The Comal ISD board of trustees voted unanimously during its Sept. 21 meeting to join other Texas districts in a lawsuit filed against the Texas Education Agency over proposed changes made to the state’s accountability ratings system and the agency’s failure to notify school districts of the changes.

The details

The A-F rating system was implemented by the TEA in the 2017-18 school year. According to CISD, the system looks at student achievement and progress, closing performance gaps, career readiness, and community and student engagement alongside State of Texas Assessment of Academic Readiness performance.

“As most public school districts in the state, we believe in holding ourselves accountable and welcome the feedback that comes with assessments,” Comal ISD Superintendent John Chapman III said. “However, changes proposed to the A-F rating will not adequately reflect the performance of our students. Essentially, the rules are being changed in the middle of the game.”

According to the district, the lawsuit is based on Texas Education Code 39.0542 which requires the commissioner of education to provide school districts with a simple and accessible document explaining the accountability performance measures, methods and procedures that will be applied to their campus performance ratings.


Comal ISD said that when school districts in the state received the document, it did not contain information on the new system that could be used. The new accountability ratings were initially scheduled to be released Sept. 28 and be based on adjusted criteria, including a new threshold for college, career and military readiness scores, raising it from 60% to 88% to earn an A rating.

“I 100% believe in accountability. ... We need to be held accountable for student growth, student opportunity, and most importantly [college, career and military preparation] as we continue to move forward,” Chapman said. “The downside to this is that we do not even know the rules that exist today, and we're being graded on those rules.”

According to Chapman, CISD performed better on the 2022-23 STAAR exam than in previous years but would still see a drop in school ratings with the proposed changes to the accountability ratings, with 16 campuses labeled as “needs improvement” by the TEA and zero campuses maintaining A ratings.

Zooming in


The TEA announced Sept. 12 that the scores will be delayed one month to allow for further re-examination of the baseline data used in calculations.

Commissioner of Education Mike Morath is specifically named in the lawsuit and is seeking one of the following two options for the accountability scores:
  • For the commissioner to issue ratings for the 2022-23 school year and the 2023-24 school year using the existing system
  • For the commissioner to issue no ratings for the two school years
“We need another year to really regroup and to figure out what are those expectations as we move forward,” Chapman said.

The backstory

The TEA also redesigned the STAAR exam in the 2022-23 school year. The new exam was given online and included the addition of 14 question types and written responses across all grade levels and content.


Major changes to the STAAR test along with pending changes to the accountability system occurring at the same time are considered unprecedented in education and leave school districts with the appearance of underperformance despite making improvements, CISD said in a news release.

“This was designed this way. It was designed this way at the Legislature, and they are doing nothing but hurting kids,” CISD Board Trustee Michelle Ross said. “And we need to fight this for our kids and for our teachers. This is unfair.”