Tennessee has work to do on its plan to reboot the state’s schools in accordance with a new federal law, says a group that champions education equity for students of color.

In a letter sent Thursday to Education Commissioner Candice McQueen, members of the Tennessee Educational Equity Coalition cited assets and shortcomings of the state’s proposed education plan in response the new Every Student Succeeds Act, or ESSA.

The group applauded the state’s attention to historically underserved groups like racial minorities. It also likes that criteria for judging schools includes data on chronic absenteeism, as well as the availability of “early postsecondary opportunities” like career certification or AP classes.

However, though the state’s first draft is almost 300 pages, the coalition wants more details on components such as community engagement and school performance.

Members also expressed concern that some students of color will fall through the cracks if schools aren’t held accountable for the performance of individual groups. While ESSA’s predecessor, No Child Left Behind, was widely derided, it had one popular aspect — requiring that schools and districts break out the performance of subgroups including racial minorities, economically disadvantaged students, and special education students. That gave decision-makers a clearer picture of whether schools and districts were serving all students. ESSA still requires that states and schools report subgroup performance, but gives leeway on how that information is used to hold them accountable.

In the state’s draft, black, Hispanic and Native American students will be grouped together in cases where schools have fewer than 30 students in any of those groups, in what the state calls a “super subgroup.”

“Super subgrouping distinct student groups in this manner misleadingly signals that these student groups are homogenous, and obscures key differences in context, history, and needs that can inform more effective intervention strategies,” the letter reads.

The coalition is comprised of members of civil rights organizations and educators, and was formed in 2016 to address chronic disparities in opportunities for Tennessee’s students of color. From its start, the group has been involved with the drafting of Tennessee’s plan, even speaking about their priorities with U.S. Secretary of Education John King last summer in Nashville.

The group’s letter calls ESSA “landmark legislation that offers great promise to fulfill the civil rights aims of the Elementary and Secondary Education Act of 1965.”

The Department of Education is taking feedback on its draft during the coming weeks, with plans to submit its final plan by April to the U.S. Department of Education.

Read the letter here: