Kentucky's school accountability system could be shifting for the 2019-2020 school year, pending a public comment period and potential feedback from federal education officials.

The state changed how it identifies schools for additional support last year in compliance with the federal Every Student Succeeds Act. Then, it rolled out two labels: Comprehensive Support and Improvement (CSI) and Targeted Support and Improvement (TSI) -- the bottom 5% of schools and those with student subgroups performing at that level, respectively.

Under those definitions, nearly half of Jefferson County schools were earmarked for additional support last fall. Roughly one-third of all Kentucky schools -- more than 400 -- were identified as TSI.

Now, those accountability identifiers could change, altering the TSI definition for fall 2019 and adding a third tier of support in fall 2020. If implemented as is, Kentucky could see fewer schools identified for support but more underserved groups slipping through the cracks.

In the draft plan, a school needs to be in the bottom 10% of all schools with at least one student subgroup performing in the bottom 5% of all students for three consecutive years to receive a TSI designation. Currently, any school with an underperforming student group receives the label, regardless of how well the school is doing as a whole.

The current methodology is meant to identify groups that may be underserved but missed because the rest of their classmates are doing well. In the accountability results released in fall 2018, dozens of schools across the state found themselves labeled as TSI for African-American and special education student performance.

Limiting the designation to the bottom 10% of schools could cause some of those groups to be overlooked. But it would reduce the number of support schools in a time when state resources are tight.

"The goal is to target schools that are in real need," said Jessica Fletcher, a Kentucky Department of Education spokeswoman.

The changes would also add a new layer of support between the two existing levels: Additional Targeted Support and Intervention (ATSI). A school needs to have been identified as TSI and continue have a student group in the bottom 5% of schools to receive the more intense label, accordingto KDE.

This will be checked every three years, beginning in 2020. So a school labeled as TSI in 2019 could have only a year to improve student performance before being moved to ATSI.

A school labeled TSI in 2020 would have until the next check-in in 2023 to improve before becoming ATSI.

KDE's interpretation of the definition differs from other education experts in the state, however. One read the statute created by Senate Bill 175 as ATSI schools being those that are TSI schools performing in the bottom 5% of CSI schools. KDE will be using their interpretation to identify schools for support.

CSI schools would continue to be identified in the same way: Any Kentucky school in the bottom 5% of all schools, or a high school with a graduation rate under 80%, would be labeled CSI. In a new change, any school identified as ATSI for three years would roll into CSI status.

Kentucky also will roll out a five-star school rating system in the fall alongside the accountability system. Using a composite score of indicators like test score growth, transition readiness and school climate, each school will be rated one to five stars, from lowest performing to best. This isn't new: State education officials said last year the rating system would launch in fall 2019.

Nearly all of the substantial changes stem from recent legislation, not state education officials. After SB 175 passed this spring, the state education board aligned its regulation with new state law in April. The draft is still going through the regulatory process, Fletcher said.

SB 175 aimed to significantly alter how schools are identified for support, hopefully reducing the number of schools labeled as TSI. Initially, the bill wanted to change the TSI definition to only label schools if a student group performs at the bottom 5% of that subgroup -- not all students.

State education officials said the initial bill could make it more difficult to spot achievement gaps and could run afoul of ESSA requirements. CSI and TSI statuses are expected to be judged in the same way, like against the bottom 5% of all students, KDE lawyers warned then. The bill was altered, passed and signed into law.

The bill also watered down the definition of transition readiness, reducing the benchmarks students need to hit to show they're ready for college or career. The legislation added a college placement exam as one way to prove readiness, too.

A public comment section on the amended draft ends May 31. The draft may be edited based on those comments before being sent to the federal education department for review, said Fletcher.