partners to identify TCSA’s next leader. Fey is committed to a transparent process and has been meeting with various stakeholders within the charter school sector and education community gathering information. She welcomes input on this search and looks forward to finding the right person to represent students from all public charter schools across the state!
TCSA’s Veronica Garcia, Martha Fernandez, and Christine Nishimura gave an overview to members on the 85th Legislative Session and a federal update. This presentation featured TCSA’s grassroots efforts, legislative wins, and the bills impacting charter schools.
Next on the meeting agenda was Jo Ann Simmons of UT Tyler Innovation Academy who gave a presentation focused on academic rigor. Simmons candidly revealed her experience on what works to improve student outcomes and led a meaningful discussion among members about best practices. We hope this conversation continues, allowing for charter leaders to share information to strengthen student achievement at every campus!
Last, but not least was Michele Stahl of the Texas Education Agency. Stahl provided information on the new A-F Accountability standards. We appreciate Stahl and others at TEA for continuously working with public charter schools, ensuring that these campuses have information to effectively meet state requirements.
TCSA thanks all the member schools who attended both in-person and online and we look forward to our next meeting at the Texas Charter Schools Conference in Grapevine.
Yesterday, the Texas Education Agency (TEA) released the 2016 Charter Schools Performance Framework (CSPF) Reports for charter schools across Texas. Provision for the frameworks is found in TEC §12.1181(a) which states, “The Commissioner shall develop and by rule adopt performance frameworks that establish standards by which to measure the performance of an open enrollment charter school.” The intended purpose of the Frameworks is to inform parents and the public of charter school performance and to inform charter renewal decisions made by the Commissioner. TEA’s Charter Schools Performance Framework focuses on academic success, financial health and sustainability and operational compliance and effectiveness.
The Academic Framework indicators are aligned to components of the 2016 Accountability Standards for Texas public schools and will change overtime to reflect changes made within the State’s academic accountability standards. The 2016 academic indicators highlight district-level student performance on the STAAR Assessment as well as 4-Year and 5-Year longitudinal graduation rates. The related data for all public charter schools, as well as traditional districts, can be found online in the Texas Academic Performance Reports (TAPR).
The indicator targets found in the Academic Framework reflect the Index 1 and Index 4 targets within either the Standard or the Alternative Education Accountability (AEA) standards, based on the designation of the district and its student population. The Index 1 Meet Standard targets are set at 60% and 35% for standard and alternative accountability districts respectively. Similarly, the 4-Year and 5-Year Extended Longitudinal Graduation Rate Meet Standard targets, which for AEA districts includes continuation and GED certification, are set at 60% and 45%.
Indicators from the Financial Framework represent several of the indicators from Charter FIRST, which is the School FIRST (Financial Integrity Rating System of Texas) rating system for charter schools detailed in 19 TAC §109.1001. The indicators, that reflect the financial health and sustainability of the organization as well as the strength of the financial controls and management practices, may change over time to ensure continued alignment and to reflect any changes made within the Charter FIRST.
The Financial Framework indicators found within the 2016 Charter Schools Performance Framework reflect performance on the 2016 Charter FIRST indicators. Information used to determine a school’s FIRST rating comes from the Annual Financial Report and audited financials for the prior fiscal year. Consequently, financial data used to determine performance ratings on the 2016 Charter Schools Financial Framework indicators listed below reflect the 2014-2015 fiscal year.
The Operational Framework is an aggregation of compliance-related indicators that monitor program, governance, and reporting compliance. These indicators include third-party and self-reported data as well as program monitoring data from TEA:
The Texas Charter Schools Association (TCSA) was pleased to host 35 charter systems at the most recent Member Council Meeting on April 27, following the successful Texas Public Charter School Rally at the state capitol the day before. Additionally, some member schools participated in the meeting virtually.
Dr. Penny Schwinn, the Deputy Commissioner of Academics at the Texas Education Agency (TEA), kicked off the meeting with a presentation and shared the latest information about upcoming changes in the assessment and accountability divisions at TEA. Most importantly, there are several bills filed within the legislature to modify the domains used to calculate the A-F Accountability Rating, set to launch in the summer of 2018. It is probable that we will see the five domains reduced to only three domains for inclusion in the accountability system. The legislature will also determine if the implementation of the A-F Accountability System will occur as planned in the summer of 2018 or be delayed for another year, potentially providing districts with preliminary reports with unofficial grades. To follow changes occurring with the new accountability system, follow the progress of HB 22 and SB 2051.
Dr. Schwinn also shared information about a new Confidential Student Report (CSR), which will be available for the EOCs on June 13th and June 30th for grades 3-8. The revised reports will be family friendly and report on student progress, focus on growth and improvement, and academic proficiency. TEA will also include resources in the report to improve student performance in reading and mathematics. We encourage you to visit TEA’s website for more information.
The new CSR features:
• Growth and progress information
• A summer reading list
• Lexile levels and trend data
• New performance level descriptors
• Resources and suggestions for parents to use at home
• Suggested questions for parents to ask teachers and counselors
Dr. Schwinn also shared changes to federal accountability related to the reporting of special education students, especially when significant disproportionality occurs from one year to the next. The 10 PBMAS indicators related to placement, discipline, and representation will be replaced by 98 indicators with these proposed federal changes. A financial penalty will be assessed when a threshold is missed; charters will also be asked to review and revise policies, procedures and practice and make any associated changes publicly available. While PBMAS previously offered a range of performance levels, the new regulations will include pass/fail thresholds. We encourage charter leaders to follow the progress of these new regulations by following information posted on TEA’s website.
TCSA included a best practice session from a charter leader during the member council meeting. The April meeting included a presentation by Latisha Andrews, superintendent of Beta Academy, sharing five tips to sharing academic data with your board. She encouraged charter leaders to avoid using acronyms and educational jargon board members might not understand when sharing academic information and results. The use of clear data can produce a clear vision for the goals that need to be established to ensure all students within your system are growing academically. She also encouraged charter leaders to have a clear vision for student progress through the use of tangible, measurable goals set by the charter board of directors.
Here are the five tips Mrs. Andrews shared with leaders:
• Be Transparent
• Make Data Meaningful
• Set Goals
• Have Clarity
• Share the Floor
Please send requests for best practice sessions to include at the next Member Council Meeting on August 3rd at TCEA in Austin to my attention at email@example.com.
Register here to attend the next meeting in-person.
Register here to attend the next meeting virtually.
Helping You Understand Your Responsibilities Regarding Community and Student Engagement Ratings and the Texas Academic Accountability System
Big changes are coming to the way CaSE (Community and Student Engagement) indicators are evaluated and reported by districts and charter holders and individual campuses. On Tuesday, May 9th at 4 p.m. TCSA is providing a free webinar to help bring clarity to charter holders on this new and somewhat confusing process.
As a reminder, since the 2013-2014 school year districts and charter holders evaluated themselves and each campus on all eight components of CaSE - fine arts, wellness and physical education, community and parental involvement, 21st Century Workforce Development programs, second language acquisition programs, digital learning environment, dropout prevention strategies, and educational programs for gifted and talented students. Each district/charter holder and campus assigned ratings of exemplary, recognized, acceptable, or unacceptable to each of the eight components, using district-developed evaluation criteria.
With the advent of HB 2804 (84th Legislative Session in 2015), districts/charter holders and campuses must also select three of the eight components and a means to evaluate their progress, as the grades for the three selected components will be included in the A-F accountability system beginning in August, 2018.
The webinar will address the following:
• Understanding the difference between the two rating systems
• Selecting CaSE indicators to be evaluated
• Developing evaluation criteria
• Due dates for reporting indicators and evaluation criteria
• Best practices for CaSE reporting and evaluation
We look forward to you joining us on May 9th at 4 p.m. Register here.
In 2015, the 84th Texas Legislature passed HB 2804, which changed the Texas school accountability system so that every campus and district/charter receives one of five ratings from A through F, both on five separate domains and also combined into a single overall grade. By now you are probably aware that earlier in January your school received ratings for four of the five domains, based on your 2015-2016 accountability data. This preliminary glance at how schools would look under the new accountability system was done because HB 2804 requires the Texas Education Agency to give the 85th Legislature a work-in-progress update by January 1, 2017. At TCSA we’ve responded to a number of questions from our member schools in regards to the A-F accountability system.
Here are some FAQs we’ve received:
When does A-F officially go into effect?
Ratings under the new system will officially go into effect in August 2018, based on 2017-2018 performance data.
Does my “new” domain score have any impact on my current domain score?
No. The 2015-2016 score you received in each domain (Met Standard or Improvement Required) will remain in place. Commissioner Morath has cautioned that no inferences should be drawn on official current or future performance ratings for schools, and that the current A-F ratings should not be considered as predictors of future district/charter or campus ratings.
Will the current method of calculating A-F ratings remain the same?
Probably not. Based on legislative input, the structure of the A-F system and the way grades are calculated may change prior to the first official reporting of A-F grades in August 2018.
As a service to our members, TCSA would like to attempt to take some of the mystery out of the new accountability system and answer more fully these and other questions you may have. To that end, TSCA Director of Training Dr. Paula Moeller and I will host a free, one-hour webinar to all member schools on Monday, January 23rd at 9 a.m.
The main goals of the webinar are:
Please consider joining us for this free webinar on Monday, January 23rd at 9 a.m.
To register, simply click here, or go to the TCSA website and click on Trainings and Events, go to the Event Calendar, and click on the A-F Webinar tab.
This is to remind member schools of the deadlines regarding an appeal of a school's academic accountability rating for the 2015-2016 school year, and the critical importance of these ratings in light of the mandatory charter revocation requirements under Tex. Educ. Code §12.115(c).
On August 12, 2016, TEA released preliminary 2016 Accountability ratings (for the 2015-2016 school year) through each school’s TEASE account. The last day to timely appeal your Accountability Rating is September 30, 2016.
Basis for Academic Accountability Ratings. Accountability ratings are determined by assessing whether a school or charter operator meets or exceeds target index scores. Chapter 2 of the 2016 Accountability Manual. The four performance indices used to evaluate academic accountability include focus on student achievement, student progress, closing performance gaps, and postsecondary readiness. Each index is based on a score of 0-100 points, with campus or district scores calculated as a percentage of the maximum possible points. Together, the index scores result in ratings of Met Standard, Met Alternative Standard, Improvement Required, Not Rated, or Not Rated: Data Integrity Issues. Schools receiving an Improvement Required or Not Rated: Data Integrity Issues ratings should consider making a timely appeal to TEA.
Opportunity for and Basis of Accountability Ratings Appeal. To appeal a preliminary accountability rating, the school must first register the intent to appeal through TEASE, beginning on August 12 through September 30, 2016. 2016 Accountability Manual, 77. Once registered, the school must then mail a formal appeal to the Division of Performance Reporting.
Appeals must be postmarked or hand-delivered no later than September 30, 2016, in order to be considered.
Chapter 7 of the 2016 Accountability Manual governs the process for appealing an accountability rating and sets forth the specific items that must be included in the appeal (pages 78-81). Once a timely appeal is received, TEA staff will review and prepare a recommendation for an external review panel. Ultimately, the Commissioner will receive a recommendation from the external review panel and make a final decision, which is not appealable. Even in the context of a charter revocation hearing, the validity of a final academic rating will not be examined.
Grounds for an appeal of an accountability rating are varied. At a minimum, a viable appeal must involve a change that would result in a higher accountability rating. A valid appeal will highlight an error attributable to TEA, a regional education service center (ESC), or the test contractor for the student assessment program. In other words, errors caused by the charter are not appealable. For more detailed examples of what TEA will likely dismiss on appeal, please review page 83 of the 2016 Accountability Manual.
Charter Revocation Implications. Under Tex. Educ. Code §12.115(c) the Commissioner shall revoke the charter of an open-enrollment charter if the charter has received:
• An Unacceptable/Improvement Required academic rating for three preceding years;
• A Substandard or Suspended-Data Quality FIRST rating for three preceding years; or
• Any combination of the ratings described above for three preceding school years.
Because of this charter revocation mandate, it is critically important that member schools fully review their academic ratings and consider making an appeal. Once an accountability rating is final, it may not be appealed. Even in the context of a charter revocation hearing, the validity of a prior academic rating will not be reconsidered.
The Texas Charter Schools Association submitted the following comments to Commissioner Morath at the Texas Education Agency on Monday, June 27, 2016. The comments pertain to 19 TAC Chapter 97, Planning and Accountability, Subchapter AA, Accountability and Performance Monitoring, §97.1001, Accountability Rating System.
The Texas Charter Schools Association (TCSA) is the statewide membership organization for effective charter schools of all types, proudly representing nearly 228,000 students in more than 628 open-enrollment charter school campuses. We appreciate the opportunity to provide comment in response to the proposed 2016 Accountability Manual (19 TAC Chapter 97, Planning and Accountability, Subchapter AA, Accountability and Performance Monitoring, §97.1001, Accountability Rating System). Specifically, we are concerned with the limitations the 2016 Accountability Manual places on the ability for a school to successfully appeal its state accountability rating.
Appeal of Accountability Ratings
Chapter 7 of the proposed 2016 Accountability Manual sets forth the process and basis upon which a district or charter may challenge an agency determination of its accountability rating, as required under Texas Education Code §39.151. As proposed, the basis upon which a ratings appeal would be granted is extremely narrow and only “limited to rare cases where a data or calculation error is attributable to the test contractor(s) or the Texas Education Agency (TEA).”
Limiting the ratings appeal process to a data calculation error attributable to TEA or the test contractor impermissibly restricts the ratings appeal process that is statutorily provided to charters and school districts under Tex. Educ. Code §39.151. The only limitation set forth in Tex. Educ. Code § 39.151 is that the appeal must be in writing. In fact, section (c) of §39.151 specifically states a school district or open-enrollment charter school may challenge “any issue identified by the school district or open-enrollment charter school challenging the agency decision.” The very narrow basis for appeal provided in the proposed 2016 Accountability is in conflict with this statutory directive.
This inappropriate limitation by rule to the accountability rating appeals process affects all public schools, but particularly charter schools because open-enrollment charter schools are subject to mandatory closure requirements under Chapter 12 of the Education Code based on accountability and financial performance ratings. Given these high-stakes accountability requirements, when a charter school receives an accountability rating that is undeservedly low due to a data calculation or entry error made by the school, it should have the opportunity to fully appeal that rating, including the opportunity to demonstrate to the Commissioner with supporting evidence that it should receive a higher accountability rating if the error is corrected. As proposed under the 2016 Accountability Manual, there is zero opportunity to ensure that the accountability rating assigned to the school is the rating the school in fact deserves. Charter schools should have a full and fair opportunity to demonstrate to the Commissioner that its accountability rating should be higher and the Commissioner should be willing to review and adjust the rating to accurately reflect the academic performance of the school.
In closing, thank you for your careful consideration of these suggestions concerning the proposed 2016 Accountability Manual. We look forward to working with you to ensure that the Accountability Ratings System is an accurate tool for measuring the performance of schools.
 Page 77, Chapter 7 of the proposed 2016 Accountability Manual.
 Tex. Educ. Code §39.151(c)
 Tex. Educ. Code §12.1141(d) and §12.115(c)