State Board adopts final rule; questions loom over AG problem
After two delays, the Indiana State Board of Education provided final approval to the new A-F school accountability framework March 4, with a few changes to address the final round of public feedback in January.
Indiana is moving to a system designed to measure more than standardized test performance, shifting the state’s evaluation framework to include student skills, experiences, and career readiness indicators alongside traditional academic metrics.
State education officials describe the framework as an effort to measure what they call the full range of characteristics needed for success after graduation, rather than focusing almost exclusively on standardized test performance. The system incorporates 18 indicators across multiple grade bands, from early elementary through high school graduation and postsecondary readiness.
At its core, the framework retains traditional academic measures but adds new indicators that reflect student progress, engagement, and real-world preparation.
But the question remains whether the slight changes made to the framework are enough to satisfy Attorney General Todd Rokita (R), who we exclusively reported in January raised several concerns with the proposed rule and questioned its constitutionality.
The Attorney General plays a significant role in the accountability framework becoming law, as he must perform a legal review of the final rule and sign off that it passes legal muster – typically a formality that has not caused serious issues in the past. The key here is that his job is meant to ensure the rule is legally sound, not conditioned on whether he agrees with the underlying policy . . . and we understand there may be some disagreement among the two offices on the Second Floor over those distinctions.
AG Rokita does have the power to not sign the rule, and he indicated in early January that he might do so if the board and Indiana Department of Education again failed to take his points into account in the final draft.
When asked if the AG’s concerns were satisfied in the final rule, Secretary of Education Katie Jenner did not answer if he agreed to sign the new rule or not, instead telling us, “You’ll have to ask the Attorney General.”
“We’ve appreciated the opportunity to speak with the Attorney General and their team. The Attorney General’s team was one of many public comments that we received … whether it’s JotForm, through letters, through focus groups,” Dr. Jenner added.
She continued, “We did the best we possibly could to really weave the comments feedback together, also, while simultaneously working with the U.S. Department of Education to really thread the needle and do what’s best for Indiana and our students.”
A Model Built Around Student Milestones
The new A-F system evaluates students and schools across different developmental stages.
In kindergarten through grade 3, the framework emphasizes foundational literacy and math skills, measuring student performance primarily through ILEARN proficiency in English language arts and math while also considering reading proficiency through the IREAD-3 assessment, accelerated literacy growth, and regular attendance.
For grades 4 through 8, the model expands to include additional academic subjects and growth measures. Schools earn credit for ILEARN proficiency in English and math, as well as student growth indicators such as one year of academic progress, accelerated growth, and movement toward proficiency. Science and social studies proficiency also factor into the model, along with English-language proficiency progress for English learners and attendance rates.
By middle school, additional indicators begin to track readiness for high school. Students may earn credit for completing a graduation plan in seventh grade and for taking high school-level coursework or earning credits by eighth grade.
High school accountability focuses heavily on college and career readiness milestones. For grades 9 and 10, schools receive credit when students remain on track toward graduation, complete key coursework, and participate in advanced classes or career-technical education. Indicators also include meeting PSAT benchmarks, participating in work-based learning, or earning credentials of value.
By grades 11 and 12, the framework incorporates diploma attainment and the new readiness seals, along with measures such as proficiency on end-of-course exams and performance on national assessments.
Under the proposal, 80% of a school’s grade-12 accountability score would be based upon readiness indicators tied to knowledge, skills, and experiences, while graduation rate and standardized assessment results would each account for 10% of the final rating to meet federal accountability requirements.
“This model values academic outcomes as well as skills and experiences. It’s so much more than just creating a robot who can memorize things,” Assistant Secretary of Education Paul Ketcham described the framework at the March 4 meeting.
“In 49 other states, it’s an accountability rule,” Ketcham declared, playing off of Indiana’s basketball motto. “In Indiana, it’s a roadmap for schools and students and families to be successful.”
How Schools Will Earn Letter Grades
Rather than focusing solely on aggregate school metrics, the model calculates points at the individual student level before averaging those scores to determine a school’s overall grade.
Each student generates an initial point total based on academic mastery – primarily test performance – and can earn additional points through indicators tied to growth, coursework, credentials, or other achievements.
The state describes this approach as treating “N size” as one, meaning each student’s outcomes directly influence a school’s accountability rating.
The resulting points are averaged across all students to determine a school’s final A-F grade.
Changes Between Earlier Drafts and the Final Proposal
IDOE made a few adjustments to the final accountability model after public comment and stakeholder feedback. Many of these changes appear to address some of the concerns OAG has had.
One change centers on English learners and early literacy. Feedback emphasized that language development is foundational to reading proficiency. The final version therefore, requires IREAD for all students while also incorporating the WIDA assessment for English learners who have been enrolled in Indiana schools for less than two years.
Another major revision involves the balance between proficiency and growth. Earlier drafts weighed student proficiency and growth targets equally. The final proposal gives greater weight to proficiency while still recognizing progress toward that goal, ensuring that students who have not yet reached proficiency cannot generate more points than those who have.
This particular change may satisfy one of the main concerns Attorney General Rokita outlined in his three letters to the department and board. Recall Rokita took issue with what he viewed as the framework “diluting” student assessments and grades. He asserted that the original drafts of the framework allowed too many “subjective metrics of students’ performance that are not tied to tests of students’ proficiency in academic subjects” to serve as the primary measure of academic mastery for high school students.
Middle school indicators were also revised. Stakeholders noted that seventh grade offered fewer opportunities for students to earn success indicators. In response, the final model adds a new measure for completing a graduation plan in middle school and shifts the high school-coursework indicator to eighth grade, where most students actually begin taking those classes.
IDOE also modified the system to better account for students with significant cognitive disabilities who participate in Indiana’s alternate assessment, known as I AM. The final rule allows those students to earn points for academic mastery, with proficiency generating the maximum possible points.
The framework additionally introduces a new indicator tied to civic literacy, recognizing students who demonstrate strong understanding of government on the ILEARN U.S. Government end-of-course assessment.
This was another concern and suggestion from the OAG, according to his January 5 public comments. He raised concerns that “the Board does not appear to have considered making assessments of U.S. government a mandatory part of its accountability model.”
At the high school level, the final version also adjusts how assessment results affect accountability scores. SAT proficiency is now a standalone indicator worth 10% of a school’s grade-12 rating, ensuring every student’s test performance is reflected in accountability results. Rokita also had expressed concerns that the SAT was not part of the grade 12 academic mastery metric in the original drafts.
Students can also generate additional points by meeting benchmarks on other college-readiness assessments, including the ACT or the Classical Learning Test – the latter of which was just added as a state-recognized college entrance exam by the General Assembly this session with the passage of SEA 88-2026.
Transition Plan and Grading Scale
The state plans to introduce the new system through a phased transition designed to establish a new performance baseline for schools.
The first year of ratings starting this fall will be labeled “year zero,” allowing educators and families to see how schools perform under the new model before long-term expectations are fully implemented.
Initial A-F grades will use a slightly lower threshold than the final scale, with schools earning an A for scores between 85 and 100 points during the transition period. Eventually, the state plans to raise the threshold to a final scale in which A grades require 90 to 100 points.
If more than 25% of schools receive an A, the grading scale will automatically increase by 2.5 points until the final thresholds are reached.
Eventually, Indiana will also implement a new plan for how to deal with failing schools with D and F grades. The General Assembly in HEA 1266-2026 directed Secretary Jenner to develop strategies for addressing academically and financially struggling schools and present those to the legislature to codify in the 2027 session.
As far as what we can expect, Dr. Jenner previews that the strategy going forward will follow more of a supportive structure, rather than punitive.
“Where we’ve seen a lot of success in Indiana is not through consequences, consequences. It’s through support,” she details. “It’s through trying to figure out, you know, every child can, every school can. How might we support them to get there? So that will be the lens that we’ll be looking through.”
Dr. Jenner pointed to the Indiana Literacy Cadre as a strategy she hopes to replicate, where schools with 70% or less passing rates in IREAD received state support through the cadre to boost their scores. The cadre has worked well so far, with large gains in IREAD scores seen over the last two years among cadre schools.
Delay in Federal Waiver Application
As IDOE and the board continued work on the A-F rule into the beginning of 2026, Secretary Jenner opted to pause the department’s federal flexibility waiver to the U.S. Department of Education.
The reason was that the department wanted to ensure its new accountability framework was shored up before it continued pursuing the waiver. A key part of IDOE’s waiver to the Elementary and Secondary Education Act requests to use its own accountability model to evaluate schools moving forward for federal funding, rather than the federal government’s model.
“We wanted to get our legislative session completed, and we wanted to get this rule approved, and then we will unpause and proceed in our conversations,” Secretary Jenner explained.
You may recall AG Rokita, in his final comment letter in January, did fault the state board for not clearly taking into consideration how the accountability model would work with its federal waiver. He wrote, “the omission from the Board’s notices of any discussion of the federal requirements and the sought-after waiver is significant,” arguing that the public lacked sufficient information to evaluate how the rule would function if the waiver is denied or delayed.
That does not appear to be the entire reason Secretary Jenner opted to pause its waiver consideration, though.
IDOE worked with U.S. DOE to ensure this accountability model met proper expectations. From what we have heard, it seems that Indiana is on the path to earn approval for the waiver once the process restarts, as the federal department has a favorable opinion of Dr. Jenner and her direction of IDOE.
“The U.S. Department of Education has been truly fantastic, and working with them, I think they have pushed and pulled in the right direction and ask the right questions of us, you know, causing us to really think more deeply about some of our policy decisions,” Dr. Jenner divulged. “They’ve also praised areas that we are leaning into. So the waiver will happen.”
The U.S. Department of Education has 120 days to review and respond to waiver applications after they are submitted. Indiana filed its request in October, but the pause extended that timeline.
A Shift in How School Performance is Measured
Supporters of the new model argue that the system reflects a broader understanding of student success, rewarding schools for preparing students not only academically but also for life after graduation.
Education stakeholders, including the Indiana Association of Public School Superintendents, the Indiana Association of School Principals, the Indiana School Boards Association, and Teach Plus Indiana, offered letters of support for the final accountability framework. They also praised the department and board for collaborating with them over the last year as the rule was developed.
Dr. Jeff Butts, executive director of IAPSS, voiced support for the proposed accountability rule at the March 4 board meeting, saying it reflects years of collaboration between educators and state leaders and improves how school performance is measured.
Dr. Butts affirmed accountability systems should give families clear information about school performance while recognizing improvement by educators.
“Systems that we have had in the state of Indiana, while they provided data, they were often too complex for families to understand, and sometimes emphasized compliance more than outcomes,” Dr. Butts expressed.
This framework provides clearer expectations across grade levels, from early literacy and math development to career exploration in middle school and meaningful postsecondary preparation in high school, Dr. Butts asserted. He continued, “This new rule represents a very important step forward. It strengthens balance between student proficiency and growth. It recognizes both achievement and progress and sharpens the focus on foundational literacy and mathematics.”
Board members also delivered high praise before taking a vote on the final rule. The vote was unanimous.
Next, the Attorney General has 40 days to sign the rule, and his office tells your favorite education newsletter he has not received it yet for review. “We will assess the rule, including whether it resolves the legal issues we identified during the comment periods, once it is submitted to our office,” an OAG spokesperson explains.
When (or if) the AG signs the rule, the Governor will be the final signature, and he is expected to add his imprimatur.