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This article analyzes five states’ interpretations of the school improvement portion of the Every Student Succeeds Act (ESSA) passed in 2015. It utilizes critical policy analysis to frame states’ improvement plans, including guidance given to districts for selecting human capital management reforms, evidence-based strategies, and partnerships with educational intermediaries. Findings highlight that states often lack the capacity to meet the federal requirements set by ESSA and use external partnerships to fill this capacity gap with varying levels of guidance given to school districts on partnering with intermediaries. This has implications for understanding states’ and districts’ capacity for school improvement and the way public funds are often used by private organizations.