By mid-January, the scramble to upload components and double-check ISBNs fades, replaced by a quieter kind of tension. The Texas Education Agency has begun its first deep reviews. Evaluators are working line by line through every component, tracing evidence, and flagging anything that cannot be verified. Those who have lived through earlier cycles recognize this stage as the calm before the reckoning.
The January 16 voluntary withdrawal deadline draws a thin, merciful line for anyone realizing their program is not ready. For those who stay, the days that follow become a test not of content but of infrastructure. It is here, between submission and scoring, that the quiet mistakes begin to surface.
The Illusion of Alignment
Teams spend months writing, cross-walking, and designing correlation tables meant to prove mastery of the TEKS. Yet year after year, reviewers note the same pattern matrices that read as promises rather than proof. The Texas IMRA process is explicit: each indicator requires concrete, traceable evidence. A correlation that gestures toward alignment but does not anchor its claim to an exact page, lesson, or assessment is treated as no evidence at all.
Even the most established publishers, some with twenty or thirty years in national markets, find themselves rewriting correlations and adding components late in the cycle. Their teams are accustomed to state reviews that value intent; Texas values verification. Many assume that a legacy product, proven across multiple states, should already satisfy these expectations. But the TEA rubrics do not honor tenure; they honor compliance.
The programs that succeed are those that accept early that Texas is different and adapt accordingly. They build alignment guides that shadow TEA’s own correlation workbooks, audit every citation, and confirm that each TEKS strand appears in at least two verifiable places.
Suitability: The Standard of Proof
The SBOE’s 2024 Suitability Rubric changed the landscape. What once existed as an afterthought is now the end-of-process confirmation that materials were age-appropriate and has become a parallel measure of excellence. Section 2 of the rubric requires positive evidence that materials promote patriotism, Texas history, and democratic understanding. Category 6 addresses sexual risk avoidance with the same precision once reserved for phonics alignment. Reviewers now flag not only what is present but what is missing.
Long-established publishers have learned that this rubric can expose complacency faster than any other. Programs built for national adoption often rely on general civic content or imported language about community and culture. In Texas, that is not enough. The SBOE rubric expects evidence of alignment with Public Education’s Constitutional Goal, codified in TEC § 4.001(b). Every reference to citizenship, enterprise, or history must tie directly to that constitutional mission.
The most forward-thinking publishers now conduct suitability-alignment audits before submission. These audits map each suitability indicator, such as 2.1.1 on patriotism, 2.1.2 on the treatment of violence, and 2.1.3 on civil order, with corresponding lessons or teacher notes. Some have even added short civics connections or instructional prompts to meet the guidance head-on. Suitability is not about avoiding errors; it is about demonstrating intentionality.
The Rise of the Internal Audit
In my experience, the strategy that has proven most effective is migrating publishers from emergency reviews to proactive systems. What once occurred only after a rejection now begins before a single file reaches the TEA. These audits are no longer confined to content teams as they draw from editorial, production, design, and data management, creating a shared accountability structure that mirrors how the state itself reviews. Three forms of internal auditing have become indispensable.
- First, standards-alignment audits are designed to ensure that each TEKS element has at least two concrete examples. Second, suitability-alignment audits to verify compliance with the SBOE rubric and
- Texas Education Code § 28.0022
- Third, appeals-preparation reviews are designed not to anticipate failure but to prepare documentation that can clarify any future misunderstanding.
In 2024, the programs that improved scores in the re-review phase were those that could show a logical trail of how feedback was received, where corrections were made, and how new evidence addressed specific indicators. It wasn’t the eloquence of their response that convinced reviewers; it was the clarity of their recordkeeping.
What Endures
When the State Board of Education meets from January 28th through 31st, the conversation will be about materials, but what the board will really be measuring is discipline. The programs that move forward will be those whose internal systems reflect the same rigor that Texas demands externally.
The lesson of this season is simple but rarely learned early enough: excellence in Texas is not achieved through brilliance but through structure. Internal audits prevent collapse. Suitability guides ensure fidelity. Appeals binders document accountability. And one dedicated manager, maintaining the Navigation Guide, anchors the entire operation.
Building the Modern Audit Culture
| Function | Primary Responsibilities | Timing Within the IMRA Cycle | Key Deliverables and Practices |
|---|---|---|---|
| Standards Alignment Lead | Oversees all TEKS correlations and confirms that every indicator includes two verifiable examples supported by citations. Coordinates across grade bands to ensure internal consistency. | Begins in pre-submission phase and continues through the first TEA review. | Maintains the standards-alignment guide mirroring TEA’s correlation workbook. Conducts internal audits prior to Form B submission and again before appeals |
| Suitability Reviewer | Interprets and applies the SBOE Suitability Rubric (Categories 2 and 6). Works with editorial staff to ensure content reflects Texas Education Code § 28.0022 and § 4.001(b) | Starts during early content development and remains active through public review. | Develops and maintains a suitability-alignment matrix connecting lesson-level content to indicators 2.1.1–2.1.3 and 6.1–6.4. Provides written documentation of evidence for each indicator. |
| Accessibility & Compliance Specialist | Ensures all print and digital materials meet MSST (2024) and WCAG 2.1 AA standards. Verifies that documentation is ready for TEA pre-approval. | Continuous early verification recommended before component upload. | Completes third-party accessibility reports and maintains version-controlled documentation showing resolution of all findings. |
| Navigation Guide Manager | Serves as custodian of the TEA-issued Excel workbook listing all program components and ISBNs. Ensures consistency between submitted files and EMAT entries. | Begins immediately after Form B submission and continues through final approval. | Validated Navigation Guide with confirmed ISBNs, component cross-references, and notes on any TEA-requested adjustments. |
| Appeals Coordinator | Leads evidence organization for re-review and appeal phases. Tracks reviewer feedback and prepares responses supported by documentation. | Activated upon receipt of scoring reports preparation begins months earlier. | Maintains an appeals binder linking each indicator to corresponding artifacts, reviewer notes, and response narratives. Coordinates resubmission within TEA deadlines. |
| Internal Audit Director | Integrates all above roles, sets timelines, and leads cross-departmental meetings. Reports directly to leadership on readiness and risk. | Throughout the full IMRA cycle, beginning at program inception. | Produces comprehensive readiness reports before each milestone (Form B, component upload, correlation submission, appeal). Guides continuous improvement across cycles. |
