ESSA “N-Size” Questions In the Spotlight

June 10, 2016

Bill DeBaun, Program Analyst

A relatively in-the-weeds topic is being scrutinized over its implications for data reporting and accountability -- and NCAN members should pay attention because it could affect new progress in postsecondary reporting requirements. A report released last week by the Alliance for Excellent Education, “Ensuring Equity in ESSA: the Role of N-Size in Subgroup Accountability,” pushes for setting state “n-size” limits no higher than 10. 

N-size is the “minimum number of students needed to form a student subgroup for federal reporting and accountability purposes,” Jessica Cardichon writes in the report, and a recently proposed rule for the Every Student Succeeds Act restricts states from setting their n-size greater than 30 without justifying it to the federal government. That’s because the thresholds could be manipulated to hide or display students’ academic and graduation outcomes, potentially harming students most when they’re at-risk. For instance, ESSA now requires the reporting of students’ postsecondary progress in the year following high school graduation – another outcome that could be skewed through n-size tinkering.

The Alliance for Excellent Education report describes how the n-size mechanism can obscure reporting: “If a state sets the n-size at 30 students and a high school has only twenty-nine African American students in the twelfth-grade class, that subgroup of African American students essentially does not exist for reporting and accountability purposes.” The subgroups specified in ESSA include “economically disadvantaged students, students from major racial and ethnic groups, children with disabilities, and English learners.”

In addition to the academic progress and graduation rate reporting that was required under No Child Left Behind, states will now be required, starting in 2017, to report on the percentage of high school graduates, overall and by subgroup, who enroll in “programs of public post- secondary education in the State; and…if data are available and to the extent practicable, in programs of private postsecondary education in the State or programs of postsecondary education outside the State” in the year following high school graduation. (NCAN will address the question of “if data are available and to the extent practicable” on reporting students’ postsecondary progress in private and out-of-state institutions in an upcoming blog post.)

This development is big news for NCAN members and the college access and success field because it would represent a school-level source of enrollment patterns, but the reporting requirements here are subject to the same potential n-size issues described above. If a state’s n-size is X and a school only has X-1 or less students from a given subgroup, no data on postsecondary enrollment for graduates from that subgroup will be reported.

The n-size tension resides around balancing desires to, on one hand, report on as many students in subgroups as possible (to identify achievement gaps) and, on the other hand, protect student privacy. An n-size set too low could potentially result in a violation of a student’s FERPA rights if the student becomes personally identifiable.

The question of n-sizes revealing or hiding student subgroups is not a hypothetical one. The Alliance report provides a number of real world instances where change an n-size changed a number of reported students. For example, “The California CORE Districts chose to use an n-size of 20 students, which is lower than the state-set n-size of 50 students and, collectively, were able to include 150,000 additional students in their accountability and support system.”

The Alliance report recommends that “ED should issue regulations under ESSA that prohibit states from setting an n-size above 10 students for reporting and accountability purposes unless the state demonstrates that setting a higher number would not exclude a significant number of students and schools. Under this regulation, states still would maintain the flexibility to set an n-size below 10 students.” That would be a significant change to the proposed rule, which currently says that “a State’s n-size may not exceed 30 students, unless the State is approved to use a higher number after providing a justification, including data on the number and percentage of schools that are not held accountable for the results of each required subgroup of students in the State’s system of annual meaningful differentiation, in its State plan.”

NCAN is staying engaged with this topic, and we will provide updates through this blog, Success Digest, and other avenues if and when there are new developments of which members should be informed.

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