The US Department of Education (ED) is seeking recommendations for what non-regulatory guidance should be provided to assist states and districts in understanding and implementing the Every Student Succeeds Act (ESSA). The ESSA requires that states report chronic absenteeism rates, and allows districts to spend federal dollars on training to reduce absenteeism.

The guidance from ED is designed to help the public understand the law, how ED is interpreting the law, and to provide clarification and examples of best practices. Once it is made final, the guidance won’t be mandatory, and it won’t impose any new requirements.

In January, ED sought comments on possible areas for regulation under Title I of the ESSA. This time the department is asking for input on ways to expand early learning; strategies to recruit, develop, and retain teachers and leaders (Title II); clarification of fiscal requirements; student support services (Title IV); and other areas where state and local agencies could benefit from additional guidance. In addition, ED plans to develop guidance regarding students in foster care, homeless children and youth, and English Learners (Title III).

We invite you to share with ED your thoughts, comments, and suggestions on areas or specific new requirements of the ESSA that you think would benefit from such guidance. We’ve developed draft comments, and a summary is below. Click here to find our final comments. Feel free to use our comments or adjust them to reflect your own interests. Comments should be submitted by May 25, 2016.

We are delighted by the requirement in the ESSA that schools must report on chronic absence (missing too much school for any reason), and we applaud Congress for including language that recognizes that no one measure of success is sufficient for examining whether a school is meeting the needs of its students.

Our experience working with schools and districts across the US has shown us that data reporting requirements are only effective if they are accompanied by guidance that is specific, actionable and research-based. And so we strongly believe that school districts would benefit significantly from (non-regulatory) guidance that gives them direction on how to use chronic absence data to identify which students, schools, sub-populations and even neighborhoods are at risk due to poor attendance.

With this in mind, Attendance Works offers the following draft recommendations:

• Provide guidance to districts to prevent chronic absence by taking an early warning approach that monitors when students miss 10% or more of school and use those data to trigger intervention throughout the year.
• Adopt a common 10% reporting requirement to align with using chronic absence data as an early warning indicator.
• Encourage messaging to families about the impact of chronic absence.
• Support incorporating attention to attendance into implementation of a multi-tiered system of support (MTSS).
• Promote cross-sector, inter-agency approaches to addressing chronic absence.
• Support the inclusion of chronic absence data in school report cards.
• Promote the reporting of chronic absence by grade level.
• Encourage states and districts to draw upon lessons learned about using chronic absence as a diagnostic tool and alternative accountability metric.

You can send comments to ED in an email message to ESSA.guidance@ed.gov, noting the topic area(s) in the subject line. Also, please include within the body of your email message, your name and, if applicable, the organization on behalf of which you are submitting comments. Click here to find the ED request for comments.

Updated July 1, 2016