Development Grants Executive Summary

Updated May 18, 2014: Thank you to those who submitted comments on the draft executive summary for each of the Development Grants competition and the Expansion Grants competition. We will consider this public input as we develop competition requirements, priorities, and selection criteria for a notice inviting applications, which will be published in the Federal Register later this summer.

Note: Updated on May 14, 2014 with information about the data source the Departments used to develop funding bands.

Posted May 5, 2014

States with small or no State-funded preschool programs will be eligible to apply for Development Grants. We intend for high-quality preschool programs to be located in regionally diverse communities or consortia of communities in cities, towns, counties, neighborhood, districts, rural areas, or tribal lands, with a high level of need or distress as determined by the State.  High-quality preschool programs funded under either category of the Preschool Development Grants will need to meet the competition’s criteria for high-quality preschool programs. Other preschool programs within the State will not be required to meet these criteria.

This document will be posted for public input until 5:00 PM EDT on Friday, May 16, 2014, at which time the input section will be closed and we will begin considering comments received as we develop final requirements, priorities, selection criteria, and definitions. We will also be holding a webinar to review the executive summaries.  Further information will be posted on the Preschool Development Grant Web page. We will publish these requirements, priorities, selection criteria, and definitions in a notice inviting applications in the Federal Register later this summer.

This is a moderated site; all comments will be reviewed before they are posted.  We reserve the right not to post comments that are unrelated to the Preschool Development Grants competition, are inconsistent with ED’s Web site policies, are advertisements or endorsements, or are otherwise inappropriate.  Please do not include links to advertisements or endorsements, as we will delete them before we post your comments.  Additionally, to protect your 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 comments as the comments will be publicly available for others to review.  For more information, please be sure to read the “comments policy.” We intend to post all responsive submissions on a timely basis.

Please understand that posts must be related to the Preschool Development Grants Program, and should be as specific as possible.  If you include a link to additional information in your post, we urge you to ensure that the linked information is accessible to all individuals, including individuals with disabilities.  Each post must be limited to 1,000 words.  All opinions, ideas, suggestions, and comments are considered informal input and may or may not be reflected in the final Preschool Development Grants competition requirements, priorities, selection criteria, or definitions, established in the final Preschool Development Grants notice inviting applications. ED and HHS will not respond to any posts.

Again, thank you for your interest in this opportunity to support early learning.  We look forward to hearing from you.

Note to reader: Defined terms are used throughout this document and are identified using initial capitalization.  Definitions are provided later in the document.

Department of Education’s linking policy

Department of Education’s disclaimer of endorsement

Please download and read the Development Grants Executive Summary. Then click “Leave a Comment” at the bottom of the screen and add your comment. Please note that the Application Requirements, Program Requirements, and Definitions are the same for both Executive Summaries. In these and additional areas where the language is the same, you do not need to make your comments in each Executive Summary (Development Grants and Expansion Grants).

Please indicate in your comments the area in which you are addressing:

Purpose: A Development Grant is to support a State with a small or no State-Funded Preschool Program to—

  • Develop or enhance preschool program infrastructure and capacity to deliver High-Quality Preschool Programs; and
  • Implement and sustain High-Quality Preschool Programs to reach and serve additional Eligible Children in one or more High-Need Communities.

Eligibility Requirements

Award Information

Application Requirements

Priorities

Selection Criteria:

  • A) Executive Summary
  • B) Commitment to High-Quality Preschool Programs
  • C) Ensuring Quality in Preschool Programs
  • D) Collaborating with Subgrantees
  • E) Strong Partnerships between Subgrantees and LEAs or other Early Learning Providers
  • F) Alignment within a Birth through Third Grade Continuum
  • G) Budget and Sustainability

Program Requirements

Definitions

44 Comments

  1. To continue our third round of comments to the Pre-K Development Grants in process at the Department of Education, the National Head Start Association is pleased to offer the following recommendations to the Absolute and Competitive Priorities and further suggests additional Competitive and Invitational Priorities:

    ABSOLUTE PRIORITY 1 (Development): Building High Quality Preschool Programs
    We reiterate our suggestion that both Development applicants work towards high quality standards aligned with the Head Start Program Performance Standards, especially for education, comprehensive services and family engagement. As the most comprehensive set of federal standards for high-quality, comprehensive early learning programs, the Head Start Program Performance Standards should serve as the main guide for States under this program. These standards offer specific and valuable guidance for implementation of new programs, and though some may not apply, we suggest States adhere closely to Head Start Performance Standards dealing with:
    Implementing comprehensive health and education services for both children and their families;
    Ensuring exceptional learning outcomes and readiness for kindergarten;
    Use of developmentally appropriate curricula;
    Opportunities for learning through play and experience;
    Appropriate class ratios;
    Designing effective parent and family engagement programs; and
    Addressing the needs of culturally and linguistically diverse families (including Dual Language Learners, Migrant/Seasonal families, and American Indian/Alaska Native families) and children with special needs.
    Further, states should demonstrate how they will prioritize slots to the most vulnerable children and families across their states and within communities.

    COMPETITIVE PRIORITY 4, 6: ADDRESSING THE NEEDS OF CHILDREN IN PROMISE ZONES
    Applicants should propose projects that incorporate research-based practices designed to serve and coordinate with a federally designated Promise Zone.

    NHSA suggests the inclusion of the following additional competitive and invitational priorities:

    COMPETITIVE PRIORITY: SUPPORTING WORKFORCE INVESTMENTS
    A well-qualified, well-compensated workforce is a key component to creating a quality early learning program. States should consider how their programs will recruit and retain highly qualified early childhood educators without simply “poaching” qualified but under-paid teachers from existing programs. They should also be allowed to use funds to help existing programs like Head Start and child care retain early childhood educators with degrees and assist educators in attaining BAs through scholarships and related support services such as substitutes and paid release time. Therefore, policy guidelines that allocate funding for equal access to early childhood education staff throughout the mixed delivery system should be implemented. State plans should address how they will support attainment of BA degrees, how they will support a culturally and linguistically diverse workforce, and how they will support comparable salaries with the K-12 system.

    COMPETITIVE PRIORITY: SINGLE INTAKE SYSTEM
    Creation and use of a single intake system to facilitate enrollment and access to services/facilities — creating a one-stop shop for families who wish to access appropriate education, health and mental health, and community services and appropriately enrolling families in programs for which they are eligible and which can best meet their needs.

    INVITATIONAL PRIORITY: TECHNOLOGY
    States should have a plan for improved access to technology connectivity for sites and communities to allow innovative use of technology to improve quality, administration, professional development, parent engagement, or other aspects of system development.

    INVITATIONAL PRIORITY: TWO-GENERATION APPROACH
    Many families benefit most from Head Start programs because of the opportunity for family goal setting and support accessing education or job training experiences for parents. States that integrate preschool access with opportunities for parents to strengthen and stabilize their families should be awarded additional points.

    INVITATIONAL PRIORITY: MEETING NON-TRADITIONAL FAMILY NEEDS
    Within this category, states that develop innovative approaches to family situations including non-traditional work hours, migrant/seasonal workers, refugee communities, etc. will be awarded additional points.

    INVITATIONAL PRIORITY: EXPLORING ADDITIONAL MEASURES OF QUALITY IN PRESCHOOL PROGRAMS
    Monitoring and evaluating preschool programs should include a tool similar to the National Head Start Association Quality Initiative. The QI designations Program of Achievement and Program of Excellence are earned only by programs that consistently demonstrate excellence in program management and service performance, and that continually support the achievement of robust outcomes for at-risk children birth to five years old, pregnant women, families, and their communities. It is imperative to recognize programs that are adaptive experts and continually strive for success.

    INVITATIONAL PRIORITY: ALIGNMENT OF EARLY LEARNING AND DEVELOPMENT STANDARDS TO HEAD START CHILD DEVELOPMENT AND EARLY LEARNING FRAMEWORK
    State Early Learning and Development Standards should be anchored to the Head Start Child Development and Early Learning Framework. The Framework is research-based and aligns with and builds from the five fundamental domains of birth to five school readiness. In addition, they are used to identify critical areas of learning and development for preschool-aged children, encompassing dual language learners and children with disabilities.

    We hope these answers are helpful to you as you continue developing these grants. Please do not hesitate to contact us with any questions or for further discussion.

  2. The National Head Start Association is pleased to offer our third round of comments to the Pre-K Development Grants in process at the Department of Education. Thank you for taking into consideration our previously submitted comments. We ask that you please take into consideration the following comments, as well.

    E. Strong Partnerships between Subgrantees and LEAs or other Early Learning Providers
    We appreciate that the summary addresses the need for strong partnerships in order to sustain true community-based interventions. However, we suggest that to ensure that children and families have continued services, we recommend that the Memorandum of Understanding require that all grantees must have a defined plan of action to pursue should a sub grantee or local provider no longer be able to provide services.

    F. Alignment within a Birth through Third Grade Continuum
    Without question, these grants should be used to encourage states to support an aligned birth to age 8 continuum of high quality programs for children and families. In their applications, states should describe how they, in partnership with the state’s Head Start community including the Head Start collaboration director and state Head Start Association, will align and coordinate preschool programs with services for infants and toddlers, such as Early Head Start, CCDBG, and home visiting, as well as with other federally-funded programs and their K-3 systems. States should also describe how they and their partners will address the special needs of children and families (including but not limited to Individualized Family Service Plans for children with special needs under age 3 and non-traditional families). Finally, states should describe how they will address children’s transitions from preschool to kindergarten and how they will leverage Title I funds and other K-12 education funds to improve the continuum with consideration to the latest research relevant to the incoming population of young children (ie. dual language learners).

    G. Budget and Sustainability
    We believe states should absolutely be required to demonstrate their commitment to sustaining these programs beyond the life of the grant. Funds should be used to “supplement not supplant” existing funding commitments. States should also be required to ensure they maintain their investments in state-funded preschool and state funding for early childhood programs at the 2011, 2012 or 2013 level, whichever is highest. States and localities, if applicable, must also maintain 2012 or 2013 allocations (whichever is higher) toward early childhood in flexible funding streams (i.e. TANF, SSBG & Title I). Further, states should show that new preschool efforts will not result in a diminution of services or quality improvement efforts for infants and toddlers in the geographic areas served by expanded preschool services.

    Beyond the sustainability of funds, states should also show commitment to the ongoing desire to meet quality measures. This should include supporting the extension and continued existence of state advisory councils; developing a system of monitoring sub grantees and local providers, including measures such as CLASS, ECERS, and other evidence-based monitoring tools. Further, to establish transparency, an ongoing monitoring system that reviews the operational, fiscal, and management aspects of sub grantees and local providers should be established.

    Program Requirements, Part K
    In reference to the Program Requirements part k, we recommend that the State Advisory Boards should have a history of effectiveness in supporting collaboration between stakeholders.

    Definition of High-Need Community
    NHSA believes the overarching system should focus on serving the most vulnerable first. States should conduct a needs assessment with local communities to identify concentrations of the highest-need, low-income children, including children who are dual language learners, migrant children who travel from state to state, seasonal farmworker children who face unique challenges, American Indian/Alaska Native children, and children with other risk factors who currently do not have access to high-quality preschool. The research is clear that the lowest-income and most vulnerable children benefit most from high quality early care and education. With limited federal resources and long waiting lists for many programs, especially Head Start and CCDBG, these new funds should augment the total investment in early childhood by prioritizing the most vulnerable children and families first.

  3. Thank you for the opportunity to comment on the U.S. Department of Education’s Preschool Development and Expansion Grants Executive Summaries. Serving children and families for over 40 years, Knowledge Universe is best known for its KinderCare Learning Centers. We offer early childhood education and care through approximately1,600 community-based centers and employer partnerships. We are honored each day to provide high-quality education and care to over 150,000 children across the United States. We are committed to serving all children regardless of background and financial circumstance, and we are proud of the diverse group of children we currently serve. Approximately one-third of our children are from low-income working families who receive assistance under the Child Care and Development Block Grant (CCDBG), and each year we serve approximately 27 million meals through the Child and Adult Care Food Program. In addition, led by our Inclusion Services team, each year we assist more than 2,500 children with special needs. We are also the largest partner with Child Care Aware and the Department of Defense in providing high-quality community-based childcare for America’s military families, serving some 2,700 active duty families.

    We offer the following recommendations pertaining to the Preschool Development and Expansion Grants Executive Summaries.

    Supporting and Maintaining a Diverse Delivery Model

    States should be explicitly encouraged and receive a competitive priority for applications that propose supporting and maintaining a diverse mixed delivery model. The application criteria should also require States to work with the full range of Early Childhood Intermediary Organizations and Early Learning Providers in their states to ensure a diverse mixed delivery model. Further, associations of center-based child care providers should be included as an example of Early Learning Intermediary Organizations in the Definitions Section to ensure full representation of community providers.

    Ensuring significant participation of high-quality, community-based early education and care programs as partners in the delivery of the public early education investment taps the expertise of a highly-qualified and experienced workforce already working with young children, utilizes an innovative and effective public-private partnership, increases overall system capacity to serve more children, and supports working parents’ need for full work day, year-round education and care for their children. Further, allowing four-year olds to be served in community settings is essential to maintaining affordable care for infants, toddlers, and three year-olds.

    An additional benefit of our current mixed delivery model for early childhood education is that this system has excess capacity that easily could be tapped to serve more children without incremental investment in bricks and mortar. Even today a number of states utilize this mixed delivery model to tap into capacity among an array of high-quality providers in implementing their state preschool programs, but this opportunity can and should be expanded.

    When parents entrust their young children to the care of others, it is critical that parents be fully engaged in the process and feel confident about the options they have and the choices they have made. No two families are the same, and every child and family situation is unique. Our nation’s current mixed delivery model of early education and care respects and provides for the individual choices and needs of children and families and offers the best environment for creating strong family-provider partnerships and engagement.

    Additionally, a full-day, full-year program as is available through a mixed delivery model is a critical component for working families and for child development. The current mixed delivery system is essential for meeting the needs of working families’ schedules be they full-day, half-day, before-school, after-school, year-round, or summer only. For children of low-income families, the allowance for full-day, year-round education provides for greater consistency and continuity and results in better outcomes for children.

    Alignment within a Birth through Third Grade Continuum

    In their applications, States must describe how high-quality preschool programs will not lead to a “diminution of other services for programs serving children from birth through age 5.” State preschool development and expansion programs may very likely affect program service patterns and costs at the early end of the continuum for infants and toddlers. In their applications, states should also be required to describe how programs funded under the grant will not lead to increased costs for the care of infants and toddlers.

    Definition of High-Quality Preschool Program

    The definition of a High-Quality Preschool Program includes only Head Start Performance Standards and the NIEER benchmarks as examples of evidence-based and nationally recognized measures and standards. The National Association for the Education of Young Children (NAEYC) Standards for the Accreditation of Programs for Young Children must be added to the examples of evidence-based and nationally recognized measures and standards. NAEYC standards for accreditation are externally validated, evidence-based, and nationally recognized as comprehensive standards for quality early childhood education. The NAEYC standards are based on the best research on the development and education of young children and are regularly updated in response to recent changes in best practice in the field of early childhood education.

    The definition of a High-Quality Preschool Program also includes a requirement that teachers hold a B.A degree. Current research is inconclusive and mixed on the effects of a B.A. degree on improved child outcomes. (See R. C. Pianta, W. S. Barnett, et al The Effects of Preschool Education: What We Know, How Public Policy Is or Is Not Aligned With the Evidence Base, and What We Need to Know). Teacher qualification requirements should instead respect the multiple pathways reflected in NAEYC Early Childhood Program Standards and Accreditation Criteria. Teacher credentials should be based on actual early childhood education classroom experience, professional development, and learning, and should not displace the many qualified, experienced, and dedicated teachers already serving our youngest citizens.

    Promise Zones

    We question the inclusion of a competitive priority for Promise Zones as proposed in the Executive Summaries. Promise Zones are currently limited to five localities with plans to expand to only an additional fifteen over time. As these localities are so limited, we recommend this priority be removed.

    Sincerely,
    Celia Hartman Sims
    Vice President, Government Relations
    Knowledge Universe

  4. May 16, 2014

    These comments are being submitted on behalf of the IDEA Infant & Toddler Coordinators Association (ITCA) on the draft Executive Summaries of the Preschool Development and Preschool Expansion Grants authorized and funded under the FFY 2014 Consolidated Appropriations Act, 2014 (Public Law 113-76). The ITCA represents states and other jurisdictions implementing the Individuals with Disabilities Education Act (IDEA) Part C for infants and toddlers with and at risk for developmental delays and their families.

    ITCA appreciates the Administration’s support of a number of the recommendations we made in February 2014 and the changes made to enhance efforts toward inclusion of IDEA, Part C and Preschool Special Education in these grants. These positive changes reflect the administration’s priorities and will help ensure all young children and their families have access to and are able to participate in quality early learning opportunities.

    As we have stated previously, our priority is a final application package that ensures full involvement of the Part C and Preschool Part B 619 programs in the implementation of these preschool grants. The changes made in this version will help ensure that young children with disabilities and their families have the services and supports necessary for them to be successful in community early learning opportunities.

    ITCA comments and recommendations for these Executive Summaries are as follows:

    • ITCA supports the competitive priority in both grants that gives preference to those applications that demonstrate how grant efforts will be integrated within a broader continuum of high quality care and education supports for children participating in an ambitious and achievable plan from birth to third grade. We support the language requiring a description of how partnerships will be fostered and resources leveraged from community agencies. We do request that Part C and 619 of IDEA be specifically included in the identified list of community programs in this section. ITCA notes and supports the reference to transition, including from Part C to 619 under IDEA.

    • ITCA supports the required application selection criteria under Strong Partnerships (Section E.) in both grants that require a description of how the state will ensure each subgrantee coordinates and collaborates in “supporting full inclusion of children with disabilities…” This is a very positive addition. We do suggest that the language be revised to include “supporting access to and full participation in all opportunities.”

    • ITCA appreciates and supports the requirement in both grants that the State Advisory Council on Early Education and Care must include state coordinators from both the Part C and the 619 programs.

    • ITCA notes that the language clearly states grant funds are to be used for four year olds. We strongly encourage the Administration to include language permitting and encouraging states to make a portion of the project funds available for children beginning at birth. We further recommend language that would give competitive advantage to applications that include children starting at birth. Adding references and focus on activities down to birth in this priority will increase significantly the value of this preschool effort, making it more likely that children will succeed in school and life.

    • ITCA is pleased to see the requirement in both grants that states must ensure the percentage of children with disabilities served under the grant reflects, at a minimum, the percentage of children served statewide through 619 of Part B of IDEA statewide. However, we recommend that states be required to set numerical targets reflecting appropriate increases in the percentage of preschoolers with disabilities that will participate in these opportunities. A required plan for activities to work toward that these targets and required public reporting of data demonstrating improved performance toward targets is recommended to ensure full inclusive opportunities.

    • ITCA appreciates and supports the required application requirement in both grants on how the state will address the needs of eligible children, “including those who may be in need of additional supports, such as children who have disabilities or developmental delays….”

    • ITCA supports element (f) “full inclusion of children with disabilities” in the definition of a high-quality preschool program. We suggest a slight revision to include access to and supports to ensure full opportunities.

    • ITCA recommends that the required Memorandums of Understanding include agencies implementing Part C and 619 of IDEA and include a description and plan to ensure that these programs are fully integrated into grant activities to ensure necessary supports and services are available for children with disabilities and their families. The MOU should be required to specify how the Part C and 619 representatives will be involved in grant leadership and decision-making and how the grantee will evaluate and report to the federal office periodically on the implementation of all partnership efforts including any changes that will ensure that grants implement partnership activities as planned and proposed in the application.

    • ITCA must again state the reality that additional resources for early intervention and preschool special education services are critical to ensure full participation of children with disabilities in these new opportunities. As new early education opportunities for children from birth to five are expanded, the number of infants, toddlers and preschoolers with disabilities identified can be expected to increase. ITCA recommends a percentage of funding to support IDEA’s early childhood programs be set-aside from the $250 million allocation to ensure that appropriate services and supports can be provided to achieve this purpose.

    Thank you for opportunity to submit comments to these proposed changes. As always, ITCA is available and willing to provide any additional information or clarification that may be needed. Feel free to contact us by email at ideaitca@aol.com if we may be of further assistance.

    Sincerely,

    Donna Noyes, ITCA President
    Maureen Greer, ITCA Executive Director

  5. Thank you for giving us the opportunity to submit comments in response to the Departments of Education and Health & Human Services’ proposed grants program for preschool development.

    OVERVIEW

    As an independent agency of the federal government, the National Endowment for the Arts (NEA) supports artistic excellence, creativity, and innovation for the benefit of individuals and communities. In its research capacity, the NEA is committed to promoting public knowledge and understanding about the contributions of the arts.

    As part of a comprehensive strategy to achieve this goal, the NEA’s Office of Research & Analysis coordinates an Interagency Task Force on the Arts & Human Development, a coalition representing 18 federal entities. The mission of the task force is to catalyze research opportunities and information-sharing about the arts’ potential role in health and education across the lifespan.

    Through the ongoing work of the Task Force, the NEA and its federal partners have shared with the public ongoing research on the emotional and learning-related benefits associated with inclusion of arts curricula in early childhood education, e.g., in Head Start programs.

    Similarly, the NEA is collaborating with investigators on the National Children’s Study to understand the relationship between early childhood arts involvement and development of positive health and educational outcomes later in life. And finally, NEA and Task Force members are conducting a literature review of research on cognitive and socio-emotional outcomes associated with arts participation in early childhood.

    As all of these efforts suggest, there is a need to improve the evidence base for understanding and leveraging the arts’ direct impacts on early childhood development. Promising research is under way. Nevertheless, the application requirements for the Preschool Development Grants Competition provide an opportunity to recognize the general importance of the arts, and structured play opportunities, in the creation and maintenance of a high-quality preschool program.

    SPECIFIC COMMENTS

    The NEA commends the description of “arts and arts education programs,” along with other “community-based learning resources,” as an indicator of strong community partnerships between State sub-grantees and early learning providers (page 15). We suggest adding “and museums” after “libraries” in that same section.

    Our remaining comments focus solely on the definitions that begin on page 18 of the Development Grants Executive Summary document.

    • Under item “b” of the definition of “Comprehensive Services (page 18): add to “parent education” the following phrase: “and arts and cultural programming that will allow family engagement.”

    • Under item “d” of the definition of “Comprehensive Early Learning Assessment Systems” (page 19): add “and Peer Interactions,” which is a useful metric for gauging pro-social behavior patterns related to early learning.

    • Under the definition of “High-Quality Preschool Program,” add a new item (page 20): “Structured opportunities for creative play and/or arts engagement (e.g., music, art, creative movement or dance, and drama) in conformance with applicable State or National standards.”

    • Under item “d” of the definition of “Program Standards” (page 22): add to the sentence beginning “These strategies may include, but are not limited to,” the following phrase: “integration of arts-related content or curricula that address culturally or linguistically specific needs of parents, children, and family members.”

    Again, we appreciate this opportunity for feedback.

    Office of Research & Analysis
    National Endowment for the Arts

  6. On behalf of the more than 1.5 million members of the American Federation of Teachers, including approximately 90,000 early childhood education professionals who work in diverse delivery systems, we welcome the opportunity to offer comments and suggestions to the two executive summaries created for the expansion and development grants that will make up the Preschool Development Grants Competition.

    Both recent and long-standing research demonstrates that children who attend high-quality preschool programs benefit academically and are more likely to lead productive, healthy lives as adults. Yet, for all the research pointing to gains from early childhood education, comparatively few of America’s children have access to early learning. As your departments note, only 40 percent of eligible children have access to Head Start, and fewer than 30 percent of all 4-year-olds are enrolled in state-funded preschool programs.

    In light of these troubling statistics on preschool access, Congress’ decision to include a significant increase for early childhood education and care in the FY 2014 budget is a critical first step toward providing more children access to these services. However, it is regrettable that the new funding will be distributed via a competitive grant program, forcing states to compete for needed resources, creating few winners and many losers—most specifically the children in the “non-winning” states. The AFT believes all children should have access to high-quality early childhood education and care beginning at birth, and we advocate for a national commitment to make a voluntary program universally available—with first priority given to disadvantaged children.

    We strongly support establishing systems that focus on high-quality programs that include school readiness, comprehensive services, standards for program quality, family engagement, and a well-prepared and stable educator workforce. Because of our vision for early education and care, the AFT wholeheartedly endorses the Strong Start for America’s Children Act. It is also why we are very pleased to see federal resources allocated to help states establish and strengthen such systems.

    Preschool systems must be grounded in the belief that early childhood education takes place within a continuum from birth to age 8. When states provide early learning and care opportunities to young children without considering the education or care they received before or after age 4, they fail to meet the needs of young learners. While we would have preferred that this grant not be competitive, we appreciate that the departments have decided to give preference priority to states that demonstrate how they will support a birth-through-third-grade continuum of learning. Furthermore, the inclusion of full-day kindergarten as one marker of an integrated birth-through-third-grade system is especially important.

    The importance of a smooth transition from preschool to kindergarten cannot be overstated. Where information about a child’s learning needs can follow him or her to kindergarten, the kindergarten teacher is better equipped to meet the child’s individual needs. However, kindergarten entry assessments should never be used to prevent a child’s entry into kindergarten or as a single measure for high-stakes decisions. To this end, we are pleased that the definition of “kindergarten entry assessment” included in the executive summaries strictly prohibits the assessment from being used in these ways.

    An early childhood education system that is characterized by strong partnerships between early learning providers and local education agencies (LEAs) is much less likely to be a patchwork of uncoordinated programs and duplicated efforts. We commend the departments for incentivizing states to create early learning systems that include a strong role for LEAs. Without their active involvement, preparing children for a successful transition to kindergarten becomes all the more difficult.

    The definition of a “high-quality preschool program” included in the executive summaries draws on nationally recognized criteria and is well-rounded and comprehensive. The departments made the right decision by including factors such as low staff-child ratios, comprehensive services for children, the full inclusion of children with disabilities, developmentally appropriate curricula, high-quality professional development, individualized supports and accommodations, and full-day programing.

    Including instructional staff salaries comparable to K-12 teacher salaries in the criteria is vitally important. Early educators continue to be underpaid and undervalued. As you know, the National Survey of Early Care and Education, a nationally representative survey released by the Administration for Children and Families in October 2013, found that preschool teachers who work in child care centers and have a bachelor’s degree could expect to earn about $28,000 annually, far below what the average college-educated American with a bachelor’s degree earns. Across early learning settings and teachers’ education levels, the average annual salary for an early educator is even lower at $22,000. Due in part to low compensation, staff turnover in early education remains prevalent. High-quality public preschool systems cannot and will never be fully realized unless compensation is addressed.

    Research demonstrates that the skill levels of early childhood educators and caregivers are critical factors in developing children’s cognitive, social and emotional growth. We recognize that preschool programs, such as those in the District of Columbia Public Schools, that require high staff qualifications for teachers, namely a bachelor’s degree in early childhood education or equivalent certification, provide high-quality early learning.

    However, we remind the departments that many members of the current workforce, particularly those working in community-based programs, often lack access to continuing education and professional development. We strongly recommend—particularly for development grants, where recipient states have been identified as low-capacity—that programs be given time and resources to support teachers as they work to meet the bachelor’s degree requirement.

    We strongly urge both departments to include language as part of the definition of “formative assessments” that makes it clear that the questions, tools and processes constituting formative assessments are developmentally appropriate in what and how they measure. Public preschool settings should foster a love of learning, not impose the burdens that accompany developmentally inappropriate assessment. The testing-over-teaching mentality that has seeped into too many early-grades classrooms should not be allowed to take root in preschool. Assessments should only be used to help inform and improve classroom instruction. Following these assessments, teachers should receive results within an appropriate time period so they can provide real-time information, allowing teachers to alter their instruction accordingly. The amount of time allocated to formative assessments should be minimized so it does not needlessly take away from time that could be used for teaching and learning.

    We believe there is a need for assessments and data collection. However, what we are witnessing today is an overreliance on and obsession with assessments and data collection, with data being collected on students as young as preschool age and following them into college. We are very concerned about this trend, as it leaves many unanswered questions, including: How is the data being used? Is student privacy being protected in the use of the data? We look forward to working with both departments to better address data collection and to determine a better way of gathering information that respects student privacy and circumstances.

    If implemented correctly, these grants have the potential to facilitate preschool expansion in a way that supports learning and school readiness, while meeting the needs of the whole child. Based on our experiences with competitive grant programs, including Race to the Top, we have seen too many examples of improper implementation, which we hope can be avoided in this instance. The grant application and implementation for the selected states should be developed collaboratively and should echo the voice of the teachers and staff who work most closely with young learners. It appears that the development and expansion grants address this and ask for stakeholders to be involved. However, we encourage the departments to remind applicants of their obligation to develop their applications collaboratively, and to require those who do not do this to re-engage with stakeholders in a more meaningful way and then resubmit their applications.

    Thank you for taking our comments into consideration. The AFT is enthusiastic about working with both departments to ensure that every young child in our country has access to a high-quality early education program that meets the needs of the whole child and family.

  7. The Early Care and Education Consortium (ECEC) thanks the U.S. Departments of Education and Health and Human Services for the opportunity to comment on the draft Preschool Development and Expansion Grants competition requirements and priorities. ECEC is the nation’s leading trade association of non-profit, and tax paying community, multi-state child care providers, state child care associations, and educational services organizations. Our members are uniformly committed to promoting access, affordability, and continuous quality improvement within a diverse early care and education mixed delivery system. We offer the following recommendations pertaining to both competitions.

    Supporting a Diverse Delivery Model
    1. The current application criteria for both development and expansion grants do not explicitly encourage states to utilize a diverse mixed delivery system in implementing their preschool program initiative. Community providers are referenced in ‘Priority 5-Supporting a Continuum of Early Learning and Development’ but not within the core selection criteria. The application criteria should explicitly incentivize states to build diverse and robust delivery systems that involve high-quality providers across a range of settings, including schools, Head Start, and regulated and licensed community early care and education providers—both non-profit and tax paying. A diverse-delivery system has many benefits. A mixed delivery system improves program access, maximizes parent choice, and addresses the challenges of limited space in schools as a cost-effective solution. Expanding options for high-quality preschool experiences also improves continuity of care, which research shows is a significant predictor of positive school readiness outcomes. Overall, a diverse delivery system engages and leverages the expertise and resources of the full scope of the early education community.

    The majority of state preschool programs are implemented via a mixed delivery model, and this approach should continue with support channeled through federal initiatives. Pennsylvania, Florida, and Georgia are among the states that demonstrate the success of effectively implemented diverse delivery models, leveraging not only program space, but resources that support professional development and comprehensive service delivery.

    2. Relying on a robust diverse delivery model as the mechanism to both develop and expand state preschool programs should be added as a Competitive Preference Priority to both competition applications. State preschool development and expansion should include a wide range of early childhood care and education providers that allows parents to choose among high-quality programs based on state Tiered Quality Rating and Improvement System ratings or national accreditation, including schools, Head Start, and both non-profit and tax-paying community early care and education providers.

    3. In developing or continuing to expand an existing mixed delivery system, the application criteria should require states to engage and connect with the full range of Early Childhood Intermediary Organizations and Early Learning Providers to ensure that the state’s identified needs will be met through diverse providers. This outreach should incorporate initial steps to establish an MOU with identified, high-quality providers and additional partners; however, the application requirements should clarify that MOU’s can be executed in the 90-day Scope of Work period following the application phase.

    4. Associations of center-based child care providers should be included as an example of Early Learning Intermediary Organizations in the Definitions Section to ensure full representation of community providers. Early Learning Intermediary Organizations should be referenced explicitly in existing Competitive Priority 3 in the language discussing how the state will foster partnerships and leverage resources from existing community agencies.

    Maximizing the Impact of Program Funds
    5. Competitive Priority 4 targets Promise Zones, which are not Promise Neighborhoods. These zones are limited in number—totaling only five localities, are not evenly distributed across states, and may impede state flexibility in identifying high-need communities with resource gaps. This priority should be removed.

    6. Section F, Alignment within a Birth through Third Grade Continuum, asks states to describe how high quality preschool programs will not lead to a ‘diminution of other services for programs serving children from birth through age 5.’ State preschool development and expansion may affect program service patterns and capacity for four year-olds, and produce an unintended consequence of increased care costs among providers serving large numbers of preschool-age children as well as infants and toddlers. States should also be required to describe how programs funded under the grant will not lead to increased cost of care for infants and toddlers.

    Supporting Program and Workforce Quality Improvement
    7. The applications’ definition of a High-Quality Preschool Program includes Head Start Performance Standards and NIEER criteria as evidence-based and nationally recognized measures and standards, but does not include accreditation by the National Association for the Education of Young Children (NAEYC). NAEYC accreditation should be added to the definition of a High-Quality Preschool Program as it serves as an externally validated, evidence-based, and nationally recognized set of comprehensive measures and standards.

    8. The applications’ definition of a High-Quality Preschool Program includes a requirement that teachers hold a B.A degree. A growing body of research demonstrates that child outcomes are improved by education, training and professional development that strengthen early childhood care and education provider capacity to actively engage young children in supportive and developmentally appropriate interactions around curriculum-based and domain-specific content. However, current research findings remain inconclusive regarding the effects of providers holding four-year versus two-year degrees on child outcomes and program quality (http://www.psychologicalscience.org/index.php/publications/journals/pspi/the-effects-of-preschool-education.html). The application criteria should not be limited to this degree threshold, but require states to support improving credentials and qualifications of all preschool providers and staff through multiple pathways providing high-quality education, training, and professional development opportunities. In addition, the application should encourage states to support scholarships, release time, and other supports that enable workforce development.

    9. The definition of a High-Quality Preschool Program includes a requirement for instructional salaries ‘comparable to kindergarten through grade twelve teaching staff.’ The applications’ criteria, allowing state flexibility in addressing levels of compensation, should reference only kindergarten level staff or be removed.

  8. I have been the principal of a developmental preschool in New Mexico for over ten years. I have personally seen the huge positive impact preschool can have on a student’s life. For children in a high poverty, high mobility area who are also bilingual, it becomes a greater impact. For my students who also have developmental delays, it is essential. I am very excited to see this initiative to promote these services. My concern is the type of programs that are supported by this grant. Please give serious consideration to requiring recipients to provide intensive readiness instruction to preschoolers. Guidelines that allow for the majority of learning to occur by exploration instead of direct instruction do not have the impact that is needed in our community. Please consider raising the academic rigor in the guidelines so students who so desperately need this intervention can be successful when they reach kindergarten.
    Thank you for your consideration.
    Elizabeth T. Boggs

  9. Thank you for the opportunity to comment on the Executive Summaries of the Preschool Development and Preschool Expansion competitive state grants. The Center for the Study of Social Policy (CSSP) applauds the Secretaries of the Departments of Education and Health and Human Services for balancing the needs to expand preschool access in high-need communities and build infrastructure to support continuous quality improvement. Our recommendations focus on four strategies.

    1) Add criteria to encourage outreach to isolated or marginalized families who stand to gain the most from preschool participation.

    2) Prioritize strategies to value and engage parents, help families build protective factors and increase parents’ capacity to support their children’s development.

    3) Expand criteria for local partnerships that promote families’ seamless access to supports in their communities.

    4) Include criteria to promote comprehensive, accountable, early childhood systems that incorporate early learning and intervention, health, mental health and family support.

    Our comments apply to both grants. For proposed language changes to specific sections of each grants’ Executive Summaries, please see our side-by-side document, publicly available on CSSP’s website at http://www.cssp.org/reform/strengthening-families/2014/CSSP-COMMENTS-ON-PRESCHOOL-GRANTS.pdf.

    Rationale
    Brain science underscores parents’ primary influence on their children’s development, therefore better child outcomes cannot be achieved without considering parents’ role and the context of families. The literature identifies five protective factors that are associated with positive child outcomes and reductions in the likelihood of child abuse and neglect: parental resilience, social connections, concrete support in times of need, knowledge of parenting and child development, and the social and emotional competence of children. To have the greatest impact, state policy should promote culturally and linguistically responsive strategies to engage parents, help families build protective factors and increase their capacity to support their children’s development. Language in the Executive Summaries which focuses solely on children has the potential to undervalue the role of parents and exclude them as important contributors to successful solutions. The Preschool Development Grant competition presents an opportunity to shift the conversation and place families at the center so that children thrive.

    Recommendations
    1) Add criteria to promote outreach to isolated or marginalized families:

    ** Children living on the margins stand to gain the most from high quality preschool, but are often the least likely to participate. Criteria should encourage state support for culturally responsive outreach to ensure that all families are informed of the availability and benefits of new or expanded preschool programs.

    ** The definition of “eligible children who may be in need of additional support” should include all children whose families are or have been involved in the child welfare system. Whether such children are in foster care, placed with relatives, or remain or are returned home, they are likely to have experienced not only the trauma of abuse or neglect, but also the trauma of separation (or the threat of separation). These children in particular will benefit from high quality preschool experiences with staff who are trained to respond to their developmental needs.

    ** Similar to requirements for children with disabilities, states should be required to ensure that the percentage of children whose families are involved in child welfare that are served in the High-Quality Preschool Programs reflects, at minimum, the percentage of 4-year-old children whose families are involved in child welfare, as a percentage of the population.

    2) Prioritize strategies to value and engage parents:

    ** The grants’ criteria should prioritize strategies that engage parents, help families build protective factors and engage parents in decisions about their children’s education. States are laying the groundwork to support family engagement through Quality Rating and Improvement Systems, thanks to the Race to the Top Early Learning Challenge, Head Start’s Parent, Family and Community Engagement Framework and CSSP’s Strengthening Families approach. The Preschool Development Grant competition should be explicitly promote continuity and alignment of family engagement across preschool, child care and K-3 education.

    ** States should be required to describe how parents will be involved in the design, implementation and monitoring of the grant activities (as appropriate).

    ** Criteria should address how the grant will support professional development training on culturally responsive parent engagement strategies, alignment of these strategies with K-3 approaches, and promotion of policies that require screening and assessment data to be shared with parents so families can make informed decisions.

    **Criteria should emphasize the need to value and support the family’s role during the transition from preschool to kindergarten.

    3) Expand the scope of criteria to promote families’ access to a seamless continuum of supports in their own communities:

    ** Criteria to promote local collaboration should extend beyond early care and education programs to include health, mental health, family support, housing and other community assets. Such partnerships will improve programs’ capacity to help families build protective factors by connecting them with comprehensive wrap-around services.

    ** In additional to the Promise Zones initiative, criteria should also encourage connections with other federal grants that promote early learning (e.g., Promise Neighborhoods, Project LAUNCH, Race to the Top District grants, Invest in Innovation, etc.). The Promise Zone initiative is limited to a handful of sites, putting several states at a disadvantage. Meanwhile, there are federal dollars supporting early learning efforts in many other communities that can be leveraged with the new Preschool Grant dollars to maximize impact.

    4) Include criteria to encourage states to build comprehensive, accountable early childhood systems:

    ** States should be asked to support more coordinated systems of early learning, health, mental health, early intervention, family support and other services (e.g., encouraging cross-sector planning, aligned eligibility requirements, joint training, professional development and state and local data sharing.

    ** Criteria should support data collection on measures of children’s health and development, families’ access to services and other factors that contribute to child and family well-being. States should also describe how they will disaggregate and use data by race and ethnicity to inform policy decisions and implement continuous improvement strategies.

    Thank you for considering these comments and noting the specific recommended language changes in the accompanying side-by-side document. CSSP looks forward to continuing our support of this important investment in our nation’s future.

  10. Thank you for the opportunity to offer input in the implementation of $250 million in Race to the Top Funds to develop, enhance, or expand high-quality preschool programs, as provided by the FY14 Consolidated Appropriations Act.

    The Executive Summaries of the Development Grants and Expansion Grants reflect critical values for the early learning community: invest in quality; ensure a full continuum of birth to five services that connects well with early elementary grades; target communities with the greatest needs; and deliver services through a mixed-delivery system.

    Within that framework of shared goals, we have some comments on ways that we believe the competition could be improved.

    • Allow States to Serve 3-Year-Olds. States should have discretion to utilize preschool funds to expand services to serve both 3- and 4-year-old children. Most of the 40 states with preschool programs serve both 3- and 4-year-olds. Research has shown the incremental benefit of a two-year, quality program for those children who may be the least likely to succeed in school without the benefits that preschool can provide. Serving 3- and 4-year-olds together fosters a continuum of early care and learning and builds on existing mixed delivery systems. States should be allowed to use funds this way, and the definition of “Eligible Children” and “State-Funded Preschool Program” should be changed to include three-year-olds.
    • Give States Flexibility in Choosing Subgrantees. The application timeline may be too aggressive for states to engage in a thoughtful process of engaging with specific subgrantees. States should participate in a thoughtful process of conducting needs assessments, engaging in community outreach based on those needs assessments, lining up subgrantees capable of meeting identified needs, and identifying the work needed to support subgrantees. While some states have already undertaken work that would allow them to complete such a process before submitting an application, we encourage the Departments to allow applications from states that are committed to that process even if they will not complete it until after the application deadline.
    o We strongly support the inclusion of community providers in state early learning systems. For community providers, the preschool funded through this competition – a full-day program with teachers paid comparably to those in school districts – will likely look very different than the programs they currently provide, and require adjustment in the use of other funding streams at the provider level (particularly Head Start and child care). Given that, we are concerned that a timeline that is too aggressive would disadvantage community providers and make it harder for them to participate.
    o In the same vein, we support a competitive preference priority for states that have strong integration plans for community providers.
    • Give States Flexibility in Implementation. The application sets a hard cap of 10% on infrastructure and quality improvements. We understand that the purpose of this grant program is to provide money to communities to expand access to high-quality State-Funded Preschool, but there may be states in which the best strategy for doing that requires more funding for infrastructure – particularly in developmental states. Rather than hold states to a hard cap on infrastructure spending, states applications should be judged on how they meet the goals of expanding access and improving quality – and given flexibility in assigning funds to strategies calculated to meet those goals. This may be particularly true in the first year of the grant, especially if it is more cost-efficient to have the state pay for certain start-up costs. Moreover, infrastructure spending may help states sustain quality by improving their teaching force in durable ways.
    o Infrastructure spending may also be the most effective way for states to improve the overall quality of their teaching force, improve quality in underserved communities, and serve children with special needs.
    • Address the Needs of All Students. Subgrantees are required to deliver High-Quality Preschool to Eligible Children who may be in need of additional supports (D.3), but we know that most of the children in the categories mentioned do need additional supports. Service to children in need of additional supports should be both required and prioritized. Needs assessments should identify these children, and then implementation plans should reflect those needs assessments – and provide the funding and support needed to outreach to and serve these children effectively. For example, requirements for coordination across funding streams (such as D.4.i and 6.1) should specifically reference McKinney-Vento funds serving homeless children.
    o The definition of comprehensive services requires several important kinds of screening, but we recommend adding hearing screening, given its importance to supporting child health and development.
    • Incorporate Leadership as an Element of Quality Programs. In addition to ensuring preschool classrooms have well-qualified teachers, states should include strong leadership as a key component of building quality programs. Support from principals and other administrators who are knowledgeable about early childhood development practices are critical to guiding quality instruction and program success. This is true in both school-based and community-based programs. Accordingly, leadership should be included as an element of quality under C.1.
    • Layered Funding. In addition to the state-level fund coordination described in G.1, subgrantees should be explicitly encouraged to braid and blend funds to support High-Quality Preschool Programs.
    • Program Standards Should Focus on Education Quality. The definition of “Program Standards” identifies the elements that should be used to differentiate levels of quality. None of these elements require the direct evaluation of the quality of pedagogy in preschool programs. High-Quality Preschool should feature great teaching, and the measurement of High-Quality Preschool should focus on the quality of that teaching. There are existing tools that allow for this kind of evaluation, and states should reserve their highest ratings for programs that demonstrate teaching excellence for all children — including those who are linguistically, culturally, racially, and ability diverse.
    o An important strategy for improving education quality is collaboration between teachers and leaders across early childhood and early elementary. The language in F.2.b could be amended to specify that collaboration is an important element of sustaining educational and developmental gains.

    Sincerely,

    Diana Mendley Rauner, Ph.D.
    President
    Ounce of Prevention Fund

  11. The First Five Years Fund (FFYF) would like to commend the Administration for all the progress that has been made on developing the Executive Summaries of the Preschool Development and Preschool Enhancement Grants competitions. Your vision for the grant competitions reflect FFYF’s goal of improving access to high-quality preschool opportunities for low-income children. We are particularly supportive of the inclusion of standards that set the threshold for quality, including full day programs, highly skilled teachers, small class sizes and adult-to-child ratios, evidence-based curricula, and comprehensive services. We welcome this opportunity to provide additional feedback to these grant competitions, in addition to those which were submitted earlier this year as part of the Grow America Stronger campaign http://www.growamericastronger.org/preschooldevelopmentgrants. We wish to highlight areas that we think could help strengthen the competition.

    Allow states to serve low-income three year olds. Research shows that greater outcomes are found when children have at least two years of high quality education and care, especially for those who may be the least likely to succeed in school without the benefits of preschool. We recommend that the competition give states the flexibility to serve both low-income three and four year old children. This approach would also further the goal of creating a continuum of early learning opportunities for children from birth. The earlier you start, the better the outcome.

    Give states flexibility in choosing subgrantees. With the current requirements, the timeline may be too aggressive for states to meaningfully engage with subgrantees, especially as some states may not yet have the infrastructure in place to quickly make this selection. We recommend that the competition allow for a longer timeline so that states may engage in a more thoughtful and deliberate selection of subgrantees that can offer the highest quality programs. One alternative may be to require that states instead articulate the criteria they will use to select subgrantees as a way of ensuring this process is beginning to take place.

    Promote a mixed delivery system. A diverse delivery system has many benefits. It improves program access and gives parents choice. It solves the problem of limited space in schools and is cost-effective. Most important, it engages the expertise of the entire early education community. The majority of state preschool programs use a mixed delivery model, and this approach should continue. We recommend the competition be amended by adding language in Section D that encourages states to identify a range of subgrantees that meet the high quality standards as well as the needs of working families, including schools, private preschool providers, child care centers, and Head Start programs.

    Support quality improvement. We share the Administration’s vision for ensuring these grants support quality. Given what we know about the current need in states to increase quality elements, we recommend allowing states to spend more than ten percent of funds on quality improvement.

    FFYF looks forward to working closely with the Administration throughout this process, as well as to identify additional opportunities to support states in increasing access to quality early childhood education opportunities to children birth through five.

  12. The following comments apply to both the Development and Expansion Grants program Executive Summaries.

    NAEHCY is a national membership association working to ensure success for homeless children and youth whose lives have been disrupted by homelessness.

    NAEHCY has previously described the severe developmental delays, health problems, and lower academic achievement experienced by homeless children. Research reveals striking evidence that, over and above the deleterious effects of poverty, homelessness disproportionately impacts the well-being and life prospects of very young children. (Details and supporting citations can be found at http://www.naehcy.org)

    For homeless young children, access to high quality preschool programs is critical for future success. Yet, lack of records and transportation, the high mobility that accompanies homelessness, lack of available slots/programs, and lack of awareness and outreach by early childhood programs often prevent homeless children from accessing early education programs. Consequently, homeless children make up a very small percentage of children enrolled in Head Start and school district preschool programs.

    These low rates of participation will not change until there are specific, strong, and explicit mandates for local preschool programs to: identify and enroll homeless children; assure continuous enrollment even when children move; provide professional development on homelessness for prekindergarten staff; and collaborate with homeless liaisons and service providers.

    The Strong Start for America’s Children Act (S. 1697) (“Strong Start Act”), which was recently approved by the Senate HELP Committee, recognizes the need for such specific mandates. (Details about the Strong Start Act’s specific homeless provisions can be found at http://www.naehcy.org.)

    Because access to quality preschool is crucial for homeless preschoolers, but will not improve without specific mandates for detailed plans that provide for measurable and accountable outcomes, the Development and Expansion Grants competitions should include provisions like those in the Strong Start Act as criteria for awards.

    Unfortunately, the Development and Expansion Executive Summaries give scant attention to homeless children, mentioning them only twice in each summary—once in paragraph (f)(8) of the “Application Requirements” section, and once in paragraph (3) of the “Collaboration with Subgrantees” section. These references suggest that homeless children (and other highly vulnerable children) may not actually need additional supports. They also lump migrant, homeless, and foster care children together in a way that suggests that States may forgo addressing homeless children’s needs entirely, as long other Eligible Children’s needs are addressed.

    These documents also fail to define “homeless children” in accordance with the McKinney-Vento Act’s education provisions, which ED administers. This omission will create confusion and result in fewer homeless children being served.

    Accordingly, paragraph (f)(8) in the “Application Requirements” should be revised as follows:

    How the State will address the needs of Eligible Children, including those who are in need of additional supports, including children who have disabilities or developmental delays; who are English learners; who reside on “Indian lands” as that term is defined by section 8013(7) of the Elementary and Secondary Education Act of 1965, as amended (20 U.S.C. 6301 et seq.) (ESEA); who are migrant; who are “Homeless” as defined in Subtitle VII-B of the McKinney-Vento Homeless Assistance Act (42 U.S.C. §11434a(2)); who are in foster care; who reside in rural areas; who are from military families; and other children as identified by the State, if applicable.

    Paragraph (f)(3) should be similarly revised.

    In addition, “homeless” should be included in the glossary as a defined term and capitalized throughout the documents. The definition should expressly refer to the definition in Subtitle VII-B of the McKinney-Vento Act (at 42 U.S.C. § 11434(a)(2)).

    To ensure homeless children’s access to high quality preschool programs, the State “Eligibility Requirements” should be expanded to require that Subgrantees will adopt the policies and procedures specified in the Strong Start Act.

    Similarly, there should be a new competitive preference priority specifically addressing the needs of homeless children:

    Priority __: Competitive Preference Priority – A Detailed and Comprehensive Plan for Increasing Access to and Continuity of Preschool for Homeless Children

    A State meets this priority based on the extent to which it submits an ambitious and achievable plan showing how the State will increase the access to, and continuity of, preschool for “Homeless Children” as that term is defined in Subtitle VII-B of the McKinney-Vento Homeless Assistance Act (42 U.S.C. §11434a(2)(A)). In particular, to achieve a competitive preference under this priority, a State must give priority to Subgrantees who demonstrate a detailed, comprehensive, and accountable plan (with objective performance assessment criteria) for increasing access to and continuity of preschool for Homeless Children, including through collaboration with McKinney-Vento Act Liaisons for Homeless Children and Youth.

    In paragraph (1) of the “Strong Partnerships between Subgrantees and LEAs or other Early Learning Providers” section, McKinney-Vento LEA Liaisons should be added to the list of partners, and paragraph (2) of that section should include a new lettered paragraph that states, “Supporting full inclusion of Homeless Children” in order to assure that coordination and collaboration plans contain plans for including Homeless Children.

    The coordination requirements and criteria (such as in those addressed in the “Commitment to High-Quality Preschool Programs,” “Collaborating with Subgrantees,” “Budget and Sustainability,” and “Program Requirements” sections) should include provisions to assure coordination with programs funded under Subtitle VII-B of the McKinney-Vento Act.

    Additionally, in the “Program Requirements,” states should be required to include State Coordinators of Education for Homeless Children and Youth on the State Advisory Councils, and a provision should be added to ensure that the percentage of Homeless Children served in the High-Quality Preschool Programs reflects, at minimum, the percentage of 4- year-old children identified as Homeless by local educational agencies and Head Start programs in the State.

    Finally, paragraph (d) of the “Essential Data Elements” definition should include specific references to migrant, homeless, and foster care status as essential demographic information.

  13. May 16, 2014

    The Honorable Arne Duncan
    Secretary
    U.S. Department of Education
    400 Maryland Avenue S.W.
    Washington, DC 20202

    Dear Secretary Duncan:

    I am pleased that the U.S. Department of Education is preparing to move forward with the Development Grants and Expansion Grants competition for the Preschool Development Grants program. However, it has been brought to my attention and I am extremely concerned that the U.S. Virgin Islands and the insular areas are not eligible to compete for this program. In an email sent by the U.S. Department of Education on Wednesday, May 14, 2014, the Department indicates that “All states, the District of Columbia, and Puerto Rico will be eligible to apply for the Departments of Education and Health and Human Services jointly-administered $250 million Preschool Development Grants competition.” I respectfully ask that you include the U.S. Virgin Islands and the other insular areas.

    I strongly agree and support the President’s initiatives to ensure that every child has access to high-quality early learning; especially in my district, the U.S. Virgin Islands, where child poverty rates are increasing. Recent studies published by the Community Foundation of the Virgin Islands indicate that, although the percentage of children in families with incomes below the poverty line fell between 1999 and 2009, Virgin Islands poverty is likely to have increased since 2010 due to recent economic downturn. The published study also indicates that more than one-fourth of Virgin Islands children ages 3 to 4 (27 percent) were not enrolled in school in 2010. These findings strongly support the need for preschool development programs in the U.S. Virgin Islands.

    Mr. Secretary, as you may recall, this is not the first time that U.S. Virgin Islands and the insular areas have been excluded from eligibility to compete for much needed education programs. My colleagues and I are still actively pursuing inclusion of the insular areas for the Race to the Top Program. We do not want our local education agencies to miss another opportunity due to exclusion from eligibility to compete. On behalf of the children from the insular areas, I hope that the Preschool Development Grants program will be modified to include the U.S. Virgin Islands and other insular areas.

    I thank you in advance for your attention to this matter.

    Sincerely,

    Donna M. Christensen
    Member of Congress

  14. I am writing to comment on the Preschool Development Grants. These grants are limited to states that have little or no state initiatives in this area.

    My comments center on the requirement that there be connections with the State Advisory Council on Early Childhood Education and Care that meets the requirements described in section 642B(b) of the Head Start Act (42 U.S.C. 9837(b)) and as described in paragraph (k) of the Program Requirements.

    The challenge is that in several of the states which are eligible for the Preschool Development Grants, there exists no State Advisory Council on Early Childhood Education and Care. The creation of a State Advisory Council was connected with the application and receipt of grants for the development of state infrastructure on early education. Some states which chose not to pursue these grants did not establish the Council. Having no Council precludes those states from pursuing a Preschool Development Grant.

    I think this absence should be noted in the grant rules. The grant rules need to identify options for those states without such a Council to consider so they can apply for the Preschool Development Grants. Such options for those states can include, but not be limited to:
    • Establishment of a Council by the state’s Governor
    • Establishment of a Council by the state’s Legislature (should it still be in session)
    • Assigning the duties of a Council to an existing state group by the state’s Governor
    • Other

  15. Dear Secretary Duncan,

    The Campaign for Grade-Level Reading is focused on the number one predictor of school success: third grade reading proficiency. The Campaign applauds your decision to use $250 million from the FY14 Consolidated Appropriations Act, 2014 for a new Race to the Top competition to work with states and communities across the country to build, develop, and expand high-quality preschool programs. Low-income children start kindergarten 12 to 14 months behind their peers in pre-reading and language skills. This Race-to-the-Top preschool initiative, which requires states to ensure that low-income children in families at or below 200% of poverty are served first, is a key strategy to improve school readiness for low-income children.

    In reviewing the Draft Development and Expansion Grant Executive Summaries, The Campaign for Grade-Level Reading applauds your inclusion of:

    • Priority 3 in the Development Grant and Priority 5 in the Expansion Grant: Competitive Preference Priority – Supporting a Continuum of Early Learning and Development. Specifically, “To receive a competitive preference under this priority, the State must demonstrate how it will integrate High-Quality Preschool Programs within a broader continuum of high-quality care and education supports from “birth through third grade”, including full-day kindergarten.”

    • Required focus on children in families at or below 200% of poverty

    • Focus on the “whole child,” including 1) addressing the need to ensure smooth transitions between infant/toddler services and preschool and between preschool and kindergarten, 2) providing family engagement, support, nutrition, and other comprehensive services, 3) all essential domains of school readiness (including health and social emotional development)

    • Focus on Birth through Third Grade Continuum (section F in the Development and Expansion Grant Executive Summaries)

    In order to continue the work of supporting early learning, The Campaign recommends that the following language be incorporated in Section F: Alignment within a Birth through Third Grade Continuum (in both the Development and Expansion Grants):

    (2) For kindergarten through third grade, these activities include (b) Sustaining early educational and developmental gains of Eligible Children upon kindergarten entry from High-Quality Preschool Programs throughout the early elementary years, “including efforts designed to increase the percentage of children who are able to read and do math at grade level at the end of third grade.”

    Ralph Smith, Managing Director
    Campaign for Grade-Level Reading

  16. The Preschool Development Grants Program offers a promising opportunity for States to increase children and families’ access to high-quality preschool. The National Women’s Law Center appreciates the opportunity to comment on the draft requirements, priorities, selection criteria, and definitions for the Development Grants competition and the Expansion Grants competition. The following comments apply to both the Preschool Development Grants and Expansion Grants, unless otherwise noted. (The National Women’s Law Center is submitting its comments in two parts. The first part of the Center’s comments is in a separate post.)

    Selection Criteria
    D. Collaborating with Subgrantees
    (1) Instead of requiring States to include a description of how they “selected each identified Subgrantee,” States should be asked to describe the process for how they will select Subgrantees.
    In addition, this item should be revised to include language requiring States to describe how their process for selecting Subgrantees will include a range of early learning providers.

    (4) The language should be revised as follows to emphasize the importance of a diversity of early learning providers and to indicate that States are not expected to have identified all of their Subgrantees and have signed MOUs prior to applying for a Preschool Development Grant, only that States are required to have a plan for selecting Subgrantees and obtaining MOUs (additions and changes are capitalized): “The State will ensure that the Subgrantees (WHICH REFLECT THE RANGE OF EARLY LEARNING PROVIDERS) are committed to the effective implementation of High-Quality Preschool Programs, as evidenced through a TEMPLATE MOU or TEMPLATE FOR ANOTHER FORM OF binding agreement between the State and each Subgrantee.”

    E. Strong Partnerships between Subgrantees and LEAs or other Early Learning Providers
    (2)(d) This item should be revised as follows and moved to the definition of High-Quality Preschool (changes are capitalized): “Ensuring that High-Quality Preschool Programs have AGE-APPROPRIATE facilities to meet the needs of Eligible Children.”

    G. Budget and Sustainability
    (1) Promise Neighborhoods should be included in the list of funding sources that should be coordinated (as applicable) to help expand High-Quality Preschool Programs.

    Program Requirements
    (k) In addition to the representatives listed, States should also be required to include the State Head Start Collaboration Director on their State Advisory Councils on Early Childhood Education and Care.

    Definitions
    Eligible Children
    This definition only refers to four-year-old children, yet if a State or locality is already reaching all four-year-olds, it should be allowed to use funds received through this grant to serve younger children in families under 200 percent of the federal poverty level. This definition should be revised to allow flexibility for States to serve younger children in low- and moderate-income families if they have adequately met the need among four-year-olds in low- and moderate-income families.

    High-Quality Preschool Program
    In addition to the Head Start Program Performance Standards and the National Institute for Early Education Research (NIEER) quality benchmarks, National Association for the Education of Young Children (NAEYC) early childhood program standards should also be listed as an example of evidence-based, nationally recognized standards that can be used to define a High-Quality Preschool Program. The ten NAEYC early childhood program standards, which are currently being used by state and local preschool programs, are research-based and have been externally tested for their validity as program standards.

    We also recommend the following specific revisions to the individual standards used to define a High-Quality Preschool Program:

    (a) The phrase “State-approved alternate pathway” should be replaced by “State-approved pathway to certification.”

    (g) The current language should be replaced with the following: “The program implements a curriculum that is consistent with its goals for children and promotes learning and development in each of the following areas: social, emotional, physical, language, and cognitive.”

    (l) This item should be revised as follows: “Evidence-based standards for health, safety, and appropriate learning environments.”

    In addition, we recommend that the definition of a High-Quality Preschool Program incorporate the following standards, which are included in NAEYC’s early childhood program standards and are essential for ensuring quality:

    (m) The program establishes and maintains collaborative relationships with each child’s family to foster children’s development in all settings; these relationships are sensitive to family composition, language, and culture.

    (n) The program promotes positive relationships among all children and adults to encourage each child’s sense of individual worth and belonging as part of a community and to foster each child’s ability to contribute as a responsible community member.

    (o) The program uses developmentally, culturally, and linguistically appropriate and effective teaching approaches that enhance each child’s learning and development in the context of the program’s curriculum goal.

    (p) The program effectively implements policies, procedures, and systems that support stable staff and strong personnel, fiscal, and program management so all children, families, and staff have high quality experiences.

    (q) The program is informed by ongoing systematic, formal, and informal assessment approaches to provide information on children’s learning and development. These assessments occur within the context of reciprocal communications with families and with sensitivity to the cultural contexts in which children develop. Assessment results are used to benefit children by informing sound decisions about children, teaching, and program improvement.

    • The Preschool Development Grants Program offers a promising opportunity for States to increase children and families’ access to high-quality preschool. The National Women’s Law Center appreciates the opportunity to comment on the draft requirements, priorities, selection criteria, and definitions for the Development Grants competition and the Expansion Grants competition. The following comments apply to both the Preschool Development Grants and Expansion Grants, unless otherwise noted. (The National Women’s Law Center is submitting its comments in two parts. The second part of the Center’s comments is in a separate post.)

      Eligibility Requirements
      There appears to be an inconsistency in the definition of the requirement in (a) that States must serve less than 10% of Eligible Children in a State-funded preschool program to be eligible for a Preschool Development Grant. The requirement uses a percentage of Eligible Children, which is defined in this draft as children under 200% of poverty, but the footnote indicates that States were identified using the National Institute for Early Education Research (NIEER) State Preschool Report, which provides data on the children served as a percentage of all children in the State. This requirement should be clarified.

      Application Requirements
      (a) A State should not be required to have its application signed by an authorized representative from each Subgrantee. States will likely only have a Subgrantee competition after they have been awarded a Preschool Development Grant and have funds to provide through a subgrant, and will not be able to identify all of their Subgrantees prior to applying for the Grant. This requirement to have all Subgrantees identified prior to the application could create an incentive for States to limit the number of early learning providers they use, rather than conducting an open competition for Subgrantees or conducting thorough needs and capacity assessments. States should be required to describe a process for selecting Subgrantees and obtaining Memoranda of Understanding (MOUs) with Subgrantees, but should not be required to identify Subgrantees prior to receiving the grant award.

      (b) In addition having letters of support from the entities listed, applicants should also have letters of support from the Child Care and Development Fund (CCDF) administrator, Head Start collaboration director, and the State Education Agency.

      Competitive Preference Priorities
      Competitive Priority – Addressing the Needs of Children in Promise Zones
      While States should be asked to demonstrate how they will encourage coordination between the Preschool Development Grant and Promise Zones where applicable, applicants should not be asked to coordinate with Promise Zones as a competitive priority. Only five States currently have a Promise Zone, placing the large number of remaining States at an automatic disadvantage due to a status unrelated to their commitment to expanding preschool opportunities. Even if a State did have a Promise Zone, it might prefer to focus its preschool expansion efforts on a community other than a Promise Zone where there may be a greater need for early learning opportunities.

      Additional Competitive Priority
      We recommend that a Competitive Priority be added to encourage States to ensure that preschool programs are offered by a diverse range of eligible Early Learning Providers that meet the quality standards. With a greater variety of providers, including school-based, Head Start, child care, and other community-based providers, there is a greater likelihood that a State or community will address the need of its families, including families requiring early care and education during a full day (including hours beyond the school day) while parents work. Involving a range of providers also allows for quality to be improved across the early learning system, rather than in one narrow part of it. States should be required to indicate how they will assess the resources available to meet the need for preschool in each community offering preschool under this grant, how they will take full advantage of the range of providers in each community, and how each type of provider will have a fair opportunity to participate in offering preschool. States should also be required to describe how they will conduct comprehensive outreach to the full range of providers in the geographic areas to receive funding and how they will collaborate with Early Childhood Intermediary Organizations in conducting this outreach.

      Selection Criteria
      A. Executive Summary
      (5) This requirement should specify that the stakeholders are to indicate their support with a written letter.

      (7) The list of activities to build or enhance State-Funded Preschool Program infrastructure should explicitly include scholarships, paid release time, substitute teachers, and other supports for teachers to help them receive their early childhood education credentials. These supports to help teachers gain educational credentials are essential for enabling States to develop the strong early education workforce that is critical to delivering high-quality preschool across a range of settings.

      B. Commitment to High-Quality Preschool Programs
      (5) The list of preschool programs and services with which to coordinate should include Promise Neighborhoods.

      C. Ensuring Quality in Preschool Programs
      (1) Items (e) “Improving teacher training programs” and (f) “Improving professional development programs and practices” should be combined as follows and made a mandatory use of funds, rather than an allowable activity: “Improving and delivering training and professional development programs and practices.”

      The list of quality improvement activities that States can fund through this grant should also be revised to include the following item: “Improving standards and practices related to meeting the needs of English Language Learners.”

      In addition, for States that have received Early Learning Challenge Grants and are applying for Expansion Grants, the following activities should not be allowable uses of funds; instead, States should be required to describe how their activities under the Expansion Grants will enhance their Early Learning Challenge Grant activities in these areas:
      (a) Enhancing or expanding Early Learning and Development Standards;
      (c) Conducing a needs assessment to determine available program resources;
      (g) Linking preschool and elementary and secondary school data;
      (i) Implementing a Comprehensive Early Learning Assessment System.

      (2)(c) This item should be clarified to indicate how a State is expected to measure school readiness if it does not have a kindergarten entry assessment.

  17. Allies for Children advocates for policy and practice changes that improve the health, education and wellbeing of children in Southwestern Pennsylvania. We are pleased to submit comments regarding the draft Executive Summaries of the Preschool Development and Preschool Expansion Grants authorized under the fiscal year 2014 Appropriations Act.

    We stand in support of the National Association for the Education of Young Children (NAEYC), and its views to strengthen the commitment to a mixed delivery system. The Development and Expansion Grant applications should have a competitive priority for States that agree to use these funds for quality support and expanded services across the diversity of childcare, Head Start, and school providers. A requirement of a diverse delivery system will result in better quality across the states’ early childhood system, benefit working families who need more than a school-length day for their children’s care and learning, and provide young children with greater consistency of quality care throughout the day and year. The application should be clear that subgrantees can be childcare and Head Start programs that meet the quality standards so long as a teacher is enrolled and making progress toward the Bachelor degree requirement. This has been a policy used effectively in some states to build a high-quality, diverse delivery system for preschool.
    In addition, the application should require that States describe how they conducted thorough and transparent outreach to the array of eligible Early Learning Providers to receive funding. The State should collaborate with the Early Childhood Intermediary Organizations to conduct that outreach across all of the types of Early Learning Providers.

    The definition of Program Standards and High-Quality Preschool Program should reflect the 10 research-based NAEYC early childhood program standards. (The standards are described at http://www.naeyc.org/files/academy/file/OverviewStandards.pdf)

    Allies for Children also believes that policies should support early childhood educators across all settings to reach the teacher qualifications requirement. We agree with NAEYC’s suggested language in the Development and Expansion grants: States are required to use a portion of the quality and infrastructure funds to provide scholarships, release time, and other supports to help teachers in child care and Head Start programs to meet the degree requirement and be given four years of such assistance. States should also be required to use the grant funds on other early childhood workforce support. We also agree with directing the competition with Competitive Priority points for Promise Zones.

    The drafts state that the funds will be used to pay for delivering preschool to 4-year old children. If State or local preschool programs are serving four and three-year-olds in their preschool programs, they should be allowed to serve eligible four-year-olds and with remaining resources serve 3-year-olds in families under 200% of the federal poverty line. The prekindergarten program is part of a larger continuum of learning that starts at birth, and the earlier children have access to quality experiences the better prepared they will be for school and life successes.

    Allies for Children looks forward to working toward high-quality early childhood education for all children and youth.

    Sincerely,

    Patrick Dowd, Ph.D.
    Executive Director
    Allies for Children

  18. On behalf of Child Care Aware® of America, I am pleased to submit the following comments for the record concerning and in response to the design and implementation of the Preschool Development Grants program.

    Child Care Aware® of America works with state and local Child Care Resource and Referral (CCR&R) agencies nationwide. These agencies help ensure that families in 99 percent of all populated zip codes in the United States have access to affordable, quality child care. On behalf of Child Care Aware® of America, I am offering the following remarks and recommendations concerning the Preschool Development Grants program.

    Child Care Aware® of America believes that to give children what they need to succeed, child care settings must not only provide safe and healthy environments, but also must support learning and development. Parents need a range of high-quality choices. We need a system that develops and supports all child care settings and offers parents affordable choices. When looking to develop or expand existing preschool programs, Child Care Aware of America firmly recommends that a greater emphasis is placed on ensuring that states adhere to mixed or blended delivery system that allows families to take advantage of the choices already available to them while working to improve the access to quality early learning opportunities in those communities.

    Finding quality and affordable early learning is one of the toughest jobs parents have. In addition to trying to decipher a complex set of standards that vary by state, parents have to also find a program that fits their financial and timing needs. While looking to develop or expand preschool programs in a state, Child Care Aware of America strongly recommends that state and local Child Care Resource and Referral agencies are looked to as a leader in the early childhood field to assist with coordination among programs and families.

    Child care resource and referral agencies help provide concrete information on supply, cost and the quality of care so that parents can make informed decisions. Some of the services that resource and referral agencies provide to parents include:
    • Information about types of child care, characteristics of quality child care, relevant licensing regulations, average costs, availability of public subsidies, and state child care quality rating and improvement systems.
    • Enhanced referrals, which includes vacancy checks to help parents narrow their choices to those providers that have a current opening.
    • Delivering consumer education and referrals by a variety of methods, including face-to-face meetings, telephone calls and Web-based referrals.
    • Multilingual services.

    State and local child care resource and referral agencies play a critical role in acting as a resource for communities on early learning programs, whether it’s connecting families to a child care program or helping them connect with other early learning programs if they are eligible, such as Head Start, Early Head Start, or state Preschool programs. Additionally, child care resource and referral agencies help families understand the bigger picture of the early childhood program landscape in their community and helps families figure out what early learning programs are best for their own situation. When the Preschool Development Grants are dispersed to the states and communities, state and local child care resource and referral agencies would be able to efficiently and effectively help connect families with these new or expanded opportunities for early learning.

    Lastly, Child Care Aware® of America supports the belief that ensuring the safety and healthy development of children is not only common-sense, but a way to ensure that the Preschool Development Grant program is building out the supply of quality early learning experiences, rather than simply modifying the appearance and structure of existing programs.

    Since its inception in 1987, Child Care Aware® of America (formerly the National Association of Child Care Resource and Referral Agencies) has worked to improve the system of early learning for all children and continues to support and promote national policies and partnerships to ensure access to quality child care and early learning services. Child Care Aware® of America is uniquely positioned in the early childhood field, as both as a leader in the advocacy for quality child care and as a member agency with partnerships across the country impacting providers, families, and children and looks forward to working with the Administration, states, and communities as they take advantage of this funding opportunity.

  19. On behalf of First Focus, a bipartisan advocacy organization dedicated to making children and their families the priority in federal policy and budget decisions, thank you for the opportunity to comment on this new competitive grant. We applaud the Departments of Education and Health and Human Services (the Departments) for supporting state capacity to develop, enhance, or expand high-quality preschool programs, including comprehensive services and family engagement for preschool-aged children from families at or below 200 percent of the federal poverty line (FPL). Please note that these comments apply to both Development and Expansion Grants.

    A large body of research reveals the importance of access to high quality early education, yet high quality pre-K is still not available to every child. This is primarily an equity issue: the high cost of private preschool combined with the limited availability of public initiatives means low- and middle-income families can’t afford private pre-K and can’t access public pre-K, so their children are often left out. This creates unequal starting points for children from high-income families and children from low- and middle-income families when they enter kindergarten. It strains the K-12 system by forcing teachers in the early grades to try to make up for the lost opportunity of pre-K for those children who were left without access, and often those gaps never close. A number of states have worked to remedy this by expanding their state-funded pre-K programs, but the 2009 recession slowed that progress. While investments in these programs are now increasing again, the development grants will help jumpstart this growth. As such, these grants should support efforts to increase access to preschool and to link access to quality to ensure maximum positive impact, and states should have plans to continue funding these initiatives after the exhaustion of the one-time grant funds.

    First Focus is pleased to submit the following additional comments to enhance the framework outlined in the executive summaries of both Development and Expansion Grants. Our recommendations build on several of the issues that we commented on previously, and will serve to strengthen the framework of Development and Expansion Grants for states’ work to expand access to high-quality pre-K.

    • Ensure equitable access to children with high needs. States should ensure that subgrantees have outlined specific plans for ensuring access to the hardest to reach, hardest to serve children in the state’s identified high needs areas. This can be accomplished by requiring states to outline specific plans to conduct outreach to families that are underserved in existing programs, such as children whose parents have low levels of literacy and/or without a high school degree, limited English skills, homeless families, families in foster care, children from diverse racial and ethnic backgrounds, geographically isolated families, and families on waiting lists for Head Start services.

    • Meet the needs of working families. We applaud the Departments’ commitment to full day pre-K, however, working families will need coordination with extended day and year round services. States should ensure that pre-K programs align childcare and other resources for optional care before and after pre-K so working families and parents who work non-traditional hours can participate, allowing for a full year of enrollment without recalculating income eligibility.

    • Allow for comprehensive services in pre-K approaches. Comprehensive services, as defined in the notice include offering health, mental health, dental, and vision screenings with referrals as needed. State plans should describe how the public health and primary care practices are leveraged to support the provision of comprehensive services.

    • Encourage innovation with Head Start. The notice encourages States to pursue collaborations with Head Start and work to integrate Eligible Children within economically diverse, inclusive settings, including those that serve children from families with incomes above 200% of the federal poverty line. Head Start programs and States can collaborate towards these goals with clear encouragement from the Departments regarding support for innovative blended funding models and guidance on simplified cost allocation methodologies that result in greater ability for Head Start programs to enroll more children in economically diverse classrooms.

    • Ensure that teachers are prepared to work with dual language learners. States should articulate specific plans to create a workforce that is well prepared to serve dual language learners. This could include certifications, endorsements in bilingual education, or professional learning experiences that prepare teachers to support first and second language development, including through partnerships with families.

    • Ensure that school principals are trained in child development. The proposed framework includes important provisions on teacher training, collaboration with LEAs, and ensuring successful transitions from preschool to kindergarten. Including leadership training for principals and directors of preschool providers can strengthen these provisions. Too often, instruction in kindergarten through third grade fails to adequately account for children’s developmental needs, and providing principal and school leader training in addition to teacher training will help children with the transition from preschool to kindergarten and kindergarten through grade 3. To provide adequate training for principals and school leaders, section C, subsection 1 should, instead of only teacher training programs, state “Improving teacher, principal and school leader training programs,” and section D, subsection 4 in both Development and Expansion Grants should include training for principals and school leaders. Additionally, Section F, subsection 2 should include, in addition to aligning teacher training and competencies, aligning principal and school leader training and competencies.

    • Do not give certain states an unfair advantage. Currently both the Development and Expansion grants give additional priority points for Promise Neighborhood zones. While we support the Promise Neighborhoods initiative and understand the importance of community engagement to provide children comprehensive services until they graduate from high school, awarding priority points to the five states with Promise Neighborhoods for both Development and Expansion Grants puts the other 45 states, DC, and Puerto Rico at an unfair disadvantage. States that establish MOUs with subgrantees in Promise Neighborhood zones will already have an advantage because many of the systems necessary for coordination and collaboration will already be developed or in development. These states do not need the additional advantage of priority points when applying.

    • Ensure all states are able to apply. As with all competitive grants, the Departments should consider the cost and time burden involved in the successful submission of an application. The proposed application is comprehensive, with a number of requirements that may be difficult for some states to meet. This is especially true for Development grants, which are intended for states with limited state pre-K programs. States with small or no state-funded pre-K programs may not have the capacity or expertise to fulfill all requirements of the application. As such, we hope that the Departments will look at the scope of the current framework and identify ways in which the application itself can be simplified while still meeting its intended goals.

    • Clarify what will happen with additional funding if it is not. With the specification that $80 million is for Development Grants and $160 million is for Expansion Grants, it is unclear what will happen if all of the money in either category is not distributed to states. If this is ultimately the case we hope the Departments will grant additional funding from either category to the applicants in the other category that scored the highest of those applicants that did not receive grants.

    First Focus welcomes this exciting new competitive grant opportunity to increase states’ capacity for providing high-quality pre-K to children from low- and middle-income families. We hope the Departments will consider our recommendations above that further strengthen the framework of both Development and Expansion Grants, and we look forward to working with both Departments in implementation of these grants.

  20. New Horizon Academy is a Minnesota based; family owned and operated child care company. We operate 62 child care centers in Minnesota. All 62 of our child care centers in Minnesota have obtained the highest possible recognition for our quality programs by being NAEYC accredited. In addition, all 62 sites are rated 4 stars, the highest rating, in the states QRIS- Parent Aware. In addition we operate 4 child care centers in Idaho that are in the initial stages of becoming NAEYC accredited. We serve over 8,000 children and employ over 1,500 teachers. Our mission is to provide the best early childhood experience for every child in our care, through continuous improvement based on current research and best practices.

    Supporting a Diverse Delivery Model

    States are not explicitly encouraged to build on mixed delivery systems. Community providers are referenced in ‘Priority 5-Supporting a Continuum of Early Learning and Development’ but not within the core selection criteria.

    Recommendation: Explicitly state that a competitive priority will be given to states that build and/ or support a robust mixed delivery system.

    State applications will need MOUs with early learning providers as part of their application. This will be difficult to accomplish with child care providers in advance of submitting application, given the grant application timeline.

    Recommendation: State application should describe a process for obtaining MOUs, including the outreach efforts needed to reach a range of early childhood providers. States can be allowed a 90 day time period to amend their application if awarded the grant with the actual MOUs.

    The definition of Early Learning Intermediary Organization includes a wide variety of organizations that represent a group of early learning programs. The definition does not include center based child care associations.

    Recommendation: Center-based child care associations should be included as an example of Early Learning Intermediary Organizations in the Definitions Section.

    Ensuring Maximum Impact of Program Funds

    Competitive Priority 4 targets the inclusion of Promise Zones, which are not the same thing as Promise Neighborhoods. They are limited in number, not evenly distributed across states, and may impede state flexibility in identifying high-need communities with resource gaps.

    Recommendation: This priority should be removed.

    Section F, Alignment within a Birth through Third Grade Continuum, asks States to describe how high quality preschool programs will not lead to a ‘diminution of other services for programs serving children from birth through age 5.’

    Recommendation: This should be extended to a discussion of how programs funded under the grant won’t lead to increased cost of care for infants and toddlers.

    Supporting Program and Workforce Quality Improvement

    The definition of a High Quality Preschool Program includes Head Start Standards and NIEER, but does not include other widely recognized high quality program measures and standards.

    Recommendation: Include the National Association for the Education of Young Children (NAEYC) accreditation to the definition of High Quality Preschool Program.

    Recommendation: Include highest levels of the State’s QRIS to the definition of High Quality Preschool Program.

    The definition of a High-Quality Preschool Program includes the BA requirement, but without a focus on early childhood knowledge and/ or alternative educational pathways.

    Recommendation: Revise requirement of a BA in the definition of a High Quality Preschool Program to reflect the need for core knowledge in early childhood development. This should include a core number of credits in early childhood coursework, paired with years of experience. Multiple pathways to education and experience have proven to be effective in determining effective teacher qualification.

    The definition of a High-Quality Preschool Program includes a requirement for instructional salaries ‘comparable to kindergarten through grade twelve teaching staff.’ There is a wide range in teaching salaries within the K-12 system, with secondary teachers having significantly higher salaries then primary grade teachers.

    Recommendation: The definition of High- Quality Preschool Program should reference only kindergarten through 3rd grade teachers or be removed.

  21. The Center for American Progress is pleased to submit the following comments on the proposed components of the Preschool Development Grants program. We believe this framework provides a step forward in expanding access to high-quality preschool for vulnerable children. We commend the Administration for the work on this program thus far. We are particularly supportive of the following provisions:
    • Quality standards requiring teachers with a Bachelor’s Degree, small class sizes and ratios, full day programs, evidence-based curricula, program evaluation, and comprehensive services.
    • Strong partnerships between schools and community-based providers to ensure the seamless transition of children to kindergarten, especially around family engagement and comprehensive services.
    • Focus on the continuum of early learning program from birth through third grade, including coordination of services across programs and funding streams.
    • The inclusion of all states as potential applicants for either an expansion or development grant, regardless of how far along they are in providing preschool.

    We respectfully submit the following recommendations for your consideration:
    • Provide additional flexibility to states for quality improvement. Allow states to spend more than ten percent of funds on quality improvement. The most recent NIEER yearbook indicates that 40 percent of children served in state preschool are in programs that do not meet half of the benchmarks. States need flexibility to improve existing slots and the qualifications of the workforce to bring existing slots up to quality standards.
    • Allow states to serve low-income three year olds. States should have flexibility to provide preschool to three and four year old children. Research demonstrates that low-income children especially benefit from two years of preschool. This approach also furthers the goal of creating a continuum of early learning opportunities for children from birth. Some states have made considerable progress in serving four year olds, so providing flexibility with three year olds will also ensure that all states have the opportunity to apply for this grant.
    • Include observational measure of instructional quality in the definition of high-quality programs. We know that the single most important determinant of quality is the interaction between the teacher and the child. The definition of high-quality programs should include a measure of instructional support and teacher-child interaction that can be used for quality improvement.
    • Extend the timeframe for establishing subgrantees. Consider eliminating the requirement that states have subgrantees selected at the time of their application. States may not have time to conduct a thorough selection process during the application period. This is especially important for the development grants, as some states may not yet have infrastructure in place to quickly select subgrantees. We would prefer a longer timeline that allows for a more thoughtful and deliberate selection of subgrantees that can offer the highest quality programs. States should, however, articulate the criteria they will use to select subgrantees.
    • Promote a mixed delivery system. Consider adding language in Section D that encourages states to identify a range of subgrantees that meet the high quality standards as well as the needs of working families, including schools, private preschool providers, child care centers, and Head Start programs.
    • Include comparable salaries and benefits for instructional staff in the definition of a high-quality preschool program. It’s important that both salaries and benefits are comparable to avoid losing skilled early childhood staff to the K-12 system.
    • Strengthen supplement not supplant language. Consider a maintenance of effort requirement—in terms of children and funding level—especially for states in the expansion grants. Item (j) under program requirements should be revised to reflect that states may not supplant funds that would otherwise be available for improving state preschool, but also programs serving children across the birth to five spectrum.
    • Clarify that all funds must target children birth to five. Section (F)(2) could be read to suggest that states can use funds for activities in K-3. Given the comparatively small amount of funding available to provide access to programs for children prior to kindergarten entry, all Preschool Development Grant funds should be targeted to preschool-aged children. While CAP shares the goal of aligning programs from birth to third grade, efforts to improve elementary school programs should be funded through other resources.

    Thank you for the opportunity to comment on the framework for this important program. We look forward to continuing to work with you to support the expansion of high-quality early childhood programs.

  22. Thank you for the opportunity to comment on the Preschool Development and Expansion grant competitions. CLASP appreciates the leadership of the Departments of Education and Health and Human Services and their strong commitment to advancing high quality early learning experiences for young children. CLASP supports many provisions in the draft executive summaries of the Development and Expansion Grant competitions, including a recognition of the time it will take development states to make infrastructure and quality improvements in development states. Included in our recommendations are areas where think the competition could be strengthen by additional emphasis on developing and expanding mixed-delivery preschool systems, supporting the development of the early childhood workforce and meeting the needs of English learners.

    Please find a PDF version of our full comments on our website at http://www.clasp.org/resources-and-publications/publication-1/CLASP-Comments-Preschool-Devt-Grants-May-16.pdf

  23. The American Library Association (ALA) [http://www.ala.org] is pleased to submit additional comments on the design 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.

    Accordingly, ALA believes that the Preschool Development Grants 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.

    Therefore, ALA is pleased that the language under (E)(2)(f) of the Selection Criteria of the Executive Summaries for “Development Grants” and “Expansion Grants” includes coordination and collaboration activities to help ensure that subgrantees utilize “community-based learning resources, such as libraries, arts and arts education programs, and family literacy programs.”

    While, ALA is encouraged that language under (b)(1) of the Eligibility Requirements of the Executive Summaries for “Development Grants” and “Expansion Grants” includes an assurance that subgrantees that are LEAs will form strong partnerships with other early learning providers, we are concerned that the definition of “Early Learning Provider” does not specifically include libraries as an allowable partner under the definition.

    Therefore, ALA recommends that the Preschool Development Grants program recognize our contributions to the development of early learning initiatives and specifically include libraries as an allowable partner under the definition of “Early Learning Provider.”

    Finally, ALA supports the language under (C)(1)(c) of the Selection Criteria of the Executive Summaries for “Development Grants” and “Expansion Grants” that would authorize State grantees to conduct “a needs assessment to determine available program resources” in the State. We believe that a State needs assessment will help to increase the utilization of existing community-based learning resources under the program, but would recommend that libraries be specifically included as part of that needs assessment to help ensure that existing early learning initiatives in the State are utilized to their full potential as new early learning resources are awarded to States.

    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 on 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

  24. On behalf of Grantmakers in the Arts and its Arts Education Funders Coalition (http://www.giarts.org/group/arts-funding/arts-education/arts-education-funders-coalition), thank you for the continued opportunities to comment on the Preschool Development Grants and Expansion Grants program. As an organization representing grantmakers who have supported arts education in schools, early learning opportunities and community organizations, we see the power of systemically including the arts and arts education in K-12 and early learning programs. To that end we have worked to look for systemic opportunities to embed arts education into Federal education and related programs.

    Both grant opportunities represent an important occasion to begin to establish and expand high quality state preschool programs for low income students. While we have the benefit of Head Start providing early childhood education to some low-income children in America, the need to ensure greater access to high quality early childhood learning opportunities is important. The opportunity represented through these grants can be made stronger by more robustly including the arts and arts education as a specific approach to learning for young children, just as it is now under the Child Outcome Frameworks used under the Head Start program.

    A growing body of research on the effects of early arts experiences shows their positive relationship to improved, overall academic performance and school readiness. We have the work under the Head Start program and the Office of Head Start to thank for this research and significant evidence of the positive effects of the arts and arts education. Of additional importance, research in the arts also demonstrates that development of creativity at an early age provides continual benefits later in life.

    Comment on Strong Partnerships between Subgrantees and LEAs or other Early Learning Providers
    We want to first thank you for including language encouraging strong partnerships between subgrantees and arts and arts education as described on page 15 of the Development Grant executive summary and page 17 of the Expansion Grants executive summary. The specific mention of these partnership opportunities will motivate both subgrantees and local arts and arts education programs to collaborate to expand and enrich their service offerings.

    Comment on Definitions
    Secondly, we want to recommend a more robust inclusion of the arts in the “approaches toward learning” aspect of the Essential Domains of School readiness. As we referenced above, the importance of creative arts has already been recognized in early childhood programs through Head Start. Domain 5 of the Head Start Child Outcomes Framework identifies four elements: art, music, movement, and dramatic play. We strongly believe that the State preschool opportunities afforded under this initiative should not have any less focus on the arts then Head Start. In addition, we want to point out that Congressional legislation introduced to authorize the Obama Administration’s larger State Preschool initiative included in the 2014 and 2015 budget requests already specifically include a reference to the arts as part of the approaches to learning domain. To improve the existing language in the executive summary, we would recommend including the phrase, “, including the utilization of the arts and arts education” after “approaches toward learning” in the definition of “Essential Domains of School Readiness” on page 20 (for Development Grants) and on page 22 for (Expansion Grants).

    Lastly, we want to express our support for the executive summary’s strong requirement that States receiving these grants collect, analyze and use high-quality and timely data and evaluate their implementation efforts. While research and evidence have continued to show the value of the arts and arts education for young children, continued use of best practices based on research and evidence, as well as continual program evaluation, will strengthen the impact of state preschool programs and leverage the federal funding provided to produce better outcomes.

    Thank you for your attention to our comments and we look forward to working with you.

  25. The Association of Christian Schools International (ACSI) offers the following comments on the Preschool Development Grant Program. The Grants are divided into two: Development Grants and Expansion Grants. Thank you for the opportunity to provide this input which applies to both categories.

    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. 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. Grants under both Development and Expansion programs should respect for the broadest array of early learning programs including private and faith-based. Such factors could attract parents voluntarily to the programs and thus build demand for more. As written, the Preschool Development Grant Program appears to exclude participation of faith-based providers. This is disappointing since it effectively excludes the full diversity of low-income families, particularly those for whom faith is a priority and who are thus compelled to settle for a secular early education program or none at all. Diversity of programming would seek to ensure the ability of faith-based programs to participate. As we noted in our earlier comments: “… allowing the greatest diversity possible in programming and provision of services would likely best drive creativity, excellence and new ideas.”

    2. One model that allows a measure of faith-based participation in early education is the concept of certificates to parents as in the Child Care and Development Block Grant (CCDBG) Act. It has the advantage of empowering parents to purchase quality care that best meets their needs and enabling the participation of the widest range of providers.

    3. With a view to encouraging the expansion or further development of early education, the grant program could promote a diversity of services by ensuring that states recognize accreditation in lieu of licensing or that they do not establish restrictive policies such as acceptance of only state-based training and/or state mandated curricula.

    4. If the grant program were to ensure participation by an established national accrediting body, it would give states confidence in a particular faith-based program and give the state capacity to remove burdens that might otherwise keep faith-based and other non-government providers from engaging. After all, the effort to ensure the broadest diversity of programs, including faith-based programs, would need to guard against the inadvertent absorption of non-public early learning into a single government-only system.

    5. If the grant program were to utilize existing, nationally-known, diverse quality assurance accreditation models, it would not only assure professional quality, but also diversity of mission and pedagogy with existing networks that can be ramped up quickly and with the efficient use of dollars maximized by utilizing the current private infrastructure.

    6. Continuity of a particular early education program could be enhanced by allowing parents the ability to buy services directly and thus avoid the usual challenge of what to do when a grant comes to its inevitable end. Again, the popular, bipartisan CCDBG program is a good 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

  26. NAEYC is submitting its comments in multiple parts. Please refer to additional NAEYC comments on mixed/diverse delivery systems, early childhood educators, NAEYC early childhood program standards and high-quality preschool as well as the following comments.

    IV. Directing the competition with Competitive Priority points for Promise Zones:

    The Promise Zones (compared to the Promise Neighborhood awards) reach only five localities. The additional points for states – and the federal suggestion to partner with certain localities that may or may not be the best selection for the use of Development or Expansion grants – tips the competition to five states and pre-determines the selection of the local catchment area for preschool quality and expansion funds.

    Recommendation: We urge you to eliminate this as a competitive priority and instead include Promise Zones in the list of programs and funding streams which the State needs to leverage and coordinate to improve and expand high-quality early childhood programs.

    V. Creating flexibility to serve younger children:

    The drafts state that the funds will be used to pay for delivering preschool to 4-year old children.

    Recommendation: If State or local preschool programs are serving four and three-year-olds in their preschool programs, they should be allowed to serve eligible four-year-olds and with remaining resources serve 3-year-olds in families under 200% of the federal poverty line. The prekindergarten program is part of a larger continuum of learning that starts at birth, and the earlier children have access to quality experiences the better prepared they will be for school and life successes.

  27. NAEYC is submitting its comments in multiple parts. Please refer to additional NAEYC comments on mixed/diverse delivery systems, NAEYC early childhood program standards and high-quality early childhood programs, and other areas of comment for this blog as well.

    III. Supporting early childhood educators across all settings to reach the teacher qualifications requirement:

    The Congressional report accompanying the fiscal year 2014 appropriations bill that created the Preschool Development and Expansion Grants states that “funds may also be used to help early childhood educators to attain higher credentials and degrees.” This is not reflected in the list of the uses of funds in the Development and Expansion drafts.

    Recommendation: A genuine commitment to a high-quality system of early childhood education, including a diverse delivery system of preschool, requires a commitment to helping teachers earn the required Bachelor degree. Both Development and Expansion rants should require States to spend a portion of the funds to help teachers in child care and Head Start programs meet the degree requirement through scholarships, release time, and other supports. New Jersey’s Abbott preschool program and North Carolina’s state preschool program made this commitment, and their preschool systems are stronger as a result.

    The quality of the teacher-child interaction is the linchpin of quality and deserves more directed attention with these resources. We strongly suggest the following language in the Development and Expansion grants: States are required to use a portion of the quality and infrastructure funds to provide scholarships, release time, and other supports to help teachers in child care and Head Start programs to meet the degree requirement and be given four years of such assistance. States should also be required to use the grant funds on other early childhood workforce support.

  28. NAEYC is submitting its comments in multiple parts. Please refer to additional NAEYC comments on mixed/diverse delivery systems, supporting educators, and other areas of comment.

    II. Aligning to and using NAEYC early childhood program standards to define research-based standards for high-quality preschool and program standards –

    Recommendation:
    The definition of Program Standards and High-Quality Preschool Program should reflect the 10 research-based NAEYC early childhood program standards. (The standards are described at http://www.naeyc.org/files/academy/file/OverviewStandards.pdf) The draft Development and Expansion Grants document names the Head Start program performance standards and the NIEER benchmarks in its state prekindergarten report, but fails to note NAEYC early childhood program standards. There are states that use NAEYC’s early childhood program standards as an eligibility threshold. For example, Connecticut’s School Readiness Program and the newly enacted preschool program in public schools both require providers to meet NAEYC early childhood program standards. Boston Public Schools have committed themselves to NAEYC accreditation for their preschool and kindergarten programs. Their studies show a relationship between NAEYC early childhood program accreditation and children’s better academic outcomes. http://www.bostonpublicschools.org/cms/lib07/MA01906464/Centricity/Domain/111/4-9-12_early_childhood_presentation.pdf

    The 10 NAEYC early childhood program standards – some of which are captured in (a) through (l) – are research-based and have been (externally) tested for their validity as program standards. If the federal government names in the application or accompanying materials private entities that have developed indicators, standards, or benchmarks of program quality, then NAEYC must be named as well. At a minimum, the ten standards areas should be explicitly listed in the definition. The areas not currently listed in the draft include 1) the program establishes and maintains collaborative relationships with each child’s family to foster children’s development in all settings. These relationships are sensitive to family composition, language, and culture 2) The program promotes positive relationships among all children and adults to encourage each child’s sense of individual worth and belonging as part of a community and to foster each child’s ability to contribute as a responsible community member 3) The program uses developmentally, culturally, and linguistically appropriate and effective teaching approaches that enhance each child’s learning and development in the context of the program’s curriculum goal 4) The program effectively implements policies, procedures, and systems that support stable staff and strong personnel, fiscal, and program management so all children, families, and staff have high quality experiences; and 5) The program is informed by ongoing systematic, formal, and informal assessment approaches to provide information on children’s learning and development. These assessments occur within the context of reciprocal communications with families and with sensitivity to the cultural contexts in which children develop. Assessment results are used to benefit children by informing sound decisions about children, teaching, and program improvement. The item (g) on curricula should be modified to “the program implements a curriculum that is consistent with its goals for children and promotes learning and development in each of the following areas: social, emotional, physical, language, and cognitive.”

  29. National Indian Education Association Comments on New Preschool Development Grant Competitions: Development Grants and Expansion Grants as authorized under the Consolidated Appropriations Act of 2014 (Public Law 113-76).

    Native education stakeholders founded the National Indian Education Association (NIEA) in 1969. Today the organization is the most inclusive Native organization in the country representing Native students, educators, families, communities, and tribes. From communities in Hawaii, to tribal reservations across the continental U.S., to villages in Alaska and urban communities in major cities, NIEA has the most reach of any Native education organization in the country. As a membership-driven organization, NIEA’s mission is to advance comprehensive educational opportunities for all American Indians, Alaska Natives, and Native Hawaiians throughout the United States.

    The Federal Trust Responsibility
    For Native students to succeed in education, they must have a strong foundation in early childhood learning. There are nearly 200 tribal head start programs in 27 different states funded by more than 150 grants that serve approximately 42,500 children of Native descent. With roughly 90 percent of Native students attending public schools, this early learning system serves less than 20 percent of the eligible Native children. These students often begin elementary school with fewer opportunities due to economic and geographic barriers that inhibit student readiness.

    Unfortunately, inequality in access to resources persists among Native-serving education institutions as they seek to attain federal funds for initiatives, such as Race to the Top. This is a clear violation of the federal government’s trust responsibility with tribes. Established through treaties, federal law, and U.S. Supreme Court decisions, this relationship includes a fiduciary obligation to provide parity in access and equal resources to all American Indian and Alaska Native students, regardless of where they attend school. While NIEA is happy to see tribes and Indian Head Start programs included in the executive summaries as well as the need to meet the needs of children residing on Indian lands, there continues to be underlying issues with these new grant opportunities.

    Incorporating the recommendations listed below will provide greater access to tribes, build strong foundations for education success, and foster a better educated Native citizenry who will contribute to the overall prosperity of the country.

    Bureau of Indian Education: A State Education Agency
    Similar to rules under Race to the Top grant competitions, the Bureau of Indian Education (BIE) would be ineligible as a state education agency (SEA) for these new grants. This exclusion fails to honor both the federal government’s trust responsibility to provide Native children with a quality education, as well as Executive Order 13592, “Improving American Indian and Alaska Native Educational Opportunities and Strengthening Tribal Colleges and Universities,” which aims to leverage and coordinate federal resources to expand educational opportunities for Native students.

    This disparity in resource delivery abrogates the federal trust responsibility and is working to institutionalize inequality for Native students. While the new grant competitions summaries cite the Elementary and Secondary Education Act (ESEA) to set guidelines for defining Indian lands and local education agencies, the competitions ignore that the ESEA also defines the BIE as a state education agency. For example under State Allotments (Section 1003 – School Improvement), the BIE is named alongside states and outlying areas as recipients of grant funds.

    Under ESEA Section 1821 – Definitions, State is clearly defined as:
    The term `State’ means each of the several States of the United States, the District of Columbia, the Commonwealth of Puerto Rico, the United States Virgin Islands, Guam, American Samoa, the Commonwealth of the Northern Mariana Islands, and the Bureau of Indian Affairs for purposes of serving schools funded by the Bureau.

    While the new grants include Puerto Rico, they continue the Administration’s trend of excluding the BIE from its definition of State. This is unacceptable and must be amended as the Departments of Education (ED) and Health and Human Services (HHS) move forward with this competition. NIEA requests that the BIE be explicitly included in the list of eligible applicants in this grant competition and any other subsequent notice, as well as the Catalog of Federal Domestic Assistance.

    Tribal Consultation
    Indian head start and child care programs, as well as tribal education agencies, have decades of experience providing educational opportunities for American Indian and Alaska Native children. Tribal inclusion in early education is particularly imperative for the goals of the new preschool grant competitions, which seek to prepare more children for kindergarten and build a strong foundation for educational success. For Native students in tribal communities, tribal partnership and input exemplifies locally directed education and is critical to developing a student-centered learning environment that meets Native children’s unique cultural and linguistic needs. While NIEA appreciates the inclusion of tribes and Indian Head Start programs as collaborative partners, the competitions should require tribal consultation with states to guarantee that the competition meaningfully improves our students’ early education outcomes.

    Tribal Support
    The requirement that program standards be “culturally and linguistically responsive” is a good start. However, local tribal support and involvement is imperative to certify that a plan is culturally sensitive for tribal citizens within their early education system. NIEA requests that applications include tribal letters of support to verify tribal involvement. Further, where a state can prove it is partnering with tribes, award preference should be provided to those states in the competition.

    Consider Tribes as Stakeholders
    NIEA appreciates that ED and HHS include Indian children living on “Indian Lands” (as defined by Section 8013 (6) of the Elementary and Secondary Act of 1965) in its definition of “Children with High Needs.” However, states should include tribal leaders and their Native education experts in the development and implementation to ensure the learning and school readiness needs of Native students are properly addressed. To assist tribes and states as they partner, Early Learning Intermediary Organizations under the grants should also include National Indian Education Associations who have the capacity and expertise to deliver services.

    Conclusion
    If you have questions or concerns, please contact Ahniwake Rose, NIEA Executive Director, at arose@niea.org.

  30. NAEYC is submitting its comments in multiple parts. Please refer to additional NAEYC comments on this blog as well.

    I. Strengthening the commitment to mixed delivery system:
    The majority of state and local prekindergarten programs pursue a “mixed delivery” system – child care, Head Start, and school providers who can meet the state quality standards can apply for funds directly or through subcontract. A mixed delivery system has several positive features: it allows parents flexibility in where they will enroll their children and creates seamless experiences in the same setting often from the time the child is an infant. A mixed delivery system also strengthens the entire early childhood system by raising and supporting quality in all settings serving young children. Although the definition of Early Learning Provider is an inclusive list, the mechanism for state-to-local grantmaking is not.

    Recommendation: The Development and Expansion Grant applications should have a competitive priority for States that agree to use these funds for quality support and expanded services across the diversity of child care, Head Start, and school providers. A requirement of a diverse delivery system will result in better quality across the states’ early childhood system, benefit working families who need more than a school-length day for their children’s care and learning, and provide young children with greater consistency of quality care throughout the day and year. The application should be clear that subgrantees can be child care and Head Start programs that meet the quality standards so long as a teacher is enrolled and making progress toward the Bachelor degree requirement. This has been a policy used effectively in some states to build a high-quality, diverse delivery system for preschool.

    In addition, the application should require that States describe how they conducted thorough and transparent outreach to the array of eligible Early Learning Providers to receive funding. The State should collaborate with the Early Childhood Intermediary Organizations to conduct that outreach across all of the types of Early Learning Providers.

    The MOUs, even preliminary, may be difficult to acquire in a short application phase. These letters of intent or MOUs could be required in the 90-day Scope Of Work period. However, they are not necessary for the application. The State will have determined – based on a state needs assessment – a geographic area to serve and the application will also describe uses of funds for quality and infrastructure development, as well as any expanded number of children to be served. While large systems (school districts) can respond quickly to such an MOU request, it will be difficult for state systems to obtain individual MOU’s with the small, independent, and diverse providers intended to participate in a mixed delivery system.

    In order to promote a state-federal partnership, the application should allow states to subgrant in the same manner and to the same diversity of providers as permitted under its current state-funded programs. States should be required to demonstrate the quality commitment that their state systems require in order for programs to be eligible.

  31. On behalf of the America Forward Coalition (http://www.americaforward.org), thank you for the opportunity to provide additional comments on the 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 as you finalize the requirements for the Preschool Development Grants program:

    Encourage Effective Partnerships – Effective external partners provide a range of solutions that can help to provide 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. Accordingly, the America Forward Coalition believes that new early learning programming should provide incentives for effective partnerships between school districts and external partners. Too often school districts are required or incentivized to use federal funding internally when quality external partners could provide effective solutions to pressing needs and supports for pervasive problems.

    While the America Forward Coalition is pleased that the draft Selection Criteria (E. Strong Partnerships between Subgrantees and LEAs or other Early Learning Providers) requires State applicants to describe their plan to ensure strong partnerships between subgrantees, LEAs or other early learning providers, there is no guidance under the Selection Criteria as to how those partnerships should be formed and operate to ensure their success.

    Accordingly, the America Forward Coalition asks that the Department ensure that partnerships at the local level:

    (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.

    Reward Results by Investing in What Works – Early learning programming should focus on results and support organizations that have achieved success. 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 recommends that the Department 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.

    To help implement these strategies, the America Forward Coalition recommends that the Department include “pay for success” contracting to help improve early learning programming. 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 finally, (4) government, and therefore taxpayers, only end up paying for effective programs.

    Promote Innovative Solutions – The America Forward Coalition believes that the Preschool Development Grants program should embrace policies that seed innovation, extract what works, identify why it is successful, and take successful solutions to scale.

    Accordingly, we ask that the program provide enough flexibility to grantees so that they can allocate funds toward 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 new 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.

    Support Effective Teachers and Leaders – The America Forward Coalition believes all students in all educational settings should be served by effective teachers that are knowledgeable about data-driven instruction and are able to develop learning pathways for individual students as well as strong leaders who are able to attract, retain, and support a motivated instructional team, build a strong positive culture, use data to inform every day decision making, and engage families and communities.

    Therefore, the America Forward Coalition is pleased that the draft Selection Criteria (C. Ensuring Quality in Preschool Programs) requires States to describe how it will use funds for quality improvements that include establishing or upgrading preschool teacher education and licensure requirements; improving teacher training programs; and improving professional development programs and practices.

    Thank you again for the opportunity to provide additional comments.

    The America Forward Coalition Education Task Force

  32. The Service Employees International Union thanks the Departments of Education and Health and Human Services for the opportunity to offer the following comments on the Preschool Development Grants Program, Expansion Grants Executive Summary.

    Priorities

    Under the Priority 1 of the draft Expansion Grant Executive Summary, States can use no more than 10% of their federal grant award for preschool program infrastructure and quality improvements. In order to build and retain the well-qualified workforce needed to deliver high quality early childhood programs, the Expansion Grants program must require significant additional investments targeting the existing early childhood workforce.

    Approximately two million early educators currently work in in schools, child care centers, and family child care homes. The current workforce, which is comprised almost entirely of women, ranks among the lowest paid in the nation. These workers will need help to attain the qualifications required under these grants, including financial assistance like scholarships and paid release time

    We urge the Departments to structure the Expansion Grants to require States to use at least 20% of grant funds for preschool program infrastructure and quality improvements and some required portion of program infrastructure and quality improvement funds to help early childhood educators attain B.A.s through scholarships and related support services such as substitutes and paid release time.

    Selection Criteria — Section C. Ensuring Quality in Preschool Programs

    We recommend amending Section C of the Expansion Grants Executive Summary to include the following:

    –States should be required to lay out a plan that describes how they will make investments to support early childhood educators in all settings to meet education standards and receive professional development. State plans should describe how the State will adequately fund and otherwise address areas, including but not limited to: scholarships, financial incentives to reward progress towards degree attainment, paid release time and/or substitutes.

    –State plans should consider cultural and linguistic competency in the workforce and address the current workforce demographics and an approach to support a culturally and linguistically diverse workforce.

    Selection Criteria — Section D . Collaborating with Subgrantees

    In order to support and encourage the continued delivery of preschool through schools and community-based settings (licensed child care centers and family child care homes), we urge the Departments to amend Section D of the Expansion Grants Executive Summary to require States to describe how they will ensure the participation of a wide range of types of preschool providers and their plan to distribute grant funds to qualified programs across all settings, including community-based providers (child care centers, family child care and Head Start), local school districts and schools.

    Definitions

    The definition of a High-Quality Preschool Program should be amended to allow States to sub-grant funds to community-based providers if they have a teacher enrolled in a B.A. program and making progress to the degree, with incremental parity of compensation as the degree is pursued.

  33. As a Territory of the United States., the U.S. Virgin Islands has been excluded in this initiative. Unless there are other funding streams we should be focusing and which we have inadvertently overlooked, we too have a large unmet need. I am truly baffled as to why “our children” and this U.S. Territory is not eligible for the same opportunities for high-quality early learning programs. I ask that this Territory’s eligibility be reconsidered.
    Thank you

  34. May 16, 2014

    Secretary Arne Duncan
    U.S. Department of Education
    400 Maryland Avenue, SW
    Washington, D.C. 20202

    Dear Secretary Duncan:

    On behalf of the BUILD Initiative, an organization dedicated to supporting state leaders’ efforts to develop comprehensive early childhood systems tailored to the needs of their state’s young children and families, we are pleased to submit comments on the Preschool Development Grants authorized in the Consolidated Appropriations Act of 2014. We applaud the Administration’s continued efforts to provide states with an opportunity to transform their early childhood systems in a significant way. These grants, combined with the other early childhood initiatives of the Administration, will do much to expand and improve the early learning and development experiences of our youngest children.
    We also want to recognize the coordination and collaboration between the Department of Education and Health and Human Services. This framework reflects joint values and priorities focused on aligned systems that bring together all the various components of early childhood systems in states.
    Before moving on to specific recommendations, BUILD would like to again strongly urge all efforts to maintain, and strengthen a systemic approach, which was so well represented by the RTT-ELC competition that is helping now 20 states accelerate systemic work to support children birth to five with high needs. The systemic focus of Early Learning Challenge is efficient and makes great sense for what could be one-time money. Our early efforts to document the impact of Early Learning Challenge are extremely encouraging. States are building the infrastructure, making system component revisions, and testing ways to improve quality so that the early learning system can thrive, be sustained, and advance toward equitable outcomes for young children. It is precisely these types of changes (program standards, professional development systems, educator qualifications, and comprehensive screening and assessment systems, e.g.) that will lead to sustainable high-quality services for all children, including children served in state pre-K.
    The following is a series of comments and suggestions that the BUILD Initiative believes would strengthen these pre-K grants even further:
    • Greater flexibility for states to determine the appropriate balance between quality improvement/infrastructure spending and subgrants for new slots:
    o Both the development and expansion grants provide rigid percentages in terms of how federal funds maybe used within the grant period, which could serve to be a burden for states when thinking about how to best spend dollars in ways that can lead to sustainable improvements in their states. The Departments should give states even more flexibility in decided between the best uses of federal dollars that lead to improvements in pre-K quality and access.
    • Serving three year olds:
    o More than half the states currently providing pre-K programming include services for three year olds (NIEER, 2014). Research such as the Early Head Start Impact Study (2010) and others have clearly demonstrated that for high-needs children, there are increased gains when participating in high quality early childhood programming for at least 2 years. States should be allowed the flexibility to serve 3 year olds, provided the programming is developmentally appropriate and includes age appropriate staff to child ratios and group sizes.
    • Impact on the Local Early Education and Care Systems:
    o Throughout the competitive priorities and the selection criteria, the importance of collaboration and alignment with other parts of the early childhood systems is well articulated. As proven in states where public pre-K is already established, there can be significant community tension when an LEA chooses to establish a program and does not consider the impact upon the existing child care market in the community. We strongly urge the Department to include a requirement of an assessment of the current availability of high quality privately operated pre-K programs, including Head Start, within a selected community or region, as well as the amount of regulated child care available for infants and toddlers. This requirement would emphasize the importance of a birth to 3rd grade systems perspective beyond the competitive priority. This will expand the awareness of K-12 leadership of the extensive opportunities available for services coordination, provision of comprehensive services within a pre-K model, and work toward promoting successful transitions from infant and toddler services to pre-K.
    o Collaboration with Head Start programs and leveraging Head Start resources are encouraged through the notice. And, states are also encouraged to integrate Eligible Children within economically diverse, inclusive settings, including those that serve children from families with incomes above 200% of the federal poverty line. Head Start programs and states can collaborate towards these goals with clear encouragement from the Departments regarding support for innovative blended funding models and simplified cost allocation methodologies that result in greater ability for Head Start programs to enroll more children in economically diverse classrooms. In addition, states that propose plans that to create opportunities for continuous birth to five services for families through collaborations with EHS- Child Care Networks and preschool development grant subgrantees should be at a competitive advantage in this competition.
    • Community Collaboration:
    o We strongly recommend that Memorandums of Understanding (selection criteria D (4) require states and subgrantees to specify data exchange and plans related to the following: formative assessment, professional development, curriculum/instructional tools, family engagement, cross sector and comprehensive services efforts, and workforce and leadership development.
    o While family engagement is represented with the definition of TQRIS, we strongly urge that the Department require States to describe a plan for parent engagement at the state and local levels, similar to the requirements established in Title I and the Head Start standards.
    o We are concerned that the timeline for implementation will not allow for the development of successful community partnerships, and thus many school districts will be unable or unwilling to develop community based pre-K models. Therefore, we urge the Department to include a competitive advantage for those proposals that demonstrate a diverse delivery system in collaboration with existing early childhood programs and a mix of full and part day programming. No one program can meet the needs of every family, and the options need to be strengthened; not made so uniform that it becomes too unyielding for our most complex families. To that end, the Department should also provide a clear definition for “full day” programming. If the Department chooses the typical school day of not less than five hours as “full day,” those proposals that provide before and after care in the same location as the pre-K program should also receive competitive advantage. The number of daily transitions a child experiences when going from child care to pre-K and then back to child care causes stress and is counterproductive to successful learning experiences.
    • School Readiness:
    o Because school readiness is the responsibility of communities, families, early childhood providers and schools, we recommend that the Department consider requiring that LEAs work with community leaders and early childhood providers to develop a common and comprehensive understanding of school readiness that can be reflected in a horizontal and vertical alignment of curriculum, assessment, and program standards.
    • Systems Infrastructure:
    o We strongly support the requirement of reserving funds to strengthen infrastructure, however, we are concerned that percentage will be too limiting for some states. We recommend the department require states to describe how they will build from and align with existing systems such as the professional development delivery system funded with CCDF, the licensing and monitoring systems for child care, the TQRIS, and the K-12 IDEA monitoring and professional development system. The Grant presents a tremendous opportunity for states and local communities to move closer to the desired horizontal and vertical alignment of systems serving children birth through third grade.
    o We strongly urge that a portion of the 10% investment in infrastructure include leadership development and training for principals and superintendents to increase their awareness and understanding of early childhood best practices. States that have taken this approach, such as New Jersey, have seen significant gains in the capacity of LEAs to implement and sustain developmentally appropriate pre-K programs.
    • Ensuring Participation of Children Most Likely to Benefit:
    o As the Future of Children report on racial and ethnic disparities in school readiness estimates, high quality preschool experiences can reduce the gaps experienced by African American and Latino children – if all were able to participate – by somewhere between 20 and 39 percent overall. This reduction will not be achieved unless there are concerted efforts to engage these children and address the barriers (transportation, language, and social distance) to participation. Without concerted attention, simply expanding preschool on a first-come, first-served basis will do little to address (and may even exacerbate) disparities in certain populations, particularly those who have been subject to historical discrimination or marginalization.
    o Poverty or low-income status is a very crude measure of need, particularly as nearly half of all young children reside in households below 200 percent of poverty. As part of states efforts to target high need communities, the federal guidelines should emphasize that states need to describe how their plans take into account participation disparities and how the proposed expansion works to close gaps in participation and readiness by race, language, culture, and socio-economic status.
    • And, ensure that teachers are prepared to work with dual language learners.
    o States should articulate specific plans to create a workforce that is well prepared to serve dual language learners. This could include certifications, endorsements in bilingual education, or professional learning experiences that prepare teachers to support first and second language development, including through partnerships with families.
    • Defining High Needs Communities:
    o If States are provided the flexibility of defining High Needs communities, we suggest that all communities meeting that definition be identified by the State and rationale provided for the two communities or regions selected to benefit from this funding. Additionally, as part of the sustainability plan within the proposal, clearly defined goals for extending the reach of this effort to the other High Needs communities in the State should be required.

    Thank you for this opportunity to provide comment and suggestions to this very important event in the evolution of our nation’s early childhood system. We look forward to supporting states and communities as they take advantage of this opportunity.
    Sincerely,

    Susan G. Hibbard
    Deputy Director
    The BUILD Initiative

  35. The Hawaiian Medium Education Consortium is grateful for the opportunity to provide the following comments regarding the Preschool Development Grants Executive Summary.

    Organizations Providing Comments: The Hawaiian Medium Education Consortium – (1) ʻAha Pūnana Leo Hawaiian Language Statewide Preschools, (2) Nāwahīokalaniʻōpuʻu Public Charter School and (3) University of Hawaiʻi at Hilo’s Ka Haka ʻUla O Keʻelikōlani College of Hawaiian Language – of the National Coalition of Indigenous Language and Culture-Based Education.

    Purpose: The following comments address the area of DEFINITIONS in the Development Grants Executive Summary.

    Rationale for Definition Expansion: The Native American Languages Act of 1990, PUBLIC LAW 101-477, recognizes the unique status of Native American culture and languages. According to the law, it is U.S. federal policy to “preserve, protect, and promote the rights and freedom of Native Americans to use, practice and develop Native American languages.” NALA further declares U.S. federal support for the “use of Native American languages as a medium of instruction” (NALA, 25 U.S.C.2903). It also states that the United States shall fully recognize the right of Indian Tribes and other Native American governing bodies, States, territories, and possessions of the United States to take action on, and give official status to, their Native American languages for the purpose of conducting their own business. In 2010, President Obama signed on to the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) of which Articles 13 and 14 declare that States take effective measures for indigenous individuals, particularly children, to have access to an education in their own culture and provided in their own language.

    Hawaiian and English are official languages in the State of Hawaiʻi. The State’s early learning system includes Hawaiian language medium of instruction, similar to Puerto Rico’s Spanish language medium of instruction. Therefore, official languages of states, territories, and tribes must be provided for in the Preschool Development Grants Program and Executive Summary.

    The Preschool Development Grants Program and Executive Summary should expand definitions for Early Learning Intermediary Organization and Early Learning Provider. The No Child Left Behind Act of 2001 Title lll Section 3301 (10) includes a definition for Native Hawaiian Language Educational Organizations which should be included in the definitions and listed under Intermediary Organizations and Early Learning Provider.

    The inclusion of the following revisions aligned to the NALA, UNDRIP and NCLB Title lll Section 3301 (10) will demonstrate that effective measures are being taken to ensure an inclusive comprehensive early learning system that reflects the official languages of states, territories and tribes.

    DEFINITIONS (pages 18-23 of the Development Grants Executive Summary)
    Based on the rationale, the following revisions are added IN CAPITAL LETTERS.

    Comprehensive Early Learning Assessment System means a coordinated and comprehensive system of multiple assessments, each of which is valid and reliable for its specified purpose and for the population with which it will be used, IN ENGLISH OR OTHER OFFICIAL LANGUAGES OF STATES, TERRITORIES, TRIBES, that organizes information ..…

    Early Learning and Development Standards means a set of expectations, guidelines, or developmental milestones IN ENGLISH OR OTHER OFFICIAL LANGUAGES OF STATES, TERRITORIES, TRIBES that – …..

    Early Learning Intermediary Organization means a national, statewide, ….. the National Indian Child Care Association and NATIVE HAWAIIAN LANGUAGE EDUCATIONAL ORGANIZATIONS.

    Early Learning Provider means an entity that carries out an early childhood education program, including ….. tribes and Indian organizations, institution of higher education, NATIVE HAWAIIAN LANGUAGE EDUCATIONAL ORGANIZATIONS, and other eligible providers as defined by the State, or a consortium thereof.

    Essential Domains of School Readiness means the domains of language and literacy development IN ENGLISH OR OTHER OFFICIAL LANGUAGES OF STATES, TERRITORIES, TRIBES, cognition and general knowledge …..

    High-Quality Preschools means …..
    (g) Developmentally appropriate, evidence-based curricula and learning environments that are aligned with the State Early Learning and Development Standards, APPROPRIATE FOR STATEʻS OFFICIAL LANGUAGES, for at least the year prior to kindergarten entry;

    Kindergarten Entry Assessment means …..
    (d) Is valid and reliable ….. and aligned to the Early Learning and Development Standards APPROPRIATE FOR STATEʻS OFFICIAL LANGUAGES.

    Program Standards means the standards that serve as the basis for a TQRIS and define differentiated levels of quality for Early Learning and Development Programs IN STATEʻS OFFICIAL LANGUAGES.

    Tiered Quality Rating and Improvement System (TQRIS) means the system through which the State uses a set of progressively higher Program Standards APPROPRIATE FOR STATEʻS OFFICIAL LANGUAGES to evaluate the quality of an Early Learning and Development Program and to support program improvement.

  36. Easter Seals Comments to US Departments of Education and Health and Human Services
    regarding the Preschool Development Grant Program
    May 15, 2014

    Easter Seals (www.easterseals.com) thanks you for this opportunity to provide comments on the Preschool Development Grant Program. Last year, some 40,000 infants and toddlers got a great start in life with early intervention services provided by Easter Seals affiliates. In addition, Easter Seals operates the nation’s largest network of inclusive child care centers, providing full day, full year, high quality early education services to children with and without disabilities together. Easter Seals is currently in the evaluation process of a professional development protocol designed to help child care staff meet the needs of young children with disabilities and their families.
    Priority 1: Absolute Priority- Building a High-Quality Preschool Program: In order for any preschool program to be truly high quality, it must physical and program access for young children with disabilities. Services to such children through the Individuals with Disabilities Act contribute significantly to the overall quality of any early education program thanks to the expertise of special education service providers, such as occupational, speech and physical therapists who will work in collaboration with general education staff to shape and direct the curriculum so that all children can participate fully. We recommend that all applicants affirm how children with disabilities will be included in all activities supported with this grant program.
    Priority 3: Competitive Preference Priority – Support a Continuum of Early Learning and Development: Easter Seals strongly supports this priority. It is essential for early education services providers that are not part of the local education agency be full partners in the delivery of preschool services. In addition to providing direct services to children and families, many Easter Seals affiliates offer professional development training through the Training Modules for Inclusive Child Care that provide hand on guidance on how to effectively meet the needs of young children with disabilities in child care settings. Moreover, Head Start is also an essential partner, as nearly 170,000 young children with disabilities receive their special education services in a Head Start classroom. Lastly, working families must be accommodated and the grantees must work to expand full day, full year services to young children.
    D. Collaborating with Subgrantees: Easter Seals supports the requirement that subgrantees will deliver services to eligible children who may need additional supports, including children with disabilities. (item 3). Subgrantees should set out the specific actions it will take to ensure that preschoolers with disabilities who have Individual Education Plan (IEPs) through the Individuals with Disabilities Education Act (IDEA) can receive such services in all available preschool programs, including those programs not operated directly by the local education agency. Similarly, infants and toddlers who receive services in accordance to an Individualized Family Services Plan under Part C of IDEA must also be served in all programs funded through the Preschool Development Grants that also serve infants and toddlers. (item 4,i)
    Program Requirements: Easter Seals concurs that states that receive preschool development grants must continue to participate in Part C of IDEA.
    Comprehensive Services: Easter Seals concurs that comprehensive screening must be included in such services. Easter Seals currently offers the Ages and Stages Questionnaire free on its website in both English and Spanish as we believe families of young children need this basic information on their child’s development throughout the first five years of life.
    Katy Beh Neas
    Senior Vice President, Government Relations
    Easter Seals
    1425 K Street NW, Suite 200
    Washington, DC 20005

  37. The American Association of Christian Schools (AACS) strongly urges the inclusion of language in the application guidelines for the Preschool Development Grants Competition which clarifies the importance of diversity in early education programs and protects the autonomy and mission of private and faith-based preschools. The AACS is a national organization with just over 800 Christian schools nationwide, many of which include early education opportunities in both urban and rural areas. Like many other private, faith-based centers, our Christian preschools meet the needs of a wide range of families from all levels of income and offer small class sizes, low teacher-student ratios, and a variety of educational and extra-curricular opportunities that strengthen the overall educational experience for their students. Since non-public schools like ours make up the majority of existing early education providers, we are keenly interested in policies that may impact these schools.

    Specifically, we urge guidance for states which clarifies that they have the freedom to allow for exemptions for faith-based “Early Learning Providers,” as this term is defined in the Executive Summaries. The definition for “Early Learning Provider” includes any entities that are “licensed child care provider(s).” Many states currently require that all preschool programs, including privately funded and faith-based, be licensed by the state. In the previous rounds of Race to the Top-Early Learning Challenge competitions, the Department of Education offered clarification that states were not required to include private or faith-based early education programs or preschools in their reforms and could include an exemption for religious programs when requiring and monitoring licensure of preschool centers and programs. It is vital to the continued success of the vast number of these existing private and faith-based preschools and programs that their autonomy be protected and maintained. We strongly urge explicit clarification in the Final Application Guidelines for the Preschool Development Grants that private programs which qualify as Early Learning Providers are allowed to maintain their autonomy and mission.

    Inclusion of such language will ensure that states and local education agencies recognize and demonstrate strong partnerships with Early Learning Providers and will also show support for high-quality programs and services that are already evidencing great success in the education and care of young children. Without this provision, private programs already providing quality care could be forced out of the market and overall access and choice will be diminished—leaving parents with limited options for their children.

    The State of Florida provides an exciting example of a program that has been successful in expanding early education access and choice for families by collaborating with private and faith-based Early Learning Providers. Florida’s Voluntary Prekindergarten (VPK) education program allows parents to choose from a wide variety of options for the best educational choice for their children. The options include private and faith-based programs with an allowance for these schools to maintain their religious character and mission. This diverse program is successful because it recognizes the vital role and primary responsibility of parents in children’s education, and the importance of protecting the diversity, autonomy, and mission of successful private, faith-based programs.

    The autonomy of private, faith-based centers is vital to their success as it affords them the opportunity to follow their faith convictions in offering high-quality educational programs. These schools evidence quality care and high academic achievement and are committed to supporting parents in their vital role as the primary caregivers of their children. Their autonomy gives these schools the freedom and flexibility to employ highly qualified teachers that best align with the school’s mission and vision, to utilize educational methods that best meet the various learning styles presented by each individual student, and to implement high standards and educational programs that best meet their unique mission. Often these schools provide a continuum of education from preschool into elementary and through high school, which gives teachers time and opportunity to collaborate on the best methods for educating these children. This collaborative system has shown great success in producing graduates who are college and career ready. Federal policies that exclude faith-based providers as an early educational option for families break this important educational continuum to the detriment of children. For religious preschools and early education programs, the freedom to follow their faith-based mission is paramount to the excellent quality, care, and safe environment of their schools and the successful achievement of students.

    As the competition guidelines are finalized, it is vital that the final application guidelines for the Preschool Development Grants include explicit language which allows for the protection of the autonomy and mission of private, faith-based centers while encouraging states to include diverse options for parents. This will serve to enhance the educational opportunities that are available for low- and middle-income families, show support for existing centers, and allow for the continuing diversity in our American educational system that allows it to thrive.

  38. I work in a SEA in an eligible state and have reviewed the Executive Summary for the Preschool Development Grant.
    -It is difficult for me to see that these activities must be targeted at High-Need Communities, when our state, as a whole, receives absolutely no state funding for pre-kindergarten programs. Our entire state is a “high-need community!”
    -Additionally, I would like to speak to the fact of having to secure MOUs as part of the application process. I believe this is problematic. If we were not to receive an award under this grant, we would have to deliver the bad news to those administrators/directors who entered in to MOUs with the SEA. These same administrators/directors are already constantly disappointed and frustrated with the complete lack of state support and the limited federal support for early learning; it certainly could strain those relationships that we are trying so desperately to maintain or improve.
    -I also take issue with the competitive preference allowance for programs in Promise Zones. There have only been 5 identified by the Obama Administration, 4 of which are located in urban areas. Our state has 3 of the poorest counties in the US. It’s difficult for me to accept that a designation of Promise Zones automatically guarantees those states with additional preference points.
    -Our state is still working on an SLDS system that links with EC data. I was unsure from the Exec Summary whether the linked SLDS must be fully operating to apply, or whether this is something that can be in progress and the state can demonstrate that they are making progress on this front. With absolutely no state funding, developing this type of system is extremely difficult-it’s a priority, but of course you need the money to implement this type of system. Please clarify what exactly the prerequisite regarding a linked data system is.
    -Additionally, while all of us in the ECE field know that a full-day program produces the best child outcomes, it will be difficult to garner support for this. The context here is that most communities have no pre-kindergarten programs, so making that jump immediately to a full-day program could be a barrier. Half-day programs in these high need areas would be a huge step in itself.
    -I apologize for coming across as negative, but hopefully this is constructive criticism. Overall we are thrilled to have this opportunity!

  39. Thank you for the opportunity to provide comment on the development and expansion of high quality preschool programs funded by the Preschool Development Grants program. As a child care health consultant working for a local health jurisdiction I was pleased to see inclusion of both healthy eating and physical activity as components of comprehensive services to be offered by these programs. However in light of the current obesity epidemic impacting preschool age children I would like to see those topics expanded to include the standards outlined in the Let’s Move Initiative for Early Care and Education promoted by First Lady Michelle Obama and/or the national standards contained in “Preventing Childhood Obesity in Early Care and Education Programs”: Selected Standards from Caring for our Children: National Health and Safety Performance Standards, 3rd edtion. These standards include some of the following:
    1) Provide access to water throughout the day;
    2) Serve meals “family style” where caregivers/teachers sit at the table and share the meal or snack together with the children. Family style meal service promotes and supports social, emotional and gross and fine motor skills development;
    3) Food, water or active play are not restricted from children as punishment;
    4)Limit screen time for children over age 2 years to no more than 30 minutes per week during child care and work with parents/caregivers to ensure that children have no more than 1-2 hours per day of quality screen time.

    Thank you for your consideration of these important topic areas.

    Adrienne Dorf, MPH, RD
    Child Care Health Consultant
    Public Health Seattle and King County

  40. 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.

    Waterford is pleased that the statutory language under the FY 2014 Consolidated Appropriations Act (PL 113-76) allows a State to subgrant funds to LEAs and other early learning providers and that subgrantees that are LEAs “shall form strong partnerships with early learning providers” in order to carry out the requirements of the subgrant.

    Waterford believes that effective external partners 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, we are encouraged that the Eligibility Requirements under (b)(1) of the Executive Summary include an assurance that subgrantees that are LEAs will form strong partnerships with other early learning providers, and subgrantees that are early learning providers will form strong partnerships with LEAs, to help ensure successful transitions for children from preschool to kindergarten. In addition, Waterford is pleased that the definition of “early learning provider” under the Executive Summary means an entity that carries out an early childhood program, including providers as defined by the State. We believe these types of decisions should be made at the State and local level and are pleased that the Executive Summary provides for flexibility in the types of partners that can participate in the program.

    To help bolster early learning outcomes, Waterford recommends that the Department include incentives under the Preschool Development Grants program to encourage 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, Waterford believes that the coordination and collaboration activities between LEAs and early learning providers under (E)(2) of the Selection Criteria of the Executive Summary should include the “essential domains of school readiness” (which include language and literacy development, cognition and general knowledge) to help ensure that grant activities include a focus on cognitive gains as well as comprehensive support services.

    Since the program will be developed and implemented in significant part by the Department of Education, Waterford recommends that the new competition also include a competitive preference priority for grantees and subgrantees that address academic achievement and can demonstrate meaningful cognitive gains for children that participate in the program.

    To help implement new programming in a cost-effective manner, Waterford believes that the Department should encourage approaches and partnerships that utilize technology to personalize learning. In recent years many federal programs geared toward supporting digital media and technology have had funding decreased or completely eliminated. However, given the new challenges faced by our educational system, we’re seeing a renewed interest in supporting innovation in learning through the use of digital media and technology. Accordingly, Waterford believes that new early learning programming should explicitly support the use of digital learning to help transform teaching and learning in early childhood education.

    By encouraging the use of digital learning to help transform teaching and learning in early childhood education, the Department can also increase the likelihood that families living in rural areas will have access to high-quality early learning services.

    Serving children in center-based, early childhood education programs in rural areas is challenging and Waterford believes that technology and family- or home-based solutions can help to educate children that live in rural areas in a cost-effective manner. We agree with Secretary Duncan’s comments regarding the New Narrative of Rural Education on October 31, 2013 when he said he believed “that traditional formula funding must be supplemented with competitive funding and incentives for change – with appropriate priorities for rural areas to help ensure a level playing field.” Accordingly, Waterford believes that new early learning programming should prioritize funding for rural areas and ensure that grantees have adequate flexibility to design and implement programs based on local needs.

    Finally, Waterford believes that the Department should focus on evidence and results for new early learning programming, including through “pay-for-performance” initiatives. Historically, the federal government has supported programs regardless of whether the services delivered actually achieved results, as long as providers met federally-prescribed rules that generally focused on inputs.

    Waterford believes that grantees should be able to design evidence-based programs in a flexible manner that ultimately focus on early learning results, as opposed to federally-prescribed inputs. Too often, federal programs contain lengthy checklists of requirements, but pay-for-performance initiatives have the potential to change the status quo by ensuring that federal funding is actually linked to results and outcomes, not primarily on inputs and federal requirements.

    Accordingly, Waterford is supportive of pay-for-performance and other related policy models that ensure government dollars are spent in an effective manner on programs that achieve the intended results for the people they serve and would encourage the Department to consider this approach in developing the program.

    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

  41. I think it is very important that all of our communities have the ability to sustain and/or implement high quality preschools. This will ensure that most of our students are provided with excellent developmentally appropriate learning opportunities. It will allow us to also provide interventions for those students that have special needs in a place with their peers. The social and emotional aspect alone is in dire need, in order for young children to be able to function in a kindergarten class where the expectations have become higher.

  42. The Council for American Private Education (CAPE) is pleased to submit to the Departments of Education and Health and Human Services this response to the Preschool Development Grants Executive Summary. We have crafted the response in the form of recommendations regarding the program’s final requirements, priorities, selection criteria, and definitions, which are to be published later this year.

    1. 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, assessment system, and 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.

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

    3. 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.

    4. 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.

    5. 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 and 35 state affiliates serving private elementary and secondary schools. There are 31,000 private schools in the United States; one in four of the nation’s schools is a private school. About 5.3 million students (10 percent of all PK-12 students) attend them. CAPE member organizations represent about 80 percent of private school enrollment nationwide.

    According to the National Center for Education Statistics, in 2012 over 16,309 private schools had nursery or pre-K programs, enrolling over 709,024 children. NCES estimates 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.

  43. I think that Institutions of Higher Education should be eligible to apply for these development and expansion grant as they partner with SEAs and LEAs. The synergy between the two has been shown in multiple school reform studies to bring about exceptional results, and better results, than when the two operate in isolation from one another. As Dewey once said, “There’s no lower and higher education, just education.”

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