Additional Public Comment Sought for Preschool Development Grants Competition

Updated March 24, 2014. Thank you to those who submitted comments on our March 10, 2014 Homeroom Blog regarding the $250 million for the new Preschool Development Grants competition, appropriated in the FY14 Consolidated Appropriations Act, 2014 (Public Law 113-76).This input will be considered as we develop competition requirements, priorities, and selection criteria consistent with the language in the FY 2014 Consolidated Appropriations Act, 2014 (Public Law 113-76). In a few weeks, we will post an Executive Summary and provide an opportunity for additional Public input.

Public Meeting

When:   Thursday, March 20, 2014 from 3:30 p.m. – 5:00 p.m.

Where: U.S. Department of Education
Potomac Center
10th Floor Auditorium
550 12th Street SW
Washington, D.C.

You may also view the live streamed session at Thursday, March 20, 2014 from 3:30 p.m. – 5:00 p.m. at  http://edstream.ed.gov/webcast/Play/06af25dead644f46b2e786e7683e87051d

Deputy Assistant Secretary for Policy and Early Learning Libby Doggett (ED) and Deputy Assistant Secretary for and Inter-Departmental Liaison for Early Childhood Development Linda K. Smith (HHS) will attend to listen to your ideas on the new competition. Please consider the questions listed below for the Homeroom Blog in preparing your remarks.

If you are interested in speaking during the meeting, you must register by sending an e-mail to: PreschoolDevelopmentGrant@ed.gov on Thursday, March 13, 2014 from 9:00 a.m. to 5:00 p.m. ET.

E-mails received outside of this time period will only be accepted as space allows. Requests for speaking will be honored on a first come, first serve basis. A confirmation will be sent two days prior to the meeting. For attendees not speaking, reservations are not required. Persons who are unable to attend the meeting in person or who do not register early enough to speak during the meeting are encouraged to submit written input on this blog.

For security purposes, all speakers and attendees are reminded to bring a photo ID and a business card.  Please allow ample time to go through security.

Speakers

Your email must include the term “Preschool Development Grants Public Meeting” in the subject line of your e‐mail and indicate the following in the body of your cover email:

  1. Name(s) and title(s) of attendees from your organization (only one speaker per organization)
  2. Cell phone and e-mail for each attendee

The format for the Public Meeting will be as follows: 

  • Speakers will be given 3 minutes to address the group.  Time will be strictly enforced.
  • Speakers are encouraged to limit their comments to the Preschool Development Grants competition and may choose to address one or more of the questions listed below in the Homeroom Blog section.
  • In addition, all individuals and organizations are strongly encouraged to submit input in writing (electronic form preferred) by Friday, March 21, 2014, at 5:00 pm ETD.
  • Depending on the number of persons who wish to speak, we may not be able to accommodate everyone.

This is an important opportunity to provide input to the Departments. We hope you can join us. 

Please submit opinions, ideas, suggestions and comments pertaining to the new competition below. We are particularly interested in your input on these questions:

  • How should the competition address the direction in the Conference Report to the FY14 Consolidated Appropriations Act for awards to be made to two types of grantees:  low-capacity States with small or no State-funded preschool programs and high-capacity States that have a larger State-funded preschool program?
  • How should subgrantees that are early learning providers demonstrate strong partnerships with local education agencies and how should local education agencies demonstrate strong partnerships with early learning providers?
  • How should States distribute funds within the State in order to scale-up of proven preschool models in local communities?
  • What factors should we consider, if any, in distinguishing State applicants based on their past commitment to early learning and/or participation in federal or state grant programs, e.g., success or lack of success in previous related grant competitions, current federal support for early learning, or past State investment in early learning)?
  • How can we use these grants to support a more streamlined system of high-quality programs and services for children across the birth through age five continuum?
  • What can we do to encourage the sustainability of services after the grant ends (e.g. encouraging or requiring nonfederal matching funds, maintenance of effort provisions, or supplement not supplant policies)?
  • What kind of absolute, competitive or invitational priorities should we consider in designing the competition?

This document will be posted for public input until 5:00 PM ET on March 21, 2014, at which time the input section will be closed and we will begin considering comments received as we develop requirements, priorities, selection criteria, and definitions. Once the initial input from the field is collected and reviewed, we will draft an executive summary and post for comments that will, in turn, inform the final NIA.  In order to run a rigorous competition and obligate funds to grantees before December 31, 2014, ED plans to waive rulemaking on this new program, pursuant to its authority in the General Education Provisions Act.

This is a moderated site.

That means all comments will be reviewed before posting. We intend to post all responsive submissions on a timely basis. We reserve the right not to post comments that are unrelated to this request, are inconsistent with ED’s Web site policies, are advertisements or endorsements, or are otherwise inappropriate. To protect your own privacy and the privacy of others, please do not include personally identifiable information such as Social Security numbers, addresses, phone numbers or email addresses in the body of your comment. For more information, please be sure to read the “comments policy” tab at the top of the Web page.

The fine print

Please understand that posts must be related to the new competition and program, and should be as specific as possible and, as appropriate, supported by data and relevant research. Posts must be limited to 1,000 words. All opinions, ideas, suggestions and comments are considered informal input. ED and HHS will not respond to individual posts, and these posts may or may not be reflected in the policies and requirements of the program. If you include a link to additional information in your post, we urge you to ensure that the linked-to information is accessible to all individuals, including individuals with disabilities. Additionally, please do not include links to advertisements or endorsements; we will delete all such links before your comment is posted.

Again, thank you for your interest in this historic opportunity to support high-quality preschool. We look forward to hearing from you.

Department of Education’s linking policy

Department of Education’s disclaimer of endorsement

 

46 Comments

  1. The Council for American Private Education (CAPE) is once again pleased to submit to the Departments of Education and Health and Human Services comments regarding the Preschool Development Grants competition. These comments supplement those we submitted during the first comment period (http://www.ed.gov/blog/public-comment- sought-for-new-competition-to-build-develop-and-expand-high-quality-preschool- programs/comment-page-1/#comment-372229).

    RESPONSE TO QUESTIONS POSED BY THE DEPARTMENTS

    Should the grants support a more streamlined system of high-quality programs for children across the birth through age five continuum?

    If streamlined implies a uniform system of look-alike programs, our answer is no. There is no single combination of activities, lessons, methods, and settings best suited for all children in all circumstances. Children are different, and no government has the wisdom to prescribe exactly how, and under what conditions, children should develop.

    Most policymakers profess the value of diverse approaches to early education, yet many states and programs prescribe a single formula for quality and compliance. The problem is not theoretical and abstract; it is real and concrete.

    Take Montessori education, universally recognized as a time-honored, successful, high- quality approach to education. Countless Montessori programs across the country are running into QRIS or ECERS prescriptions that undermine their pedagogy and theory of child development. Their professional development, training, and credentialing programs are not recognized; their multi-age groupings are considered problematic; bed designs and classroom decorations become an issue, as does the use of real-life materials like glassware; even their reality-based, rather than play-based, philosophy often runs afoul of a state’s vision of what the ideal preschool should look like.

    Recommendation:

    While the federal government should not determine the specifics of a state’s early education program, it should require, as an explicit condition for receiving a grant, that a state’s quality rating system, professional development requirements, training and credentialing requirements, curriculum guidelines, even health and safety standards respect and accommodate a variety of truly distinctive approaches to quality early education, including those practiced by Montessori programs, faith-based programs, and Waldorf programs.
    Moreover, the development of these standards and requirements should only be done in consultation with representatives from the diverse early education community.

    As another way to respect diversity in early education, the grant program should award competition points to states that recognize accreditation in lieu of licensing requirements or other restrictive standards. If an established national or regional accrediting body (or an established state validation system) has approved a program, states should waive additional measures that could prove to be an excessive burden on providers or even interfere with their essential mission.

    How should subgrantees demonstrate strong partnerships?

    There is widespread concern within the early education community that a school-based early learning program will essentially be an application of traditional K-12 practices, objectives, and institutions to children of a younger age. Having the nation’s public education system take over early learning is neither feasible nor desirable. Our nation is blessed with an abundance of effective early education resources and programs that should not be overlooked or discarded in an effort to expand the availability of pre-K.

    Recommendation:

    The strong partnerships envisioned by this program between private providers and school districts should not suggest the absorption of one program by another, but should be limited to dialogues about promoting the availability of new programs and opportunities among families, the sharing of resources when appropriate, and discussions about learning objectives, philosophies of child development, and instructional practices.

    PUT PARENTS IN CHARGE OF PRE-K

    It is the responsibility and right of parents, the child’s primary educators, to rely on love, instinct, values, and observation to determine the setting and style of early instruction that best meets their children’s needs.
    The only significant child care measure likely to pass both chambers of Congress this session is the reauthorization of the Child Care and Development Block Grant (CCDBG) program. A central goal of the program is “to promote parental choice to empower working parents to make their own decisions regarding the child care that best suits their family’s needs.” That goal is optimized through the use of child care certificates, which afford parents the flexibility to choose among the widest range of child care providers and services, including faith-based options. According to the Office of Child Care at the U.S. Department of Health & Human Services, 90 percent of children served through the CCDBG program are served through the use of certificates (www.acf.hhs.gov/programs/occ/resource/fy-2011-ccdf-data-tables-final-table-2).

    Recommendation:

    Rather than encouraging states to prescribe precisely how early education should be carried out, the awarding of points in the competition should encourage states to provide resources, such as child care certificates, to empower parents to make their own decisions regarding child care. States can do so while still advancing quality as is demonstrated by S. 1086, which the U.S. Senate approved March 13 by a vote of 97-1, and which reaffirms the use of certificates through the CCDBG program.

    BACKGROUND

    The Council for American Private Education (CAPE) is a coalition of 18 national organizations (listed at http://www.capenet.org/member.html) and 35 state affiliates serving private elementary and secondary schools. There are 33,000 private schools in the United States; one in four of the nation’s schools is a private school. About 5.5 million students (10 percent of all PK-12 students) attend them. CAPE member organizations represent about 80 percent of private school enrollment nationwide.

    The National Center for Education Statistics (NCES) estimates (http://nces.ed.gov/programs/digest/d13/tables/dt13_202.10.asp) that of children enrolled in pre-primary school programs in 2012, including nursery school, preschool, and kindergarten, 45 percent of three-year-olds and 36 percent of four-year-olds were enrolled in private programs.

    More information about CAPE’s position on early education is available at .

  2. The Council for American Private Education (CAPE) is once again pleased to submit to the Departments of Education and Health and Human Services comments regarding the Preschool Development Grants competition. These comments supplement those we submitted during the first comment period (http://www.ed.gov/blog/public-comment- sought-for-new-competition-to-build-develop-and-expand-high-quality-preschool- programs/comment-page-1/#comment-372229).

    RESPONSE TO QUESTIONS POSED BY THE DEPARTMENTS

    Should the grants support a more streamlined system of high-quality programs for children across the birth through age five continuum?
    If streamlined implies a uniform system of look-alike programs, our answer is no. There is no single combination of activities, lessons, methods, and settings best suited for all children in all circumstances.

    Children are different, and no government has the wisdom to prescribe exactly how, and under what conditions, children should develop.
    Most policymakers profess the value of diverse approaches to early education, yet many states and programs prescribe a single formula for quality and compliance. The problem is not theoretical and abstract; it is real and concrete.

    Take Montessori education, universally recognized as a time-honored, successful, high- quality approach to education. Countless Montessori programs across the country are running into QRIS or ECERS prescriptions that undermine their pedagogy and theory of child development. Their professional development, training, and credentialing programs are not recognized; their multi-age groupings are considered problematic; bed designs and classroom decorations become an issue, as does the use of real-life materials like glassware; even their reality-based, rather than play-based, philosophy often runs afoul of a state’s vision of what the ideal preschool should look like.

    Recommendation:

    While the federal government should not determine the specifics of a state’s early education program, it should require, as an explicit condition for receiving a grant, that a state’s quality rating system, professional development requirements, training and credentialing requirements, curriculum guidelines, even health and safety standards respect and accommodate a variety of truly distinctive approaches to quality early education, including those practiced by Montessori programs, faith-based programs, and Waldorf programs.

    Moreover, the development of these standards and requirements should only be done in consultation with representatives from the diverse early education community.

    As another way to respect diversity in early education, the grant program should award competition points to states that recognize accreditation in lieu of licensing requirements or other restrictive standards. If an established national or regional accrediting body (or an established state validation system) has approved a program, states should waive additional measures that could prove to be an excessive burden on providers or even interfere with their essential mission.
    How should subgrantees demonstrate strong partnerships?

    There is widespread concern within the early education community that a school-based early learning program will essentially be an application of traditional K-12 practices, objectives, and institutions to children of a younger age. Having the nation’s public education system take over early learning is neither feasible nor desirable. Our nation is blessed with an abundance of effective early education resources and programs that should not be overlooked or discarded in an effort to expand the availability of pre-K.

    Recommendation:

    The strong partnerships envisioned by this program between private providers and school districts should not suggest the absorption of one program by another, but should be limited to dialogues about promoting the availability of new programs and opportunities among families, the sharing of resources when appropriate, and discussions about learning objectives, philosophies of child development, and instructional practices.

    PUT PARENTS IN CHARGE OF PRE-K

    It is the responsibility and right of parents, the child’s primary educators, to rely on love, instinct, values, and observation to determine the setting and style of early instruction that best meets their children’s needs.

    The only significant child care measure likely to pass both chambers of Congress this session is the reauthorization of the Child Care and Development Block Grant (CCDBG) program. A central goal of the program is “to promote parental choice to empower working parents to make their own decisions regarding the child care that best suits their family’s needs.” That goal is optimized through the use of child care certificates, which afford parents the flexibility to choose among the widest range of child care providers and services, including faith-based options. According to the Office of Child Care at the U.S. Department of Health & Human Services, 90 percent of children served through the CCDBG program are served through the use of certificates (www.acf.hhs.gov/programs/occ/resource/fy-2011-ccdf-data-tables-final-table-2).

    Recommendation:

    Rather than encouraging states to prescribe precisely how early education should be carried out, the awarding of points in the competition should encourage states to provide resources, such as child care certificates, to empower parents to make their own decisions regarding child care. States can do so while still advancing quality as is demonstrated by S. 1086, which the U.S. Senate approved March 13 by a vote of 97-1, and which reaffirms the use of certificates through the CCDBG program.

    BACKGROUND

    The Council for American Private Education (CAPE) is a coalition of 18 national organizations (listed at http://www.capenet.org/member.html) and 35 state affiliates serving private elementary and secondary schools. There are 33,000 private schools in the United States; one in four of the nation’s schools is a private school. About 5.5 million students (10 percent of all PK-12 students) attend them. CAPE member organizations represent about 80 percent of private school enrollment nationwide.

    The National Center for Education Statistics (NCES) estimates (http://nces.ed.gov/programs/digest/d13/tables/dt13_202.10.asp) that of children enrolled in pre-primary school programs in 2012, including nursery school, preschool, and kindergarten, 45 percent of three-year-olds and 36 percent of four-year-olds were enrolled in private programs.

    More information about CAPE’s position on early education is available at .

  3. Where there is a high quality early learning facility (profit, non profit or Head Start) that truly understands and implements best practices (ECERS, CLASS, TPOT, etc.), funding should be given to a willing “lead preschool” to train nearby early learning centers willing to learn and grow in “best practices”. This high functioning center should host seminars, open their model classrooms for observations, and guide these “centers/ preschools” to various agencies/resources that will help them grow in quality. Funding should be given to “lead centers” for consulting work, training material and supplies and travel stipend. Proven learning facilities doing the consulting work would need to submit partnerships with local educational agencies. This “micro method” would be a great opportunity for quality learning centers to demonstrate, encourage, and grow learning facilities in their local communities. Facilities willing to grow & partner with a “high functioning learning facility” should receive incentive funding ($15,000 each) to improve their classrooms’ environment (meet ECERS or ITERS requirements) and a one time ($12,000) “health and safety” improvement funding to fix a need (roof, broken concrete, peeling paint. etc…).

  4. How should the competition address the direction in the Conference Report to the FY14 Consolidated Appropriations Act for awards to be made to two types of grantees: low-capacity States with small or no State-funded preschool programs and high-capacity States that have a larger State-funded preschool program?

    In the low capacity states expansion monies should be applied for staff trainings (ECERS, CLASS, TPOT etc.), one time funding for durable classroom furniture to meet ECERS or ITERS standards, and college tuition “stipend” reimbursement for directors, teachers, and assistants that seek early childhood degrees. Low capacity states need to have their infrastructure strengthened first in these areas (environment, best teaching practices, and staff/director support in formal education) that directly impact children. In high capacity states, funding should go to enrollment slot expansion for proven quality learning facilities that provide services to low and moderate income families. One time expansion funding for architectural fees, engineering fees, and any building permits would encourage facilities to expand. Also, one time “major improvement repairs” should be considered for high-capacity states. These repairs may include leaky roof repair/replacement, proper playground upgrades (cushion surfacing, age appropriate play equipment, and/or safety enclosed fencing), and most importantly, school security upgrades. In high capacity states where a quality learning facility can prove enrollment needs and have contractual partnerships with the Department of Education, Department of Families and Children, and other local agencies 80% expansion funding should be considered for the total cost. Learning facilities that are non profit, for profit, or Head Start must be eligible to compete for this funding. The main criterion includes “best practice techniques” through various early childhood rating scales (ECERS, QIRS, CLASS, TPOT, etc…) and a stable financial budget. Facilities must prove they have funding to cover salaries, benefits, consumable material supplies for classrooms, and other facility costs, i.e. utilities. High Quality Preschools who are willing to expand into neighboring cities or counties that do not high quality collaborative early care, should be given “extra points/higher consideration” in the competitive grant.

    How can we use these grants to support a more streamlined system of high-quality programs and services for children across the birth through age five continuum?

    If monies are dedicated to classroom physical expansion in a private learning facility or non- profit center, the classrooms should meet all physical structural requirements to meet Infant/Toddler use. The CO (Certificate of Occupancy) for (I-2) classroom use is more stringent than preschool (E) use. It is easier to transform an approved Infant/Toddler classroom to a Preschool classroom than vice versa. As a result, funds will be maximized. Learning facilities must be well versed on the structural requirements. This will allow the learning facility to be versatile in meeting the demands of these two age groups. In addition to the structural requirements, facilities’ classrooms should meet the public school size requirements for early care.

  5. Thank you for taking the time to hear the public’s concerns and insights regarding the development of this grant.
    When you define the parameters of this competition, I strongly urge you to think about the implementation that has previously occurred. Many triumphant steps have been taken towards increasing quality and access in early learning. We, in the field, are proud of the work being done. This does not mean it has occurred without glitches in policy interpretation, application and measure. Montessori and Waldorf schools in particular are having substantial difficulty with regulation application and interpretation. Despite schools being accredited and having accredited trained teachers, some pedagogical and philosophical attributes do not fit in the “box” of “model” programming (depending on who is doing the interpretation. Please keep these communities eligible for this and future competitions by carefully assessing the language provided to grantees and their subcontractors. These Montessori and Waldorf communities are options that are well suited for the communities you support and want to serve these families. They simply must not be denied access to one another because they have been excluded from eligibility due to policy language. Thank you for your valuable time!

  6. Comment from Deborah A. Gist and Elizabeth Burke Bryant, Co-Chairs, Rhode Island Early Learning Council. The Rhode Island Department of Education and Rhode Island KIDS COUNT previously provided comments that address most of the questions that were put forth by the Department. We are now writing in response to Question 1 — “How should the competition address the issue of making awards to two types of grantees — Low capacity States with small or no State-funded preschool programs and high-capacity States that have a larger State-funded preschool program?”. We think the competition should prioritize expanding small, high quality, mixed-delivery state pre-k programs, with funding that can be used over a few years. We know that it is high quality programs that achieve improved child outcomes, and therefore it is very important that funding from this competition be used to help expand small, high quality state pre-k programs to increase their capacity to serve more children who are being left out. Regarding question 3, “How should States distribute funds within the State in order to scale-up proven preschool models in local communities?”, we urge the Department to allow states with high quality state pre-k programs that are already up and running to be able to continue using existing mechanisms for awarding funds for state pre-k expansion. In Rhode Island’s case, the State Department of Education awards funding directly to mixed delivery programs that meet high quality criteria through a competitive process.

    Deborah A. Gist and Elizabeth Burke Bryant, Co-Chairs, Rhode Island Early Learning Council

  7. The Early Learning Division at the State of Oregon thanks you for the opportunity to provide comments on the design and criteria for the Preschool Development Grants Competition.

    We respectfully submit the following for consideration:
    o In your criteria for partnerships at the local and state level, look for existing infrastructure that supports collaboration. An example would be Oregon’s Early Learning Hubs which are self-organized consortiums with statutorily designated authority to integrate early learning services across systems and traditional geographic boundaries. While communities have the flexibility to design their own operational model and set of strategies, each Hub shares the following responsibilities:
     Identify children at risk of arriving at kindergarten unprepared for school;
     Work with families to identify specific needs;
     Connect families to the supports or services that most meet their needs;
     Work across traditional silos; and
     Account for outcomes collectively and cost effectively.

    This example partnership spans across all of the sectors that touch young children and their families including health, home visiting, early learning, K-3 and human services. Furthermore there is concrete evidence of action resulting from partnerships, such as: shared/aligned goals across programs and sectors, progress on those shared goals, and/or braided funding across programs and sectors. Finally, the partnership is supported by existing, demonstrable funds (private and public) dedicated to pre-K through 3rd grade collaboration.
    o Favor states that have historically made serious, significant financial commitments to preschool programs, are currently implementing a quality framework through a QRIS, and are actively engaged in system building and efforts to streamline and coordinate services across sectors.
    o Funding should not be restricted to expanding existing models, but rather allow States that have existing programs to innovate, potentially support multiple models, and thoughtfully design services and delivery with considerations to their QRIS and local system-building and coordination efforts.
    o Related to this request for innovation is the need for seed funding to demonstrate results and for this reason we would request the Preschool Development Grant Competition not require new matching dollars.
    o And finally, do not penalize states for current involvement in Race to the Top. The aim of the Preschool Development Grant is substantively different in purpose and in scope. Our current involvement in the Early Learning Challenge provides us with the foundational infrastructure to expand access to high quality preschool learning environments as indicated through our QRIS.

  8. Comments by National Center for Montessori in the Public Sector on Preschool Development Grants

    The National Center for Montessori in the Public Sector (NCMPS) represents 455 Montessori programs operating in the public sector, serving children from birth through eighteen. We are pleased to be participating alongside our colleagues from the American Montessori Society, the Association Montessori Internationale, and the Montessori Public Policy Initiative.
    Together, we represent a movement In the U. S. that serves more than 201,00 children from birth to age 5, and more than 504,000 children overall. Approximately 125,000 Montessori students are in the public sector, serving tens of thousands vulnerable families.

    The Montessori approach to education exemplifies best practice in early learning, as measured by recent research on social, emotional and cognitive development. The core practices defining high quality Montessori education – seamless programming from birth through age 5, extended work periods for exploration, discovery, and mastery, mixed age grouping, and an integrated focus on social, emotional, and cognitive development – are shared by other developmental approaches.

    Today, I would like to specifically address your request for comment on using the grants toward a more streamlined system of high quality services for children across the birth to five continuum, an effort that we fully support. We recommend that the RFP include the following design elements as Competitive Priorities in order to support programs such as Montessori that are, in fact, specifically designed to fully and seamlessly support children through that crucial 0 – 5 age span.

    1. An uninterrupted early childhood continuum – Seamless programming from birth through Kindergarten is a cornerstone of many developmental approaches to early learning. Currently 0-3 programming and PreK/K programming are run out of different departments and are subject to different funding, regulatory, and oversight systems. Proposals that explicitly seek to smooth this gap should be given priority.

    2. Mixed-age classrooms— The research on executive functions, social and emotional development, and linguistic development is clear: mixed age grouping provides superior opportunities for early learning, and programs that include this feature as part of their design should be given competitive priority.

    3. Braided funding streams— Give preference to proposals that 1) creatively mix private and public dollars and 2) articulate processes for institutions dealing with multiple departments and funding streams. To achieve financially viable, fully integrated programs, we ask that regulations allow programs to draw on a mix of means-based tuition and public dollars. In this way, programs will be able to integrate rather than segregate students across socio-economic lines. Braided funding streams also includes facilitating access to public funding that spans across what are now the aforementioned imposed breaks between programs run out of HHS for 0 – 3 and the DOE for ages 4 on.

    In addition to the above comments on a seamless 0-5 continuum, we would like to respond to the requirement that programs be high quality and proven effective. This is a necessary standard on which we can all agree. To this end, we request that the RFP recognize quality through a diversity of programs and approaches. Here, I will speak directly to Montessori programming and where, though proven effective, it runs counter to conventional policies and regulations.

    • Teacher qualifications— Recognize accredited Montessori teacher training for 3 – 6 year olds as meeting most, if not all, the requirements for professionals working with this age group. Montessori teacher training is a rigorous program blending child development, classroom practice and Montessori theory. MACTE accredited Montessori training programs are already recognized by the DOE, and this recognition should be extended to preschool and programs run out of HHS.
    Program evaluation and accountability—Allow for program evaluation tools that are appropriate for assessing the quality of the unique Montessori setting

    • Student:Teacher ratio—flexibility in student:teacher ratio that takes into account the unique role of the teacher, environment and mixed-age classroom and allows for a larger student:teacher ratio (of up to 28:2 in a 3 – 6 year old classroom) than in conventional settings.

    • Classroom environment—environment assessment tools that are either designed specifically for Montessori classrooms or are flexible enough to recognize that some of the supplies, materials and activities one might look for in a conventional setting are not appropriate in a Montessori setting and vice-versa. For example, a Montessori classroom provides a language rich environment through the materials rather than word walls and nurtures creativity through open-ended work rather than dress-up corners.

    • Formative assessment – attention to teacher observation and detailed tracking of student progress.

    • Outcomes – attention to observable behaviors such as student engagement, independence and focus and developmentally appropriate measurable outcomes at the end of the 3-year cycle.

    One approach to paving the way for inclusion and expansion of developmental approaches, like Montessori, would be to create guidelines flexible enough to encompass the above. Another would be to recognize fully implemented Montessori as a high quality preschool program that would include all of the points above.

    While we recognize that the current funding proposal strictly addresses high quality preschool for 4 year olds, we are heartened to see the committee’s commitment to the full 0 – K continuum, and it is our deepest hope that the regulations and practices that come out of it support rather than preclude an ultimate vision for a continuum of uninterrupted, highest quality, family and child education for ages 0 – K and beyond.
    Every child should have access to highest quality care and education in a racially, ethnically and socio-economically diverse setting without families needing to renegotiate applications, resources, settings, schedules or systems as their children grow.

    Thank you for listening to our concerns.

    Endnotes:
    1. See resources at http://www.public-montessori.org/resources/does-it-work-what-research-says-about-montessori- and-student-outcomes
    2. Lillard, A.S. “Preschool children’s development in classic Montessori, supplemented Montessori, and conventional programs,” Journal of School Psychology 50:379-401 (June 2012)

  9. ADDITIONAL AMERICAN LIBRARY ASSOCIATION COMMENTS ON PRESCHOOL DEVELOPMENT GRANTS

    The American Library Association (ALA) is pleased to submit additional comments on the development of the Preschool Development Grants program.

    There are over 16,400 public libraries, in every corner of this country, staffed by literacy professionals who deliver services tailored to the needs of each community and are available to all members of the community, regardless of economic status. According to the most recent national survey of public libraries conducted by the Institute of Museum and Library Services, public libraries offered 3.75 million programs to the public. The survey found that the majority of these programs (61.5 percent or 2.31 million) are designed for children aged 11 and younger; attendance at programs increased 21.9 percent since FY 2005; and circulation of children’s materials has increased by 28.3 percent in the last 10 years and comprises over one-third of all materials circulated in public libraries.

    While our nation’s public library systems are equipped to deliver critical early learning resources to young children and families, in far too many instances across the country, libraries are NOT able to participate in the patchwork of early childhood education grants and are NOT considered as a resource in helping to design the policies and practices that link children and their families to early learning initiatives.

    In spite of significant budget restraints and difficulties in coordinating with publicly-funded early learning efforts, libraries are working at the local level across the country to help support and complement early learning efforts.

    Accordingly, ALA is encouraged that the Department is seeking additional comments on the development of strong partnerships under the Preschool Development Grants program. In general, ALA believes that the new program should incentivize a more coordinated and flexible system that would help improve our early learning efforts without “recreating the wheel” and in a way that maximizes current early learning efforts across the country, such as those taking place in our public libraries. In particular, ALA recommends that the Preschool Development Grants program recognize our contributions to the development of early learning initiatives and specifically include libraries as eligible entities and/or allowable partners.

    Our public library system stands ready to help improve early childhood education across the country, but we can only do so if policies are crafted in a way that allows for better collaboration, coordination, and real partnerships between libraries and the various federal early learning programs.

    Thanks again for the opportunity to provide additional comments related to strong partnerships under the Preschool Development Grants program. Please do not hesitate to contact me if you have any additional questions or need any information regarding ways in which our nation’s libraries can help to improve our early learning system.

    Emily Sheketoff
    Executive Director of the Washington Office
    American Library Association

  10. BELL is a national non-profit organization that exists to transform the academic achievements, self-confidence, and life trajectories of children living in under-resourced, urban communities. The organization was founded in 1992 and today, BELL is mobilizing a corps of more than 2,000 certified teachers and highly-trained tutors to educate almost 13,000 children, whom we call scholars. BELL operates two programs year-round, in the after school and summer settings, in an effort to help children excel. We rigorously monitor program quality and evaluate scholars’ academic gains by administering standardized pre- and post-program assessments to measure program outcomes.

    We are eager to help drive systems change to help ensure universal school readiness by kindergarten and respectfully ask you to consider our comments. We urge The Department to consider the importance of summer programming, particularly in the time between pre-school and Kindergarten. Without summer learning opportunities students tend to lose skills to summer learning loss. In fact, all young people experience learning losses when they do not engage in educational activities during the summer. Research spanning 100 years shows that students typically score lower on standardized tests at the end of summer vacation than they do on the same tests at the beginning of the summer (White, 1906; Heyns, 1978; Entwisle & Alexander 1992; Cooper, 1996; Downey et al, 2004). More than half of the achievement gap between lower- and higher-income youth can be explained by unequal access to summer learning opportunities. As a result, low-income youth are less likely to graduate from high school or enter college (Alexander et al, 2007). Tackling summer learning loss is a valuable strategy for academic success for low-income students and should be an option for our youngest learners. Any funding opportunities provided to State Education Agencies, Local Education Agencies or to the non-profit organizations should include summer as a possible strategy.

  11. Los Angeles Universal Preschool (LAUP) appreciates the opportunity to provide feedback regarding the new Preschool Development Grants Competition and has included answers below to the questions posed by the Department of Education.

    1) How should the competition address the direction in the Conference Report to the FY14 Consolidated Appropriations Act for awards to be made to two types of grantees: low-capacity States with small or no State-funded preschool programs and high-capacity States that have a larger State-funded preschool program?

    In the Conference Report referenced above, a high-capacity State is defined as one that has a “larger State-funded preschool program.” A “larger State-funded preschool program” should be one that provides access to quality preschool for a high percentage of the preschool age children in the state (who are not being served by other preschool programs). By contrast, a low-capacity state should have either no state-funded preschool program, or a program that serves only a small percentage of qualifying children. In addition, states in which a high percentage of children do not have access to quality preschool should receive more funding than other states.

    2) How should subgrantees that are early learning providers demonstrate strong partnerships with local education agencies and how should local education agencies demonstrate strong partnerships with early learning providers?

    An early learning provider and a local education agency can develop a strong partnership by creating an agreement that outlines desired program outcomes and defines the roles and responsibilities of each partner. With regard to individual roles, an LEA might be responsible for tracking student outcomes while an early learning provider might provide technical assistance to the LEA.

    3) How should States distribute funds within the State in order to scale-up of proven preschool models in local communities?

    Programs that have a track record of delivering quality services, practicing fiscal efficiency and leveraging local and state dollars should receive funding in order to scale-up their models.

    4) What factors should we consider, if any, in distinguishing State applicants based on their past commitment to early learning and/or participation in federal or state grant programs, e.g., success or lack of success in previous related grant competitions, current federal support for early learning, or past State investment in early learning)?

    In order to distinguish State applicants based on their past commitment to early learning, the Department of Education could consider evidence of state legislation, ballot initiatives, and programs created by school districts, state commissions and non-profit organizations that support early learning.

    5) How can we use these grants to support a more streamlined system of high-quality programs and services for children across the birth through age five continuum?

    A program should not be funded unless quality indicators are built into the program. In addition, any preschool program that is funded should have a family engagement component and a plan to create a high quality workforce.

    6) What can we do to encourage the sustainability of services after the grant ends (e.g. encouraging or requiring nonfederal matching funds, maintenance of effort provisions, or supplement not supplant policies)?

    The Department of Education could make the development of a sustainability plan a prerequisite for receiving funding. Sustainability plans might identify local and/or state resources and private donations as sources of funding and include strategies for capacity building. In addition, states that are unable to provide matching funds for federal contributions should not be penalized, particularly if they are states with a large percentage of high needs children.

    7) What kind of absolute, competitive or invitational priorities should we consider in designing the competition?

    The Department of Education should prioritize the development, expansion and enhancement of quality preschool programs. Programs that create access to preschool spots but have no quality requirements should not be funded. In addition, priority should be given to applicants with the capacity (in terms of staff, expertise and facilities) for implementation of grant requirements. In addition, successful applicants should have a good track record of program implementation. Finally, the Department could invite past Race to the Top grant recipients to apply for additional funding so that these recipients can continue and expand successful programs.

  12. On behalf of the America Forward Coalition (http://www.americaforward.org/), thank you for the opportunity to provide additional input on the development of the new Preschool Development Grants program.

    The America Forward Coalition is a network of more than 50 innovative, impact-oriented organizations, working in every State and in more than 900 communities nationwide, dedicated to driving systemic change in early childhood, education, and workforce development. America Forward Coalition members share a commitment to innovating to achieve better results, using data to track progress and ensure accountability, and leveraging resources across silos and sectors to improve the lives of the people they serve. Our Coalition organizations are achieving measurable outcomes in communities across the country every day. We believe that innovative policy approaches that spur innovation, reward results, and catalyze cross-sector partnerships can transform these local results into national change and propel all of America forward.

    We are eager to help drive systems change to help ensure universal school readiness by kindergarten and respectfully ask you to consider the following additional comments related to strong partnerships, innovation and evidenced-based programming as you develop the new Preschool Development Grants program:

    How should subgrantees that are early learning providers demonstrate strong partnerships with local educational agencies and how should local educational agencies demonstrate strong partnerships with early learning providers?

    Effective external partners provide a range of solutions that can help to deliver the full array of supports and assistance needed to remove barriers to learning and build teachers’ and leaders’ capacities that are critical to improving education systems and results for children. To help ensure strong partnerships, the America Forward Coalition believes that the Preschool Development Grants program should include partnerships that:

    (1) focus efforts on joint goals including increasing the outcomes of all students, erasing the achievement gap, increasing student engagement and time on task, and decreasing barriers to student learning;

    (2) provide evidence of success, including through supporting research and evaluation, providing documentation of successful implementation, and providing evidence of impact on outcomes;

    (3) focus on program implementation by utilizing a comprehensive implementation system including joint use agreements and a definition of roles for members of the partnership where appropriate, systematically monitoring quality, degree and pace of implementation, and explicitly planning for sustainability; and

    (4) monitor program impact and hold programs accountable by identifying specific impact indicators, providing instruments to collect impact data, and systematically monitoring impact data.

    How should States distribute funds within the State in order to scale-up of proven preschool models in local communities?

    To help scale-up proven preschool models, the America Forward Coalition believes that States should reward results by investing in what works. It is critical in a time of limited resources that we invest in a variety of approaches that focus on rigorous data, evidence and better results. In particular, the America Forward Coalition believes the Preschool Development Grants program should encourage evidence-based and effective reform strategies that include services and capacities that reduce barriers to learning, support the needs of the whole child, and build a culture for learning and growth.

    Accordingly, the America Forward Coalition recommends that the Preschool Development Grants Program include “pay for success” contracting as an option to help implement these strategies. Most public programs provide funding regardless of whether the service delivered is effective, as long as the provider follows the rules (serves eligible clients, provides the intervention specified in the manner required, spends money in accordance with regulations, etc.).

    Pay for Success flips the equation, linking payments to outcomes. Under this funding model, government dollars are paid out only if providers achieve intended results for the people they serve. The America Forward Coalition believes that programs designed to “pay for success” have several advantages:

    (1) by emphasizing outcomes rather than rules and regulations, fewer resources are wasted on compliance and bureaucracy so more funds can go to program delivery;

    (2) by focusing on results and creating incentives for cost-effective interventions, programs will emphasize more effective prevention strategies over remediation;

    (3) by providing flexibility in choice of intervention and emphasizing results, these designs encourage innovation to identify the most effective strategies; and

    (4) government, and therefore taxpayers, only end up paying for effective programs.

    What can we do to encourage the sustainability of services after the grant ends (e.g. encouraging or requiring non-federal matching funds, maintenance of effort provisions, or supplement not supplant policies)?

    Apart from a non-federal match, maintenance of effort, or supplement not supplant provisions, the America Forward Coalition believes that sustainability of services could be increased through innovative policies that seed innovation, extract what works, identify why it is successful, and take successful solutions to scale.

    Accordingly, we believe that the Preschool Development Grants program should be designed in a way that provides enough flexibility to States and school districts so that they can allocate funds towards what works for their students, including support for effective external partners. This also includes supporting technical assistance, data-sharing and capacity-building for districts, schools and community partners committed to working in integrated and coordinated ways to achieve positive student outcomes.

    In addition, the America Forward Coalition believes that the Preschool Development Grants program should include evidence-based early childhood activities that help to build cognitive and social/emotional skills aligned with school success and that lead to school readiness, with appropriate, comprehensive outcome measurements. Outcome data can help determine, and point resources to, the most effective programs, and increase the number and percentage of under-resourced and at-risk children in each age group of infants, toddlers, and preschoolers who are enrolled in high quality early learning programs.

    Thank you again for the opportunity to provide additional comments on behalf of the America Forward Coalition. Please do not hesitate to contact Deborah Smolover, Executive Director of America Forward at Deborah_Smolover@newprofit.com if you need any information or have any questions related to our recommendations.

    The America Forward Coalition Education Task Force

  13. The American Montessori Society thanks you for the opportunity to comment on the Preschool Development Grants competition.

    As you determine guidelines and standards for this competition, AMS would respectfully ask that grant awards be eligible to a diverse variety of early childhood education programs and models. Diversity in approach to early education enables parents to make the choice they believe to be best for their children.

    AMS supports innovative programming that provides a comprehensive continuum for serving children birth through age six. We support high quality in programming through evidence-based research demonstrating positive outcomes for all children. We acknowledge the role of teachers specially educated and prepared to provide for the needs of the young child and her family. And we believe in programming that is inclusive of children with special needs, those of diverse cultural and language backgrounds, and those who may be at risk due to socio-economic factors.

    Although Montessori education for young children has a long history, it meets all of the criteria for innovations that offer excellent early childhood education. An increasing body of research demonstrates the benefit and value from a fully implemented Montessori program. This includes our philosophy and theory of child development, our curriculum which is developmentally appropriate for children birth to six, and our specially educated teachers whose instruction and interaction with children is attentive to the whole child, is individualized, and is based on utmost respect for each child and her or his family.

    AMS understands the need for quality measures in early childhood education programs. The measures and systems used, however, must be accurate in their assessments and not result in the unintended consequences of obstacles to parent choice or philosophy of approach to young children. A variety of national accreditations, recognition of a variety of high quality teacher education credentials, and a diversity of methods and materials for reaching the goal of “best practice” should be provided for in the competition criteria.

    We urge you to include a variety of early childhood educators in designing this competition to assure that models such as Montessori, Waldorf, faith-based, and play-based are included in the criteria for innovative programming for young children.

    Thank you.

    Richard A. Ungerer, Executive Director, American Montessori Society

  14. The Children’s Defense Fund is pleased to supplement our earlier recommendations for the Race to the Top Preschool Development Grants program. Our recommendations below respond to the seven questions on which the Department invited input with questions one and four addressed in the first recommendation.
    • Maximize state inclusion in the grant program with special attention given to low-capacity states with no or a limited preschool program. All states have the opportunity to benefit greatly from this new investment in high quality preschool and no state should be excluded from applying for a grant. States with no or only a few high quality preschool programs that have the most progress to make should be specifically targeted for new funding to support planning, technical assistance, and preschool pilot programs. High-capacity states that already have an infrastructure established should be required to use the new funding to support expansion of access to high-quality preschool rather than systems building. States that have received a Race to the Top-Early Learning Challenge (RTT-ELC) grant should not be excluded from participation, but their activities under the preschool grants should be used for purposes separate from their RTT-ELC activities.
    • Require eligible local entities, whether local education agencies (LEAs) or other early learning providers in the community, including Head Start programs, to describe their partnership activities. States should include examples of features of mixed delivery systems but allow flexibility in the nature of local partnerships between schools and community providers. Local entities should be required to submit joint applications that describe the specifics of the partnership and how it will improve program access and the quality of care provided, including comprehensive services and family support and parent engagement. The Department and states should highlight localities with strong early childhood partnerships between LEAs and other community providers to encourage similar efforts in other communities.
    • Ensure funding is distributed within a state so as to prioritize access to high quality preschool for children in areas of concentrated poverty, and for children who have disabilities, are learning English as a second language, are homeless or are in foster care. For this purpose, concentrated poverty should be defined as districts eligible for the maximum weight in the determination for concentrated poverty in the Title I education program. As a condition of applying for a grant, a state should be required to provide a detailed plan, including a timeline, of how it intends to prioritize access to high quality preschool for all children in areas of concentrated poverty, with special attention to reaching rural or underserved areas, as it moves toward reaching children under 200 percent of the federal poverty line. High quality programs should track those described in the Strong Start for America’s Children Act and include comprehensive services and family engagement so these grants can act as a springboard for expansion of preschool access anticipated by the act.
    • Require states to submit a plan for aligning and coordinating preschool programs with other early childhood programs for children birth through 5 available within the state, including voluntary home visiting, Early Head Start, Head Start, child care, and full-day kindergarten. The plan should include the establishment of community-wide early childhood councils or other entities to promote the collection of data on children participating in these programs and the distribution of the programs by location within cities and within the state, and planning for transition from one program to another including from preschool to kindergarten.
    • Promote sustained services after the grant period ends by requiring a state to submit a preschool expansion and sustainability plan as part of its application for funding. The application should specifically address how the state will promote access to low-income children in the state beyond the grant period. All new funding provided under Race to the Top must supplement and not supplant existing funds. States should also be required to demonstrate maintenance of effort by maintaining current funding for all state-funded early childhood programs and those funded through flexible federal funding streams at the highest annual level of the last three years. Lastly, states must demonstrate that new funding for preschool will not hinder access to or quality improvement efforts in programs for infants and toddlers.
    • Specify absolute priorities for the competition should demonstrate a state’s commitment to developing a high quality system of early childhood development and learning for children birth through age 5. As discussed above, this should include the submission of plans to coordinate preschool programs with other early childhood programs across the continuum, expand preschool access to all low-income children and other children with special needs in the state, and to extend to children and families a range of comprehensive services and supports. States must also commit to using the new funds to supplement, not supplant, existing services and to maintaining current efforts in early childhood to be eligible to apply for funds.
    Competitive priorities should encourage additional quality practices in a state’s early childhood system. For example, priority in the competition for grant funds should be awarded to states with a plan, including a timetable, for giving priority access to children in areas of concentrated poverty and with other special needs. States that prioritize wrap-around supports for families and children and use family engagement practices such as modeling of positive parent child interactions should be given competitive priority. States that already mandate school districts to offer full-day kindergarten for all students and fund it as equal to first grade also should be given competitive priority to help ensure gains achieved in preschool are maintained.

  15. The Governor’s Office of Early Childhood Development in Illinois appreciates this opportunity to provide input into the design of the competition for supports for building, developing and expanding high-quality preschool programs. Below are our responses to your questions listed above.

    1. States should be eligible to apply for one piece of the funding and the criteria for low and high capacity states should be clear. A State should be considered high capacity based on its entire investment in early childhood not just preschool services. Additional investments could include Home Visiting and Special Education.

    2. States should have the flexibility to determine how strong partnerships are demonstrated. States should also have the flexibility to define the criteria for the partnerships. The focus of the partnerships should be to serve the highest need children in the highest quality setting.

    3. States should be given the flexibility to allow for multiple models based on existing State mechanisms. States should be allowed to expand current successful infrastructure approaches that will meet the needs of the highest need children. However, this time-limited money should not be expected to be spent primarily on expansion of direct services, but rather on building up components of the system such as workforce competence, technical assistance and monitoring systems, and comprehensive state- and community-level planning.

    4. States that have a proven record of success should be given preference. This includes states that are successfully implementing Race to the Top-Early Learning Challenge grants and Maternal and Infant Early Childhood Home Visiting grants.

    States should not be punished for past decisions on state investments, particularly during this period of limited state resources. Eligibility for awards should be based primarily on the quality of the state’s approach moving forward.

    5. Preference should be given to States that specifically articulate how the funds will be used to build a larger birth to five system. States should be given options to invest in quality improvement, access to services, and infrastructure.

    6. If a maintenance of effort provision is included, it should be forward looking. It should also be consistent and realistic. States should be able to include infrastructure and capital investments.

    7. States should receive preference for the following items.
    •Focus on high need children
    •Integration of programs and strengthening a birth to five continuum
    •Inclusion of bilingual children
    •Community support
    •Public/private partnerships
    •Recipient of a Race to the Top-Early Learning Challenge grant
    •Existence of a comprehensive Tiered Quality Rating and Improvement System

  16. Thank you for the opportunity to contribute to the process of determining criteria for the Preschool Development Grant funding. The Policy Committee of the Grow America Stronger campaign, a joint effort of many early education stakeholders including NAEYC, has published an excellent list of recommendations in planning for implementation of the Preschool Development Grant funding. Among their key points, I identify most strongly with the following:

    * Make funding available to all states. Give children throughout the country an opportunity to benefit from this funding.

    *Create a mixed delivery system for dispersing funds. Subgrantees should be chosen from a wide range of preschool providers–private, for-profit, non-profit, public schools, and Head Start programs. Including a diverse range of programs alleviates the problem of trying to accommodate more children in already crowded public school buildings, allows private preschools the opportunity to expand many of the high quality programs already in place, gives parents a choice for their child’s first school experience, and creates a community of expertise of early education professionals.

    *Adopt benchmarks for quality standards. In their annual report, “The State of Preschool,” The National Institute of Early Education Research (NIEER) has created a set of 10 benchmarks that effectively identify standards of excellence in preschool education: (1) comprehensive learning standards, (2) lead teachers with BA degree, (3) lead teachers with specialized training in preschool, (4) assistant teacher with CDA or equivalent, (5) a minimum of 15 hours of teacher professional development each year, (6) maximum class size of 20, (7) staff to student ratios of 1:10 or better, (8) vision, hearing, and health screenings provided with at least one additional support service offered to families, (9) at least one meal offered daily, and (10) ongoing site visits to monitor quality.

    *Set a priority for funding staff initiatives. Preschool teachers are the single most important factor in determining the quality of a preschool program. Our nation needs well-qualified, well-compensated early educators. Preschool teachers need to have salaries competitive with their public K-12 counterparts, tuition reimbursement, and stipends for ongoing professional development.

    *Encourage partnerships between local education agencies and preschool programs. Offering public school benefits to local preschool providers would provide a significant service that many preschools cannot afford independently. The public schools could also offer preschool programs with additional resources to support special needs students. Public schools would benefit from the partnership as well, with children and parents experiencing a more seamless transition from preschool into Kindergarten.

    In summary, I hope that this funding can help to support the creation of a network of high quality preschool programs nationwide, holding each program (private or public) to the same high benchmark standards of excellence. We need to supplement the funding for salaries and training to attract and retain excellent teachers in order to build excellent preschools. We need to reclaim our nation’s children from a perpetuating cycle of screen time and give them back the gifts of joy, wonder, curiosity, and play by providing them with more options for excellent preschools.

  17. ACSI Observations on Preschool Development Grants Competition, March 20, 2014

    The Association of Christian Schools International (ACSI) offers the following comments on the Preschool Development Grants Competition as requested by the Departments of Education and Health and Human Services. The responses are listed under questions posed by ED/HHS. Thank you for the opportunity to provide this input.

    ACSI is a nonprofit, non-denominational, religious association providing support services to nearly 24,000 Christian schools in over 100 countries. ACSI serves 3000 Christian preschools, elementary, and secondary schools; and 100 post-secondary institutions in the United States. Member-schools educate some 5.5 million children around the world, including 825,000 in the U.S. of whom just under 120,000 are in early learning. We are a leader in strengthening Christian schools and equipping Christian educators worldwide. ACSI accredits Protestant pre-K – 12 schools, provides professional development and teacher certification, and offers its member-schools high-quality curricula, student testing and a wide range of student activities.

    1. What factors should we consider, if any, in distinguishing State applicants based on their past commitment to early learning and/or participation in federal or state grant programs (e.g., success or lack of success in previous related grant competitions, current federal support for early learning, or past State investment in early learning)?

    The merit and quality of a state’s early learning programs, as well as the diversity of those programs, are likely better markers than merely past participation by a state in federal grants or in providing state grants in early learning. A key part of measuring merit ought to include respect for the broadest array of early learning programs including private and faith-based. For example, does the state ensure parents have access to all kinds of programs? Such factors might help to attract parents to available programs and thus build demand for more. Further, awarding points based on past participation of a state in federal programming could backfire by keeping new states from engaging when, after all, one purpose of the program is theoretically to expand early learning opportunities.

    2. How can we use these grants to support a more streamlined system of high-quality programs and services for children across the birth through age five continuum?

    ACSI questions whether a “streamlined system” of programs and services would always be in the best interest of the children who need early learning programs. Such a system suggests a one-size-fits-all approach to programs and services whereas allowing the greatest diversity possible in programming and provision of services would likely best drive creativity, excellence and new ideas.

    Streamlining, by contrast, is a good principle for the process of getting funds to the states and allowing them maximum flexibility. It could be used to reduce the difficulty states and providers face in managing grants and give states capacity for allowing greater parental engagement. One model of the latter could be based on the concept of certificates in the Child Care and Development Block Grant (CCDBG) Act which even faith-based programs could potentially accept. States, then, should earn competition points for creative approaches that maximize parental choice.

    With respect to promoting a diversity of services, states could earn points in the competition process when they recognize accreditation in lieu of licensing or other restrictive policies such as acceptance of only state-based training and/or state mandated curricula.

    Further, approval by an established national accrediting body would give states confidence in the program and give the state capacity to remove burdens that might otherwise keep faith-based and other non-government providers from engaging. Streamlining should not, after all, inadvertently be tantamount to absorption of non-public early learning into a single government-only system.

    We would also argue that utilizing existing, nationally-known, diverse quality assurance programs like existing accreditation models not only assures professional quality, but also assures diversity of mission and pedagogy with existing networks that can be ramped up quickly and with the efficient use of dollars that are maximized by utilizing the current private infrastructure.

    3. What can we do to encourage the sustainability of services after the grant ends (e.g. encouraging or requiring nonfederal matching funds, maintenance of effort provisions, or supplement not supplant policies)?

    An inherent challenge in any grant process is that, at some point, a grant comes to an end. It would be better to give parents the ability to buy services directly and to work to that end, again potentially using the popular, bipartisan CCDBG program as a starting point. Non-public early education has sustained itself over many decades on the basis of parental choice. This principle could allow for enhanced or expanded early learning and maximum sustainability of early education with diverse methodologies.

    Thank you for your consideration.

    Respectfully submitted,

    P. George Tryfiates
    Director for Government Affairs
    Association of Christian Schools International

  18. • What can we do to encourage the sustainability of services after the grant ends (e.g. encouraging or requiring nonfederal matching funds, maintenance of effort provisions, or supplement not supplant policies)?
    Nonfederal matching funds, maintenance of effort provisions, or supplement not supplant provisions can all contribute to sustainability, but none are sufficient to address the chilling effect funding cliffs have on innovation and true, lasting quality improvements. State or local matching funds are just as vulnerable to funding cliffs as federal dollars, and MOE provisions can fade over time. There is usually a legislative work-around for no-supplant policies, if lawmakers are so inclined. Sustainability is critical to lasting improvements, requiring applicants (perhaps as a competitive or invitational priority) to describe how they will use grant funds to develop aligned, coordinated, self-sustaining mixed-delivery systems using a defined approach (e.g., collective impact; BUILD Initiative system model) would promote a more fundamental sustainability solution. Such a priority would also allow for an evaluation of different approaches.

    • What kind of absolute, competitive or invitational priorities should we consider in designing the competition?
    In addition to a competitive or invitational priority for a sustainable system design, I believe the following should be top priorities:
    1. Statewide efforts to build an articulated, coordinated continuum from birth through age 8 including specific programs and/or initiatives to provide for seamless transitions from infant/toddler care to preschool settings and from preschool to kindergarten. Efforts that support educators (including administrators) across the Birth through age 8 continuum should be prioritized).
    2. Professional development initiatives that address all levels of the early childhood professional development system from high school career and tech ed, two and four-year colleges, through graduate school are essential to strengthening early childhood quality. Faculty development is often overlooked. It is assumed that college and university faculty have the capacity to adequately prepare early educators for increased levels of quality. This is not always the case. Many faculty would welcome the opportunity to strengthen their own skills to be better able to prepare their students for new, higher expectations.

  19. Maine Department of Education’ Responses to the
    Second Round of Federal Question on Public Preschool Programs

    • How should the competition address the direction in the Conference Report to the FY14 Consolidated Appropriations Act for awards to be made to two types of grantees: low-capacity States with small or no State-funded preschool programs and high-capacity States that have a larger State-funded preschool program?
    Allocate a portion of the total funds available for the grants to states with low capacity states with small or no State funded preschool programs, with a greater percentage to be allocated for States with high capacity States.

    • How should subgrantees that are early learning providers demonstrate strong partnerships with local education agencies and how should local education agencies demonstrate strong partnerships with early learning providers?
    Require States to demonstrate (document) the actual components of the partnerships that public preschool programs have with other community based agencies that are supported in a cross state agency fashion. Partner component details could reflect who funds the lead teacher, assistant teacher, facilities, and equipment with federal Part B Section 619, federal head start funds and local education agencies funds. In addition the partners should demonstrate the Memorandums of understanding the document the respective responsibilities of the partners in the implementation of the programs. On a state level the State agencies demonstrate the public policies and statutes that have support the collaborative partnerships, have an early childhood data system which has the capacity to track the impact of early childhood system variables on child outcomes that sustain into the k-12 system, and the percentage of the partnerships in the implementation of the total number of public preschool programs.

    • How should States distribute funds within the State in order to scale-up of proven preschool models in local communities?
    The States should fund programs that meet the State’s quality program standards which are reflected in statute or regulations and are supported in cross agency implementation.

    • What factors should we consider, if any, in distinguishing State applicants based on their past commitment to early learning and/or participation in federal or state grant programs, e.g., success or lack of success in previous related grant competitions, current federal support for early learning, or past State investment in early learning)?
    The important factors for consideration should be the State’s established history of state policy which supports the development of early childhood cross agency collaborative preschool programs and which reflects an established state funding formula that supports the public preschool programs once they have been established. Priority to states that have State funding Formula systems in place supported by State General Funds; but that need an infusion of funds to improve quality, establish supports to help teachers implement evidence-based skills and strategies to impact child outcomes.

    • How can we use these grants to support a more streamlined system of high-quality programs and services for children across the birth through age five continuum?
    Require the integration of public preschool programs with one or more partners that implement quality program standards recognized/supported by more than one state agency. Consideration could be given to use of grant funds for enhancements to the States’ Longitudinal Data systems to specifically track the impact of quality, integrated programs on child outcomes. In addition state that have developed cross state agency governance structures to streamline the implementation of programming across the continuum.

    • What can we do to encourage the sustainability of services after the grant ends (e.g. encouraging or requiring nonfederal matching funds, maintenance of effort provisions, or supplement not supplant policies)?
    There should be a requirement of a non-federal matching funds in the form of a state established funding formula.

    • What kind of absolute, competitive or invitational priorities should we consider in designing the competition? Competitive preference should be given to states that have not received RTT funds. Competitive priority should also be given to states that are developing early childhood components to their State Longitudinal data systems that will allow significant analysis of the quality indicators for child outcomes over time, which will drive the public policy direction in the states to significantly improve the quality of programs with valid, reliable data.

    Jaci Holmes
    Federal State Legislative Liaison
    Maine Department of Education

  20. Dear Secretaries Duncan and Sebelius,
    Thank you for the opportunity to comment. The Government of the U.S. Virgin Islands (“GVI”) is of the strong belief that the language in the Consolidated Appropriations Act of 2014 (providing funds for competitive grants to “States”), which is based on the ARRA definition, should be read by the U.S. Department of Education to achieve Congress’ intent: that intent, as reflected in the ARRA statute and legislative history, is that the Territories should be included equitably in all ARRA programs, and that Congress did not intend in the appropriations law to treat the Territories less favorably by precluding them from competing for ARRA Title 14 grants. As presently constructed and unless our interpretation is accepted by USDOE, the territories will be excluded from the participating in The Preschool Development Grants Competition. It is my hope that such exclusion does not occur.
    I would like to further suggest that there be a separate competition where the smaller outlying territories be allowed to compete among themselves rather than in the same pool with the 50 states, D.C. and Puerto Rico. Our unique differences in geography and size often diminishes our ability to be successful applicants. The Territories have made great strides in improving our systems for early childhood education and are deserving of a fair opportunity to improve the outcomes for our young children.

    Sincerely,
    John P. de Jongh Jr,
    Governor
    United States Virgin Islands

  21. Thank you for the opportunity to offer comments on behalf of the National Catholic Educational Association (NCEA) regarding the proposed Preschool Development Grants Competition. This topic is of great importance to NCEA since more than 3,200 of our Catholic elementary schools include Pre-K programs. That is apart from the hundreds of free-standing programs conducted under the auspices of the Catholic Church and affiliated agencies.

    1) Should the grants support a more streamlined system of high-quality programs for children?
    The operative word is “streamlined”.
    How is that to be interpreted? If it means a monolith, the answer is a resounding no. Diversity is a cherished value and hallmark of American civil society in which faith-based schools currently provide high quality pre-K programs for hundreds of thousands of students. To enact legislation or regulations that would diminish or eliminate the ability of these institutions to operate and deny families the opportunity to participate in existing faith-based education would be an injustice to them and ultimately to American society.

    The variety of programs currently available provides families with choices that reflect the families’ values in settings that are best for their own children. Children’s needs are different, and no one, apart from the family itself, should prescribe the conditions under which child development should take place. A single formula for determining educational quality and standards compliance is not good policy or practice.

    Our recommendation is that the federal government should require grant applicants to demonstrate that the state’s quality rating system, professional development requirements, training and credentialing requirements accommodate a variety of truly distinctive approaches to quality early education. Additionally, the development of state standards should only be done in consultation with representatives from the diverse early education community. States that recognize accreditation in lieu of licensing requirements should be allowed to waive additional licensing measures that might be burdensome on providers or interfere with their essential mission.

    2) How should states distribute funds within the state to scale-up proven preschool models in local communities?
    Rather than prescribing early education administrative criteria and curriculum for a diverse group of program providers, states should be encouraged to form strong partnerships between private providers and school districts as equal partners in providing a variety of distinct services to families. In promoting the availability of new programs as well as maintaining those successful programs in operation, the grants should be used to provide resources, such as child care certificates, to empower parents to make their own decisions regarding child care. In collaboration with local LEAs, certificates, such as those that have been provided to parents under the Child Care Block Development Grant program should be expanded.

    The National Catholic Educational Association has been providing leadership, direction and service to Catholic education since 1904. NCEA is a professional membership organization serving students in preschools, elementary and secondary schools, parish catechetical/religious education programs, diocesan offices, colleges, universities and seminaries.

  22. 1. This comment is about the partnership between the providers and schools. I am not sure what exactly the department is looking for in partnership, but a partnership to accommodate transportation, service and training would be great. The district provides transportation to the nearby centers and lets providers take part in teacher training. In order to give parents choices of providers, each provider should be able to partner with multiple schools and each school should be able to partner with multiple providers.
    2. This comment is about the distribution of funds within the state to promote proven model. Yes, it is a good idea, but it should come with initial and follow up training; otherwise, people will not know how to implement the model properly.
    3. This comment is about the past commitment and performance. I think all providers should be given a chance (old and new), but they should be monitored and provided support as needed to fix any issue they may have had in the past.
    4. This comment is about the high quality services. In my experience, more education doesn’t necessary mean higher quality. For quality service, a combination of education and experience should be considered.
    5. This comment is about matching funds. It is not a bad idea, but if matching funds are required, many providers may not be able to take part. We want to have as many options for parents as possible.
    6. This comment is about competitive priorities. I feel that it should be open to all providers (small and large, for profit and non profit). All providers need to be treated equally. Some applicants are able to partner with lots of people and gain more points but may or may not have higher quality of service. A combination of education and experience working with children may be given some priority points.

  23. The following question was posed: “How should States distribute funds within the State in order to scale-up of proven preschool models in local communities?” By definition, the answer to this is not via the bureaucratic public school system. Public school districts have yet to construct a preschool model that can be described as anything close to “proven”. The most disastrous outcome of all would be to see these well-intentioned funds absorbed into the already broken public school system. As the K-12 system evidences, the most surefire way to set this program up for failure would be to encumber it with unnecessarily onerous approaches to teacher compensation and advancement. Ultimately, the most important thing this program needs to get right is the attraction and retention of the highest quality educators within the realm of early childhood education. Making these funds available to a mixed-delivery system would ensure that market forces play an important role in the allocation of funds. Funds would flow to the highest-functioning programs, which in turn would be staffed by the highest quality teachers. (As any participant in early childhood education will attest, the only difference between programs is the quality of the teachers in the classrooms.) The best teachers would be attracted by competitive compensation and opportunities for ongoing career development. At Little Sprouts, an operator of 17 high quality early childhood education programs throughout Massachusetts and New Hampshire, this is our approach. We have been recognized by the U.S. Department of Education as a three-time recipient of the Early Reading First grant. While our view is admittedly biased, it is our strong belief that the most prudent path forward would involve programs like ours with demonstrated success over an extended period of time. Importantly, in the definition of a “proven” model, the emphasis should be on teacher compensation and teacher advancement. It is our earnest hope that decision-makers will avoid the path of least resistance – public schools – in lieu of an unequivocally superior mixed-delivery model.

  24. • How should the competition address the direction in the Conference Report to the FY14 Consolidated Appropriations Act for awards to be made to two types of grantees: low-capacity States with small or no State-funded preschool programs and high-capacity States that have a larger State-funded preschool program?
    Funds should be given to States with no funded preschool programs first because they are standing on their own in hard economic times. Title 1 school districts should get priority.
    • How should subgrantees that are early learning providers demonstrate strong partnerships with local education agencies and how should local education agencies demonstrate strong partnerships with early learning providers? Grant could include forms that the providers must get filled out by local education agencies stating past partnership and future commitments. Also state licensing inspection records for past three years to prove the program can follow and maintain basic regulations and COMAR. (If it can’t then it shouldn’t get funding.)
    • How should States distribute funds within the State in order to scale-up of proven preschool models in local communities? Title 1 areas consideration. Rural areas – where resources are less. ALSO centers that provide infant care, this is a program with added high expense despite higher tuition. These centers are providing care and learning for 5 years of the child – the target of the program.
    • What factors should we consider, if any, in distinguishing State applicants based on their past commitment to early learning and/or participation in federal or state grant programs, e.g., success or lack of success in previous related grant competitions, current federal support for early learning, or past State investment in early learning)? Should be part of Purchase of Care programs (funds for low income).
    • How can we use these grants to support a more streamlined system of high-quality programs and services for children across the birth through age five continuum? Don’t add to the requirements already in place by States for centers/teachers. Have separate funding to help center provide Infant and Toddler programs. (Very high cost in MD rural areas to operate with a 3kids to 1 staff ratio).
    • What can we do to encourage the sustainability of services after the grant ends (e.g. encouraging or requiring nonfederal matching funds, maintenance of effort provisions, or supplement not supplant policies)?
    • What kind of absolute, competitive or invitational priorities should we consider in designing the competition? )? Should be part of Purchase of Care programs (funds for low income). Title 1 areas consideration. Rural areas – where resources are less.

  25. •What kind of absolute, competitive or invitational priorities should we consider in designing the competition?

    What an exciting time to be an ECE professional! Please consider funding programs with a passion for:
    • Prioritizing people BEFORE technology
    o For instance: Technology may be a help but a laptop can’t comfort a sobbing little one who is terrified and misses her mom. Compassionate, informed and caring people MUST be at the heart of whomever you fund.
    • Knowing children and families from diverse walks of life
    • Understanding and demonstrating developmentally appropriate practice at the highest caliber, every day, all the time
    • Creating partnerships with high school students who are interested in pursuing a career in ECE
    • Making the ECE program a training ground for everyone: children, parents, partners, professionals and future professionals
    o For instance: MUCH lower than average adult to child ratios will allow all children and adults to truly cultivate relationships that matter. We need to stop pretending that young children can “thrive” when there are 15 peers in front of them waiting for attention or desperate for a hug…. If we are going to re-invest my tax dollars into my life-long passion and career, let’s do this in a manner that truly honors the profession and what brought me into the field so many years ago… This is about CHILDREN. High ratios make it all about $$.
    o For instance: Training and professional development is ongoing, shared between hands-on coaches, practitioners, parents and students (high school & college) and sustained in small learning communities who celebrate successes!

  26. The achievement gap is well established before children enter school and directly related to prenatal, post birth health and wellness practices of mothers and families. It is also related to child rearing practices, particularly of poor and non English speaking families. These practices impact the cognitive and emotional development of these children.
    The intervention has to be focused on a continuum of services starting prenatally through entering prekindergarten or kindergarten with the eligible entities being the state, county or city government because the K-12 enterprise owns the problem only when the child enters the school. Home-based programs and developing strong parenting skills to meet the expectations of schools must be the funding priority.

  27. Miss Doris Thomas, M. Ed. is very interested in creating an Educational Television and Reading Literacy program for the preschool students in the Philadelphia School System. More importantly, we can provide internet streaming services and Vimeo for students who are Special Needs students, Military students, and students who need remedial instruction. Philadelphia Public Access Corporation has access to Comcast Channel 66, 966 and Verizon Fios Channel 29 & 30. We are seeking an innovation and improving literacy grants for the development and planning of these effective Television and Internet services for Regular education populations and Special Needs populations.

  28. I am writing from the San Francisco Office of Early Care and Education. We are excited to see the implementation of $250 million in Race to the Top (RTT) funds to develop, enhance, or expand high-quality preschool programs. Research demonstrates that children who receive high-quality early care and education experiences are more likely to have more advanced language, academic and social skills. Ensuring availability, affordability and quality of early care and education provision for children birth to five years is critical.
    With this in mind we would request that the following recommendations be taken into consideration when determining funding opportunities and priorities:
    • Local early care and education systems should be recognized, and not disrupted. A mixed delivery system should be encouraged as a means of providing high quality early education services. Permissiveness in the application does not ensure that a mixed delivery system will be established or built upon. Some direction through specific language in the application regarding a mixed delivery approach should therefore be included.
    • The expansion of high-quality programs should take into account the provision of full day/full year services in order to best meet working families’ needs.
    • States should be required to include family engagement practices in all funded preschool programs. Some guidance and direction for applicants regarding nationally recognized family engagement standards should be included.
    • Workforce investments are an essential component of the funding in order to provide high-quality programs. Building upon state professional development systems and career ladders, funds should support the meaningful higher educational pathways of early care and education teachers and directors.
    • High-quality early care and education experiences are essential, particularly for those families with the highest needs. In order to ensure access to high-quality programs, local funding recipients should be participating in the state’s QRIS where one exists, or be held to specific quality criteria.
    • Funding could be made available to support data integration between various early care and education programs (Head Start, school districts, community providers, etc.) in order to better identify child outcomes and needs throughout many settings in the same community.
    • Language should be included that encourages the inclusion of Resource and Referral agencies and local early care and education planning councils in determining local needs and priorities.
    • RTT funding has no allowance for early care and education facilities but our local experience in San Francisco has demonstrated that facility investment is critical. A federal strategy to address this issue, in order to enable the expansion of educational services for young children, would be worth exploring.

  29. ADDITIONAL WATERFORD INSTITUTE COMMENTS ON
    PRESCHOOL DEVELOPMENT GRANTS

    On behalf of the Waterford Institute (http://www.waterford.org), thank you for the opportunity to provide additional comments related to the design and implementation of the Preschool Development Grants program.

    The Waterford Institute is a nonprofit research center founded in 1976. Waterford’s mission is to provide every child with the finest education, through the development of high-quality educational models, programs, and software. An important concept at Waterford is combining technology and education to battle the achievement gap. Research over the past two decades has shown that without early intervention, an achievement gap develops between at-risk and average students, and the gap increases exponentially during the early years of education.

    We believe the solution to closing the achievement gap is early intervention with the right tools. Waterford Early Learning programs provide a solid foundation for preschool, kindergarten, and grade-school students early, before the obstacles to learning overwhelm them. Whereas traditional instruction can only target the approximate needs of the average student, computer-based courseware imparts a highly specified curriculum that is thorough and rigorous but is also adapted to each student’s learning needs. Waterford’s programs ensure mastery of core concepts by individualizing instruction to meet the needs of each student. By intervening early, and using the combined strengths of technology, teachers, families and students all working together, the Waterford Institute is working to ensure that each student, regardless of primary language or beginning level of literacy, is prepared for success.

    Strong Partnerships

    The Waterford Institute is encouraged that the Department is seeking additional comments on how local educational agencies and early learning providers can demonstrate strong partnerships.

    Waterford believes that schools and early learning programs cannot achieve the results that are demanded of them and that students deserve if they are working alone. College and career ready expectations require that our educational system provides additional, aligned services – such as more time for learning, early interventions, parent engagement, professional development for educators, tutoring, and related activities – and our current system does not have the capacity to do them all well.

    High-quality partnerships can help to expand, deepen and accelerate learning – and external partners that have a track record of success and bring additional expertise and resources to the table can make a significant difference in the lives or our children. Accordingly, the Waterford Institute asks that the Preschool Development Grants program support effective partnerships that will help to ensure that students receive a better array of supports and assistance needed to remove barriers to learning, improve our educational systems, and help the children that need it most.

    Scale-Up and Sustainability of Services

    To help scale up effective programs and encourage sustainability of services after the grant ends, the Waterford Institute believes that the Preschool Development Grants program should explicitly support approaches and partnerships that utilize technology to personalize learning. The Waterford Institute uses technology to promote the academic success of every child by providing access to software designed to provide individualized, interactive instruction that ensures mastery of materials:

    – Technology is Scalable – One great teacher can instruct only a handful of students every year; software can take that knowledge and teach almost a limitless number of students.

    – Technology Provides Equity – All children, regardless of family means, should have access to the best education. Unlike standard schooling where schools and faculty can lack uniformity in terms of quality and talent, software makes it possible for the poorest children to have the same high-quality teaching available to them as the wealthiest children have.

    – Technology Provides Individualized Instruction – Software adapts to a child’s learning trajectory and ensures every activity is specifically chosen for that child’s needs, challenges, and strengths.

    – Technology is Artistically Engaging – Beautiful graphics, music, and interactive activities keep children focused on learning.

    – Technology is Generationally Appropriate – Today’s children are “digital natives” and adapt quickly and easily to software-based instruction.

    – Technology Provides Instantaneous and On-Going Assessment – Testing can be seamlessly interwoven into the software curriculum and provide invaluable assessment and reporting functions.

    – Technology is Cost-Effective – The scalability of software reduces per-hour instruction expenses to mere pennies.

    – Technology Offers Accessibility – Children can receive instruction far beyond the 180 days of the traditional school year.

    Priorities

    In developing priorities for the Preschool Development Grants competition, the Waterford Institute recommends that the Department include a competitive preference priority for applicants that include partnerships with early learning providers that have the ability to bring expertise and experience to this new program, including “mission-focused” providers that address specific early childhood development issues such as cognitive gains for preschool students.

    In addition, since the Preschool Development Grants program will be developed and implemented in significant part by the Department of Education, Waterford believes that it would be appropriate to also include an invitational priority for applicants that can demonstrate meaningful cognitive gains for children that participate in the program.

    Finally, while serving children in center-based, early childhood education programs in rural areas is challenging, Waterford believes that technology and family- or home-based solutions can help to reach these children in a cost-effective manner. Accordingly, Waterford believes that the Preschool Development Grants program should include a competitive preference priority for applicants seeking to serve rural areas.

    Thank you again for the opportunity to provide additional comments on the Preschool Development Grants program. Please do not hesitate to contact me if you need any additional information or have any questions related to our recommendations.

    Dr. Benjamin Heuston
    President
    Waterford Institute

  30. Please have the grantees consider the significant impact that very low literacy levels of far too many of our country’s early childhood educators is having on children’s ability to read at grade level. Without financial backing to provide these workers with a concrete way to pay for ABE/ESL support, young children will not be kindergarten ready or able to read when they reach 3rd grade. This is especially true for our most disadvantaged children.

  31. Massachusetts has a successful track record with respect to the allocation of public funds to help increase quality and accessibility within a mixed delivery system of early education and care. Lead Education Agencies oversee the expenditures in a way that requires community involvement, rewards innovation, and builds collaboration. A key component has been to require the implementation of programs that enhance the development of parents/guardians as first teachers as well as providing for the learning needs of young children. One of the most successful and unique programs to evolve out of this state model is called Play School, where children and families play and learn together in a moderately structured, high quality early childhood setting appropriate for children ages 0-6 years. In Clinton, MA, Play School has become an essential partner to traditional preschool/child care modes, helping to ensure that all children in our community have access to enriching experiences during these most critical years of development. This model warrants further study and, ideally, pilot replication in other communities – the funding for which could be built into the design of these federal preschool development grants. http://www.clinton.k12.ma.us

  32. What kind of absolute, competitive or invitational priorities should we consider in designing the competition?

    * Consider the key findings of the National Early Literacy Panel. The six identified-variables precursors to later literacy achievements are: Alphabet Knowledge (AK); Phonological Awareness (PA); Rapid Automatic Naming (RAN); RAN of objects or colors; writing or name-writing; and phonological memory. The other five that are moderately predictive to later literacy achievements are: concepts about print; print knowledge; reading readiness; oral language proficiency; and visual processing.

    For Deaf and hard of hearing children and children with cochlear implant who use American Sign Language (ASL), consider interactive print production activities with high-quality instructional practices in writing. That is the challenge but can be done.

    Make sure all video products as the result of this grant is accessible to Deaf and hard of hearing viewers. In this case for any educators who are Deaf and hard of hearing. Provide caption enabled features and/or provide transcripts.

    Thank you for considering my comments and good luck with this exciting project.

  33. It is a given that licensing, accreditation (health and safety), professional teachers, child-teacher ratios, and better pay, all contribute to high-quality preschool and impact children entering kindergarten ready to learn. It is not a given that high-quality preschool should be absorbed into the K-12 bureaucracy.

    An absolute priority for the initial round of funding should require that states do not extend the K-12 bureaucracy to birth to five. This provides the best opportunity for a more streamlined birth to five system. (This would not preclude a PK-12 data system.)

    Low capacity or no prior state-funded programs that design birth to five programs that serve children through established social services agencies that are aligned with early child care and education services should oversee the administration of the states’ preschool programs and funding. Low capacity and no prior state-funded programs that are not a part of the K-12 bureaucracy should be awarded preference points for equal footing with high capacity programs that do not extend the K-12 bureaucracy to birth to five. There should be no penalty for low capacity or no prior state-funded programs if the design does not extend K-12 to birth to five. LEAs have enough to do already to improve what they do within the confines of teacher unions and the whims of school boards. This is an opportunity for a streamlined system for birth to five that truly keeps the needs of the children first.

    LEAs’ monopolistic and silo propensities are not conducive to strong partnerships with outside programs. Proven models should be recognized and supported through strong partnerships with early child care and education social services agencies who have a far greater propensity for effectively working with children and families.

    After the initial round of funding, proven models should be sustained through SEA Title 1 funding. LEA Title 1 funds required for special education and remediation should be greatly reduced.

    It is imperative that proven models, including from private providers, are recognized, included, supported and replicated in partnerships with appropriate social services agencies. Proven models should be a competitive priority as they represent present and past investment, even in low capacity states or states with no prior state funding.

    It cannot be overemphasized that this is an opportunity to prepare children for the K-12 bureaucracy before they are directly and intimately impacted by it.

  34. I am asking that serious thought and consideration be given to what children need from birth to thrive, excel so the children are empowered to give us the answers to the unknown. Parents need to know how to nurture their child’s God given talents, gifts and intelligence. Before leaving the hospitals with their child, before becoming parents education must be a mandatory step. I am a retired educator/social worker. Having worked forty years professionally, with two year old preschoolers to young adults in regular classroom settings and as a special educator. There is a great deal of data that demonstrates the importance of teaching all stakeholders(parents/caregivers) the value of an education, preparing the needed support within the child’s environment to plant the seeds that will activate the child’s potential. We keep coming up with programs to fix our need to academically challenge and motivate our children. Studies show the importance of parent/caregiver involvement or where there is a home structure that does not work, the children have been removed and planted in nurturing learning environments. I am not speaking of social service programs. What works Is ensuring the safety of children, providing stimulation, teaching motivation/values to help them use their gifts, talents and energy. As a teacher we were constantly introduced to new strategies, techniques that someone developed to improve scores, & learning . I am a teacher that made home visits, remained late at school, spent time in student homes helping parents understand how to impact and inspire their child’s life. Consideration should be given to components that include Mentoring and strong relationships building that provide training for educators to learn how to work with all children within the classroom. All teachers need to know how to identify children having special needs and how to modify instruction to accommodate children’s needs. Although support personnel come into the classroom, the classwork teacher must be knowledgeable. Teachers must learn how to captivate the interest and creativity of children and teach them to become life long learners who care about making life better. Consideration must be given to youth development complimenting academic curriculums. Our children are not machines.

  35. As a retired preschool and elementary school teacher, it is very encouraging to read all the above comments!
    There is a definite need for all the requests made.
    My only request is that there is sufficient observation of the programs and the grants received to insure that the children are the ones benefitting from the funds.
    I have seen and heard of scattering of funds and directing money to other than prescribed requirements for children.
    FIRST SAFETY PRECAUTIONS, of children’s health, physical safety, referring to child ABUSE and NEGLECT.
    Teachers must be told to REPORT any evidence of neglect and abuse and PARENTS must observe classes to see if teachers are using appropriate measures of behavior control.
    Teachers need to attend STRESS retreats and sessions and supervisors must be able to deal with teacher problems.
    PARENTS; Remember your precious children are in the hands of teachers for many hours every day!!!!

  36. As an early learning practitioner, educator and family advocate for the past 40 years, I certainly support all the previous comments. In Ohio, we have made a strong commitment through the Step Up to Quality (SUTQ) rating system to expand the availability of high quality early learning programs to as many children as possible in publicly funded programs and family child care environments. Communities such as Cincinnati & Dayton have public/private partnerships that are encouraging local Kindergarten Readiness Collaboratives. Unfortunately, Catholic schools still have a difficult time accessing funding and other resources to serve the increasing number of low income, at-risk and ESL children who attend their preschools. In the Archdiocese of Cincinnati, which covers 19 urban, rural and suburban counties, that’s more than 2,000 preschoolers. There are clear directives as to how we interface/partner with our public districts to access K-12 services, but there really are no guidelines for how we can collaborate with them for professional development, assessments and data collection. If County and State reports indicate that a certain % of children are kindergarten ready or reading at third grade level without including the thousands of students in Catholic and other parochial schools, how can we have an accurate measure of the success of our efforts to help kids succeed? I would like to see the new legislation encourage states to explore opportunities to include faith-based preschools in their community initiatives.

  37. My research has consistently shown that preschool children in high fidelity Montessori, including public Montessoris serving low-income populations, do extremely well on tests of executive function as compared to lottery-loser or matched controls. Executive function is the set of skills underlying self-regulation and goal-directed action and is the since best predictor we have of success in life (see for example Moffitt et al. (2011). I would urge careful consideration for more public high-fidelity Montessori programs.

  38. I agree with Beena and Debbie Smith on the importance of training community-based early childhood workers. One of the difficulties of sustaining a quality, research based program is the turnover in the industry and the lack of training. The turnover is the result of low wages. Grant funds could help to address this by including a requirement for a stipend to be paid to employees who participate in a long-term, training program that has a proven track record of improving worker quality as evidenced by student learning outcomes. The higher salary will likely attract more stable workers and help to reduce turnover.

  39. Since this is a competitive grant, this grant must be awarded to not just any program that aspires to offer high quality preschool program, but one that integrates 2 crucial required components that impact long-term sustenance of high quality early childhood education. These are: (1) Investment in professionalization of non traditional workforce and or teachers who must have early childhood credentials as required by the state; and (2) Parent education.

  40. My hope is that the territories will be able to participate is this opportunity. We in the US Virgin Islands have made great strides through interagency collaboration to build the infrastructure that supports high quality. We would be in the group of those that have low to no state funding for preschool, mostly due to economic factors, not because of a lack of interest or will. Support to move forward would go a long way for us to continue the work and to provide high quality preschool experiences for our children.

  41. All of the preschool programs should be required to meet more than the minimal health and safety standards in their state Licensing Regulations but adhere to national health and safety performance standards established by Caring for our Children (CFOC): National Health and Safety Performance Standards, 3rd Edition, 2013. This is a wonderful opportunity to support quality child care by promoting health, early identification of children with special health care needs, and promoting early intervention. CFOC promotes a holistic program of health including behavioral health, environmental health, nutrition and physical activity, and prevention of infectious diseases and injuries.

  42. I encourage the Department to assure that the grantees carefully consider collaboration with their Part B and Part C partners for purposes of supporting children with disabilities in programs that are being developed. It is critical that we continue to build inclusive options rather than compartmentalizing programs.

  43. These grants should be distributed to programs that have demonstrated the ability to create beautiful environments that support High Quality care & education only through a verified process. In San Diego County CA this is the Quality Preschool Initiative, managed by the San Diego County Office of Education. This program has the capacity for building large High Quality provider network that is supported by educators with access to the latest research so that hard working providers gain access to information without skipping a high quality learning beat! This community partnership is diverse and includes all providers across a huge spectrum from faith-based, non- profit, for-profit, head start & state-funded preschool. It is also time to begin braiding funding so that children for. Lower income families are not SEGREGATED into programs that only serve “the poor!” Children are neither rich nor poor and deserve to attend school with everyone in their community! You can find more information on the SDCOE website! Why reinvent the wheel when this model of delivery would cut out all of the useless paperwork and grant writing and deliver services county by county with verified quality using research-based methods that are supported by every national, state and local early learning organization in America! Let’s use the funds to provide services to children and get rid of OZ and the man behind the curtain theatrics that waste funds desperately needed by little developing brains… Our future!

  44. I think support and training for early childhood teachers and helping to develop programs will provide the greatest impact long range. Many teachers in early childhood programs have very little education and centers have very few resources. It would be very beneficial to put together a program that focuses on helping teachers provide developmentally appropriate experiences and provide materials to deliver such a program. It is also important to add a component to evaluate the program within each center to ensure effectiveness and efficiency. This will allow the grant recipients to adjust their programs to maximize the results.

    • Exactly. Finding creative ways to help those who are DOING the job now learn how to do it better. I would hope that rural areas would be given priority points or have a set-aside numbers of awards as they also tend to have fewer partners to help prepare an application. In larger areas, a requirement to integrate professional development with college credit to lead to a degree (and hence justify salary increases). Rural programs can utilize online learning options but funding needs to be set-aside to provide onsite mentors to support non-traditional learners (the current instructional staff) succeed in a college course.

  45. Please have the grantees consider how the state will create inclusive preschool environments and how they will use universal design for learning strategies to assure that young children with disabilities are supported. I would suggest a requirement to show how the grantees will collaborate with the Part C and Part B programs in a state to assure that programs do not become siloed.

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