Does Colorado’s state education plan fall flat? Some who helped write it think so.

While Colorado’s federally required education plan is being celebrated by national observers for changes to the state’s school accountability system and an extensive community engagement process, some advocates who helped shape the document say it falls short of pushing schools forward.

After more than a year of work, the state education department later this month is expected to submit the 145-page document detailing how it will spend federal dollars to better student learning, increase graduation rates and improve teacher quality.

Colorado will be one of the first states to submit such a plan, which also will provide new details on how the state will adhere to requirements under the new federal education law, the Every Student Succeeds Act. Signed into law by President Barack Obama in 2015, the law was designed to give states more authority. Many education officials in Colorado felt the law didn’t fulfill that promise.

Because Colorado was already operating under a waiver from the previous federal law, Colorado classrooms probably won’t notice much change. Many of the state’s reform efforts since 2008 already comply with the new law.

However, the department and State Board of Education are pushing back against one provision of the federal law that requires 95 percent of students take an annual standardized test in English and math.

Colorado law allows parents to opt their students out of those tests. The state board directed the department to inform federal officials that the state could not guarantee that it would be able to comply with that requirement.

It’s unclear how the department will respond. Observers expect the U.S. education department of Secretary Betsy DeVos to give states more leeway than the department during the Obama administration.

A coalition of Colorado education reform and civil rights groups is not happy that the department isn’t holding schools accountable to the testing requirement.

In a letter to the state education department, the coalition said it fears a lax approach to testing will incentivize schools to encourage some students who might not perform well on the tests to skip them.

“The 95 percent participation provision of federal law originated to protect students with the most barriers to success, specifically students with disabilities, by ensuring their inclusion in statewide testing,” the coalition wrote. “As such, we recommend the state count every student in participation rate calculations, including all nonparticipants to increase transparency and demonstrate a concerted effort to assess and report meaningful data about every child.”

That state law provides parents the right to opt out — something the state department doesn’t have authority to change — isn’t justification for the coalition.

“We believe that part of the department’s role is to elevate that conversation and to push on the importance of the 95 participation rate,” said Leslie Colwell, vice president of education initiatives for the Colorado Children’s Campaign.

The coalition is also concerned about changes to how the state measures how many students are at grade level, and how well students are learning English as a second language.

Starting last year, the state began measuring school quality by the average of student scores on the math and English test instead of how many students met or exceeded expectations. That practice is going to continue.

“We’re saying that as long as you’re not doing far worse than everyone else, you’re good,” said Van Schoales, CEO of A-Plus Colorado, a nonprofit education reform group. “We’ve lowered the bar.”

Schoales said using the mean score could be beneficial, but it should be accompanied by how many students are meeting the state’s expectations.

Colorado’s plan lacks long-term goals for English language learners. That’s because the standards for English proficiency and the tests that measure how well students are learning the language are changing.

Those goals are expected to be established in the next year or two.

Going forward, schools will be required to test kids in core content areas who’ve been in the U.S. less than a year if they know English well enough. If they don’t know enough English, they won’t be tested in English or math. Right now, that decisions is left to school districts. ESSA requires practice to be consistent, thus it was part of the plan development.

That, however, could lead schools to test students who aren’t ready in the hope they’ll show greater academic growth the second year they test.

“The process of going through a high-stakes test can be challenging and frustrating for a student,” said Luis Poza, a board member of the Colorado Association of Bilingual Education. “It can be fairly harmful to their self-esteem.”

One of the more robust debates during the formation of the plan was how the state should spend federal money to improve schools. The committee that helped draft the plan was split on whether the funds should be handed out on a formula basis or through a competitive grant process.

The education department, searching for a compromise, developed a new application that is designed to match a school’s need with the appropriate support — which could be monetary or not.

Ross Izard, senior education policy analyst at the Independence Institute, a libertarian think tank, said the hybrid approach is a step in the right direction but the state could have gone further.

“We had an opportunity to take that money and really place big bets on strategies that can really work,” he said.

Pat Chapman, executive director of federal programs for the state education department, said the department received nearly 500 comments on the state plan and 21 letters from a variety of interest groups. He said the department updated the plan where it could, but said some suggestions were either outside the scope of the department’s authority or weren’t allowed under the new federal law.

“I know not everyone is going to be thrilled,” Chapman said. “But I do think it’s a good plan. And we’re considering it a living, breathing document. We plan to keep working with folks to develop the details.”

The department expects to file the plan to Washington after it receives feedback from the governor’s office and the state board takes a formal vote on the plan at its April meeting.

Correction: This article has been updated to reflect that school districts have discretion over how English language learners are tested.