There has been a recent influx of funding for schools to aid in their recovery from the COVID-19 pandemic. These funds, known as ESSER III (the third installment of the Elementary and Secondary School Emergency Relief Fund) were authorized under the American Rescue Plan (ARP) Act. ESSER III funding provides LEAs with short-term federal relief funds to be spent by September 2024 to address the effects of COVID-19 and to change the systems and practices needed to improve student learning. In the state of Wisconsin (where EA is headquartered), the Department of Public Instruction (DPI) received more than $1.5 billion to distribute to 464 local education agencies (LEAs) serving over 814,000 students. EA supports DPI through the Wisconsin-Minnesota Comprehensive Center – Region 10, in collaboration with the Center for Applied Research and Educational Improvement (CAREI) and the Wisconsin Education Collaborative (WEC). In this blog, we will describe our work supporting DPI as they worked with LEAs in the state to apply for and receive ESSER III funds.

ESSER III requires LEAs to reserve at least 20% of the funds for evidence-based improvement strategies (EBIS), and to ensure that those interventions (1) respond to students’ social, emotional, and academic needs and (2) address the disproportionate impact of COVID-19 on underrepresented student groups. To be “evidence-based,” a strategy must meet criteria that align to the ESSA (Every Student Succeeds Act) tiers of evidence. To receive the 20% of funds for EBIS, LEA staff must submit an application to the state that indicates that the strategy is at least a “Tier 4” (i.e., demonstrating a strong rationale). While well intentioned, this federal policy requirement assumes that LEAs employ staff with the capacity (meaning both time and expertise) to accurately assign each EBIS to one of the following tiers:

ESSA Tiers of Evidence

In Wisconsin, this policy does not align to the realities that almost all LEAs face, because making an accurate ESSA tier designation requires in-depth understanding of five factors of research studies:

  • Study design
  • Study results
  • Findings from related studies
  • Sample size and setting
  • How the students and setting in the study overlap with those in the district or school considering the intervention

The table below summarizes the multiple factors used to assign ESSA tiers and demonstrates the expertise needed to make these assignments effectively.

Five Factors When Making ESSA Tier Assignments

Given natural capacity constraints for many LEAs in Wisconsin, DPI developed guidance and supports in Summer/Fall 2021 to make these requirements more accessible and user-friendly for LEA staff. Then, in Winter 2021-22, DPI reviewed LEA’s submitted applications to determine whether the proposed EBIS met requirements for funding, and if not, DPI engaged in an iterative process with the LEA to make the necessary revisions.

Providing support to DPI

As mentioned above, EA provided technical assistance to Wisconsin DPI for this process through the Wisconsin-Minnesota Comprehensive Center – Region 10 (WMCC10). WMCC10’s mission is to strengthen the capacity of state education agency (SEA) staff to support LEAs—in this case, in identifying, selecting, implementing, and evaluating EBIS to improve equitable outcomes for students. We worked with DPI on steps 1 and 3 of the following four-step process:

Developing and disseminating ESSER III application guidance (Step 1)

We first supported DPI in developing guidance for LEAs on how to identify, select, and propose an EBIS which meets the Tier 1-4 requirements. When ESSER III funds were first announced (April 1, 2021), DPI recognized the challenge the application process would present to LEA leadership already facing significant capacity constraints: How do we identify and select the best EBIS for our schools and community to address issues presented by COVID-19, while also navigating a process that requires applying a complex ESSA tiering methodology?

To provide effective support at scale (i.e., serving 464 LEAs) and within a compressed timeline, DPI recognized the need to develop highly accessible guidance and resources by early Fall 2021. Some of these key resources that DPI created included:

  • A Wisconsin-specific ESSER III page, which provided a one-stop-shop for LEAs to find all necessary information about ESSER III
  • This overview of ESSER III Funds and Evidence Based Improvement Strategies to support LEAs with the specific task of selecting the most appropriate EBIS. This document includes a pre-approved list of EBIS and introduces an “Other” category (which requires the district to provide the EBIS name/description and to make an accurate ESSA tier assignment)

Although this approach decreased the ESSER III application burden for LEAs, the need to develop guidance and resources to support LEAs pursuing the “other” category remained. EA supported DPI by reviewing resources created for these LEAs to ensure they clearly conveyed essential information for accurately assigning ESSA tiers in an accessible way—while maintaining the integrity of a technical and often complex process.

The primary focus of our support was Tier 4 (Demonstrates a Rationale), because this was the minimum requirement for funding, and it included an additional application requirement of submitting an accompanying logic model or theory of action. EA collaborated with DPI to develop Logic Model Guidance and a corresponding Logic Model Template, which provided accessible guidance on how to develop a logic model for an EBIS. When co-developing these documents, EA emphasized a step-by-step approach with real-world examples to build LEA staff capacity to develop their own logic models. These Tier 4 resources were well-received by LEA staff, but it did not address the underlying capacity needed to accurately identify an EBIS as Tier 4.

For example, if an LEA inaccurately interprets a Tier 4 EBIS to be Tier 2, they wouldn’t submit a logic model. Without experience and expertise in ESSA tier assignment, LEA staff may incorrectly categorize an EBIS and then be required to resubmit the application under an even more compressed timeline. To address this challenge, DPI identified the need for an efficient application review process, which would provide timely and iterative feedback until funding requirements were met.

How do we identify and select the best EBIS for our schools and community to address issues presented by COVID-19, while also navigating a process that requires applying a complex ESSA tiering methodology?

ESSER III application review and feedback (Step 3)

Given the importance of an efficient application review process, DPI identified the need to establish a cadre of DPI reviewers and strengthen their capacity in the ESSA tiers to ensure accurate reviews and effective feedback. To do so, EA conducted training sessions where we guided DPI staff through the process of identifying and reviewing research studies for an EBIS to determine the appropriate ESSA tier. Some sessions highlighted EBIS with extensive research (often with conflicting findings) to strengthen staff’s capacity for differentiating between Tiers 1-3, while other sessions focused on EBIS with little to no research to strengthen capacity for developing a theory of action and logic model required by Tier 4.

EA also provided ad hoc consultation when it was particularly difficult to discern an EBIS ESSA tier. While DPI staff did report this training and consultation strengthened their capacity, EA’s lack of direct involvement in the application review process means we can’t directly verify the accuracy of reviews or quality of feedback. One unanticipated benefit of EA’s support was that session participants were able to transfer their learning to other DPI EBIS initiatives. DPI has also expressed interest in deeper capacity building engagements with EA, particularly around (1) selecting EBIS that are the best fit for specific populations and settings and (2) effectively monitoring implementation and evaluating impact.

Lessons Learned and Next Steps

While the $1.5 billion in ESSER III funds are needed by the 464 LEAs to address challenges presented by COVID-19, the requirements to receive the 20% allocation for EBIS have some unintended consequences for LEAs. First, very few LEAs (in Wisconsin or nationally) have the capacity (time and expertise) to identify an EBIS that best addresses student needs, accurately categorize the EBIS into an ESSA tier, and develop an accompanying logic model (when necessary). Second, expecting LEAs to develop capacity at scale within 3-6 months via support from SEAs (which are facing their own capacity constraints) is unrealistic. Within this context, DPI (supported by WMCC10) rose to the near-impossible challenge. While these efforts have achieved the policy goal of distributing millions of dollars for much-needed EBIS, the speed of the policy and application process lead to numerous questions, including:

  • Did this process lead to the best EBIS for every LEA, or simply EBIS that that were already pre-approved and required less technical capacity to propose?
  • Did this process increase LEAs’ capacity for understanding ESSA tiers, or “muddy the waters” through guidance that was simplified due to necessity?
  • Did this process equip LEAs with the motivation and resources to monitor implementation and evaluate impact?

Each of these questions illustrate an opportunity for extending the WMCC10 support to DPI going forward, even though the immediacy of the ESSER III funding and application process is passing.

Although the end of ESSER III funding may seem like the distant future (September 2024), it may be wise to anchor next steps in this end date. One thing LEAs will ultimately need to decide is whether to continue the selected EBIS without ESSER III funds. WMCC10 is discussing with DPI the possibility of offering support to LEAs for monitoring EBIS implementation and conducting evaluatios to enable this decision making. In doing so, LEAs would be providing valuable data to practitioners and policymakers on the effects of this massive federal investment on student outcomes.

Interested in Learning More About WMCC10?

Feel free to visit our website at https://wmcc10.org or send us a message, regardless of your location! If you are based in Wisconsin and Madison and are interested in receiving support, we would love to connect with you and start a conversation.