Expansion 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 that have more robust State-funded preschool programs or that have been awarded a Race to the Top – Early Learning Challenge grant will be eligible to apply for Expansion 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 Expansion 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: An Expansion Grant is to support a State with a State-Funded Preschool Program OR that has received a Race to the Top – Early Learning Challenge grant to—

  • Implement and sustain High-Quality Preschool Programs to reach and serve additional Eligible Children in two or more High-Need Communities; and
  • Enhance preschool program infrastructure and make quality improvements to deliver High-Quality Preschool Programs.

Eligibility Requirements

Award Information

Application Requirements

Priorities

Selection Criteria

  • A) Executive Summary
  • B) Commitment to State-Funded 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

34 Comments

  1. 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.

  2. As a member of the Governor’s Council on Early Childhood Education for the U.S. Virgin Islands, I was saddened but not shocked to learn that once again, the discriminatory and colonial mentality that has contributed to the ongoing suppression of the US Virgin Islands and other territories ability to participate as full partners in the United States is alive and well. What ever decision making contributed to the exclusion of these populations, who by every measurable standard benefit most from early childhood intervention, while being some of the neediest in the entire United States, can only substantiate the belief that the Virgin Islands is intended to remain “unequal”. It has been the stated intent that the Virgin Islands continue to move towards self sufficiency. That can only be achieved by a well educated population, which has been recognized since its purchase in 1917. To observe that we are still fighting the struggle for equal access to such a significant program as expansion of preschool grants is an incredibly sad testament to the documented but not widely publicized policy that the Virgin Islands and other territories were NEVER intended to attain full equality. It is my hope as my colleagues have said, that the decision makers will reconsider the exclusion of the US Virgin Islands and other territories from this funding opportunity, or alternately identify another source of funding that will allow us to continue to improve and expand our early childhood education, the foundation of success for our community.

  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. On behalf of the Cleveland Early Childhood Compact, thank you for the opportunity to provide feedback on the requirements, priorities, selection criteria, and definitions in the expressed in the draft Preschool Expansion Grants Executive Summary.

    The Cleveland Early Childhood Compact is the entity monitoring and overseeing the implementation of PRE4CLE, the city of Cleveland’s high quality preschool plan for 3 and 4 year olds. Membership on the Compact includes business, labor, faith-based, corporate, civic, philanthropic, local government, education, literacy, neighborhood and media leaders dedicated to bringing universal high quality preschool to Cleveland’s young children. PRE4CLE is one of the pillars of the Cleveland Plan for Transforming Schools, our city’s comprehensive P-12 education reform initiative. More information and a full copy of the PRE4CLE plan is available at: http://www.clevelandmetroschools.org/pre4cle.

    These comments provide recommendations regarding the final program requirements and components of the forthcoming Preschool Expansion Grants Program.

    1. We strongly support the proposed requirement of using a timely, high quality data collection method to show student progress from prenatal through third grade. We believe that each community identified in the state’s application should have robust ability to track this criteria for its program.
    2. Along with community specific data to track student progress, we recommend that communities demonstrate the ability to robustly track all identified outcomes related to the program at the community level.
    3. We strongly support the prioritization of: Implement and sustain High-Quality Preschool Programs to reach and serve additional Eligible Children in two or more High-Need Communities; and believe this is essential to enable rapid and efficient expansion of high quality preschool. We urge the Departments to limit the number of communities to 2-3 communities so the limited funds can be used to achieve some degree of scale in high need communities.
    4. We strongly endorse the commitment to the highest quality as outlined in the draft on page 23 but would recommend allowing communities to move to this standard during the course of the grant period, while still indicating a current commitment to high quality. In Ohio, we have a 5 star QRIS program, with genuine high quality being defined at the 3, 4, and 5 star level. PRE4CLE has a minimum requirement for participating providers to have a 3-star rating with a strong plan to move up to 4 and 5 star ratings. This is done, for example, through a commitment to professional development, support for educational attainment, and supplemental wages, among other strategies. We would urge the departments to set a similar threshold in the Preschool Expansion Grant.
    5. Can further guidance be provided on what constitutes acceptable matching funds? For example, are state funds appropriated in 2013 but spent for the first time in 2014 eligible? Are in-kind contributions eligible? We advocate that all matching funds be actual cash investments, not in-kind support.

    Thank you again for this opportunity. We appreciate you taking the time to review our recommendations and encourage you to contact us if you have any questions.

  5. 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

  6. 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 17). We suggest adding “and museums” after “libraries” in that same section.

    Our remaining comments focus solely on the definitions that begin on page 20 of the Expansion Grants Executive Summary document.

    • Under item “b” of the definition of “Comprehensive Services (page 20): 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 21): 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 23): “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 25): 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

  7. Comments on Preschool Development Grants from the Children’s Defense Fund

    The Children’s Defense Fund (CDF) is pleased to have the opportunity to submit comments on the Department of Education’s Executive Summary of the Preschool Development Grants program. CDF appreciates the consideration given to our earlier comments reflected in the executive summaries for both the Development grants and the Expansion grants to be awarded under the new program. We believe these new investments will help increase access to high quality early childhood development and learning for poor young children and strengthen the infrastructure needed to ensure quality programs for children long-term. They also will encourage partnerships among the components of a high quality early childhood continuum for children from birth through third grade.

    Our recommendations below are intended to further support the goal of providing a continuum of high quality care to more children from birth through age 5 and in many of our poorest communities. There is strong evidence of the benefits to young children, families and communities when such investments are made. Our comments apply to both categories of grants and are divided by the sections of the summary to which they refer, including Selection Criteria, Program Requirements and Definitions.

    Selection Criteria

    CDF is pleased by the criteria the Department highlights as part of its selection process for grant awards. The executive summary recognizes the importance of building on existing networks of early childhood service providers in the state and facilitating partnerships between various early childhood services to create an aligned system of care from birth through age 5. It also recognizes the importance of having states demonstrate how they plan to maintain or expand preschool services after the grant period ends, particularly when additional funding is not guaranteed.

    It is important, however, to ensure that full-day kindergarten is included as part of an effective continuum of early childhood development and learning. CDF appreciates the Department’s acknowledgement of a continuum of early learning programs serving children and the attention given to full-day kindergarten in the competitive priorities for the new funding. CDF recommends attention to full-day kindergarten be further strengthened in Section F of the Selection Criteria – Alignment within a Birth through Third Grade Continuum. States should be required to demonstrate how they will expand access to full-day kindergarten, starting in high-needs communities, in their ambitious and achievable plans to align preschool programs with a birth through third grade continuum of programs. With only 11 states and the District of Columbia requiring by law that school districts offer full-day kindergarten, it is essential that states attend to this missing half-step as they work to expand access to quality full-day preschool programs for 4-year-olds to help children transition to kindergarten and the early grades.

    Program Requirements

    CDF supports many of the requirements to help ensure quality that states and subgrantees must meet to receive funds under the new Preschool Development grant program. In particular, the focus on data sharing and cross state-evaluations will help ensure states can build on each others’ successes, strengthening the quality of early childhood services across the country. The Department’s requirement that these new funds be used to supplement, not supplant any other funds spent on early childhood will help ensure more children will be served and the quality of care improved.

    The one concern CDF has with this section is the requirement that the state have an established Longitudinal Data System linking early childhood data with the state’s K-12 data system before receiving funding. We recognize the critical importance of developing these coordinated data systems if children are to fully benefit from these early investments longer term. However, especially in the case of the Development grants, the Department might consider making the establishment of such a data system a competitive priority instead of a requirement and ask states to specify in their application a timetable and implementation plans for the data system. CDF appreciates the Department’s efforts to maximize the number of states eligible to receive awards to develop high quality preschool under this new program and would not like to see this data requirement discourage or preclude any state’s participation.

    Definitions

    CDF greatly appreciates the focus on quality and serving the most vulnerable children in this section. By targeting children below 200 percent of the poverty line and defining a quality preschool program as one which meets standards based on research and builds in access to comprehensive services, including family engagement, the Department ensures that the limited new funding available under this program will be spent as effectively as possible. Furthermore, by aligning these requirements with those included in the Strong Start for America’s Children Act, the Department guarantees that these grants set the stage for a further anticipated expansion of high quality preschool to reach many more children.

    Research shows that poor children in high-needs communities, particularly communities of concentrated poverty, often face greater challenges than other poor children. CDF appreciates the Department’s recognition of this fact in its requirement that states target their new investments toward communities with high-needs. This provision would be further strengthened if states were encouraged to focus on communities with high concentrations of poverty in defining high-needs communities. Recognizing the importance of discretion for states as they decide how to use these new funds, CDF recommends that states in describing their definition of high-needs communities include communities that are eligible for the maximum weight in the determination for concentrated poverty in the Title I education program or specify why they are not targeting funds on children in those communities. This provision would further help the Department ensure that new funding is going to the communities where it is most needed.

  8. 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

  9. 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.

  10. On behalf of the New Mexico Children, Youth and Families Department (CYFD), I am pleased to submit comments with regard to the proposed criteria contained in the Preschool Development Expansion Grants program Executive Summary posted by the U.S. Departments of Education and Health and Human Services.

    We offer the following recommendations for you to consider as you finalize Preschool Expansion Grant criteria:

    1) Teacher Qualifications: Under the definition of “High-Quality Preschool Programs”, the Departments propose high staff qualifications “including a teacher with a bachelor degree in early childhood education or a bachelor degree in any field with a State approved alternate pathway…” .

    In New Mexico, lead teachers in public school PreK programs must have a bachelor’s degree and licensure in early childhood education. Teachers who do not meet these qualifications or who have an elementary education or special education license are required to take early childhood education coursework. Similarly, teachers in child care and other community-based early childhood programs without a bachelor’s degree and licensure in early childhood education are required to take at least six college credits annually toward a degree and licensure in early childhood education. Assistant teachers in both public and non-public settings are expected to have an AA in early childhood education, but may be hired without an AA with an approved professional development plan and take at least six college credits annually toward the requirement. T.E.A.C.H. scholarships are available to assist PreK personnel to meet these requirements.

    New Mexico has worked diligently for the past twenty years to establish a robust system of professional preparation with a fully articulated universal course of study leading to multiple levels of licensure and certification. Although this professional preparation system is in place and public funds are used to support individuals pursuing early childhood degrees, Head Start and other early childhood programs struggle to keep qualified individuals. Most leave the state and/or leave community programs to work for higher paying opportunities.

    Regardless of having the infrastructure to prepare qualified early childhood teachers, the need for qualified teachers far exceeds the current capacity of the state.

    • The statute does not require a bachelor’s degree in early childhood education for lead teachers. We urge that states have flexibility in determining teacher qualifications. A requirement for all preschool programs regardless of setting to have teachers with a BA in the classroom will mean that many child care and other community-based providers will not qualify to operate a preschool program. This would have a devastating impact on child care programs in New Mexico. As four year olds shift to public school settings, our estimates are that child care center net revenues would be reduced by 60 percent. In order to restore lost revenue, centers would have to significantly increase rates for infants and toddlers by about 20 percent, making the cost unaffordable for most families. Centers would be forced to close.

    • Funding should be available to address both professional development and teacher salaries. One of our biggest problems with promoting greater education paths for our preschool teachers in community-based programs is the much higher pay in Head Start and in public schools. If we are to attract and retain quality teachers for preschool in child care settings, we need to assist them to meet teacher qualifications and then pay them a salary comparable to the other programs.

    We propose that the final criteria for preschool expansion grants allow for flexibility in the time period for attaining higher education credentials. Consistent with New Mexico’s current prek teacher requirements, teachers in child care and other community-based early childhood programs without a bachelor’s degree and licensure in early childhood education should be required to enroll in at least six college credits annually toward a degree and licensure in early childhood education. The difference is that they should be on a path toward a BA but not have to have a BA at the outset, which would be a significant challenge to meeting the current grant requirements as proposed. We understand the goal for high quality programs, however, capacity does not happen overnight. Flexibility on the teacher requirements would enable states to meet the goal over time.

    2) Evidence-based Curricula: Under the definition of “high Quality Preschool Programs”, the Executive Summary calls for “developmentally appropriate, evidence-based curricula…”. For the past ten years, New Mexico has invested heavily in the establishment of an authentic observation documentation curriculum planning process based on the New Mexico Early Learning Guidelines: Birth through Kindergarten. This is the foundation of the successful NM PreK Program and is being replicated as the foundation of the new third-generation tiered quality rating system across all early learning systems including home visiting and early intervention. This effort is being funded with Race to the Top/Early Learning Challenge funds. Although it is not yet a valid and reliable assessment process or an evidence-based curriculum, we are working with Child Trends to accomplish this. There should be flexibility for states with regard to curriculum and assessment with benchmarks to be met rather than a strict interpretation requiring an evidence-based model. New Mexico is firmly committed to a research-based, standards-based system of early learning.

    However, such a system is a work in progress, and is a commitment the state has made to “standards” vs. “standardization”. This approach does work. Benchmarks should be related to social, emotional, physical, and cognitive development, however, states should be granted the flexibility to align with their existing/proven early learning standards.

    In summary,
    1) States need flexibility for teacher qualifications in child care and community-based settings, especially given current state capacity and state current requirements.
    2) States need flexibility with regard to evidence-based curricula.
    Thank you for the opportunity to provide comments.

    Dan Haggard,
    Deputy Director for Program, Early Childhood Services Division
    Children, Youth and Families Department

  11. 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

  12. First 5 California (F5CA) appreciates the opportunity to comment on the Preschool Expansion Grants Executive Summary.

    Align with existing quality improvement efforts:

    F5CA supports the existing language in the summary that allows high-quality preschool to be provided through the state’s existing mixed-delivery early learning system. In addition we feel it is important to account for states that already have set benchmarks through Tiered Quality Rating and Improvement Systems (TQRIS) or other means, and that are seeing improved outcomes based on a continuum of high-quality standards. The draft definition of high-quality preschool with prescribed levels of teacher education, ratio/group size, and a full-day requirement contradicts the continuum of quality reflected in states’ existing standards and efforts to improve the quality of early learning programs. States’ ability to maximize resources and leverage current efforts depends on the alignment of new funding opportunities with existing efforts. The definition of high-quality preschool needs to allow for flexibility to ensure alignment with the significant investment of Race to the Top-Early Learning Challenge (RTT-ELC) at state and local levels.

    Teacher education requirement (Definition of High-Quality Preschool Program, pages 23-24):

    While the research is mixed on whether a Bachelor of Arts or higher degree results in improved student outcomes, F5CA sees the benefit for professionalizing the field of early learning and increasing alignment of teacher requirements with the K-12 education system. To ensure improved child outcomes with a preschool investment, F5CA recommends the requirement for higher staff qualifications include special coursework in child development, practicum experience, and an emphasis on early educator effectiveness. Research strongly suggests the quality of the teacher-child interactions impacts improved child outcomes.

    Full-day program (Definition of High-Quality Preschool Program, pages 23-24):

    In order to accommodate family need, it is critical states are able to maintain options for parents with the ability to operate part-time programs in addition to a full-day option. Preschool schedules in California, part-day or full-day, are determined at the local level based on family need. Many preschools are not full-day.

    Low staff-child ratios and small class sizes (Definition of High-Quality Preschool Program, pages 23-24):

    F5CA supports the proposed requirement for sites to maintain low staff-child ratios and small class sizes. Ratios and class sizes should be determined by each state in order to best meet local needs and capacity. For example, alternatives such as a ratio of 1:8 with a maximum group size of 24 would allow state and program flexibility while still providing increased opportunity for high-quality teacher-child interactions.

    Instructional staff salaries comparable to K-12 teaching staff (Definition of High-Quality Preschool Program, pages 23-24):

    F5CA believes if the degrees are comparable then employee salaries and benefits also should be aligned. Class sizes, child-to-staff ratios, and length of the school day and year also must be considered in salary comparisons between preschool programs and K-12 education. However, the cost associated with this augmentation would be prohibitive for the State now and in the future, despite the infusion of funds proposed within the federal Preschool Development Grants.

  13. 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.

  14. Speaking on the behalf of the children of the U.S. Virgin Islands and the outlying areas, I am truly disappointed that the U.S. territories have been excluded from this initiative. We all know the benefits of high-quality early learning and development programs for young children. As such, I too urge the Departments of Education and Health and Human Services to reconsider our eligibility.

  15. 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.

  16. On behalf of the State of Illinois, we express our appreciation for the opportunity to comment on the Executive Summary for the Preschool Expansion Grants. These grants represent a tremendous step forward in federal support for high quality preschool, and we believe the plan presented is well-conceived and has a high likelihood of supporting significant progress in developing effective state preschool programs nationwide.

    We would like to share our thoughts and concerns about a few of the proposed elements of the grant criteria.

    Competitive Preference Priority 4 (Matching Funds): We encourage the Departments to provide substantial guidance regarding how applicants will be expected to demonstrate the matching funds, and how successful grantees will be held accountable for fulfilling their promised match. We expect that in-kind resources, such as facilities and administrative costs, that are contributed by districts and Early Learning Providers will be counted in the match. In addition, we request that state and local capital funding for early learning facilities that will be used by partner LEAs/Early Learning Providers be an allowable component of the match.

    Competitive Preference Priority 5 (Continuum of Early Learning): We support this competitive preference priority and encourage substantial weighting of this priority.

    Section A: We encourage the Departments to allow greater flexibility to states in determining the percentage of the funds that will be subgranted to local communities, as in some cases the resources needed by local communities to implement high quality programs (e.g., curriculum resources, professional development, assessment resources) might be provided most efficiently through a state-level contract rather than a set of smaller, local contracts. Most importantly, we urge the Departments to not require 90% to go to local communities in the first year of the grant, as it will be exceptionally difficult for states to implement this requirement effectively. From the timelines that have been shared, it looks like the grant is contemplated to be aligned with the calendar year; if so, it would be very difficult for local communities to expend the full amount of their first year grant in a timely manner if they were to begin serving children in August/September. Delaying this requirement to the second year of the grant appears to make much more sense.

    Section B: We encourage the Departments to make clear that the amount of resources that states have invested in state-funded preschool programs serving three-year-old children will be considered in the criterion about the state’s financial investment. We also encourage including the amount of resources states have invested in high quality home visiting and Early-Head-Start-like programs for children ages birth to three.

    Section D (Collaborating with Subgrantees): In order to accomplish the intent of Section D, #2, we recommend that the Departments explicitly allow the use of these federal funds to raise quality (e.g., by paying a salary differential to allow the hiring of certified teacher at district salary levels, providing curriculum materials, or providing staff training) in a mixed income program, without requiring cost allocation of these expenses to reflect Eligible vs non-eligible participating children. This approach would be consistent with the guidance for the new Early Head Start-Child Care Partnerships. You may consider targeting this policy to programs that are full-workday, full-year programs that serve at least 50% Eligible children.

    We look forward to the release of the final invitation for applications, and appreciate your consideration of our comments.

    –Theresa A. Hawley, PhD
    Executive Director, Illinois Governor’s Office of Early Childhood Development

  17. 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

  18. 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.

  19. Voices for Virginia’s Children is an independent, statewide child advocacy organization. Voices seeks to improve public policies that improve the well-being of Virginia’s children, especially the most vulnerable children. Our comments are focused on Virginia’s position as a potential grantee, a state that would be eligible for an Expansion grant but does not currently receive an Early Learning Challenge grant.

    We are very grateful that this Expansion Grant would enable more of Virginia’s youngest children to benefit from high quality early childhood education. We are glad to see this competition focused on mixed delivery programs implementing high quality standards and targeting an at-risk population.

    With an existing state preschool program, Virginia shares many of the challenges faced by other states hoping to scale up our existing program, such as limited funding at the state and local level and the infrastructure to maintain a growing and evolving early learning system. Given those challenges we see this opportunity as a way to strengthen our existing early learning system as well as provide the initial boost of funds to expand access. As a state that does not participate in the RTT- Early Learning Challenge we would like to see a larger set-aside of funding be made available for system level improvements (such as strengthening our early childhood workforce, building on our quality improvement initiatives and strengthening our data and accountability systems). We encourage you to consider a larger infrastructure set-aside especially for the non-Early Learning Challenge states in the range of 25-30% of total funding.

    Additionally, our belief is that the entire state of Virginia could benefit from increased access and system level improvements rather than targeted communities alone. We hope that the Department and Reviewers will take into consideration that the criteria for two or more communities could also apply to a statewide approach. Our expectation is that this opportunity could have significant policy implications for our current preschool programs. When determining how Virginia can implement this expansion opportunity, policy implications for the entire state should be considered rather than approaches that work best in specific communities.

    Thank you for this opportunity to provide comments before the grant criteria are finalized.
    -Emily Griffey
    Sr. Policy Analyst, Early Care and Education
    Voices for Virginia’s Children

  20. Los Angeles Universal Preschool (LAUP) appreciates the opportunity to provide feedback regarding the Expansion Grants Executive Summary and has included questions and comments below.

    1. If a state receives an expansion grant, must it use 90% of its funding to maintain current preschool spaces and/or increase preschool spaces? (p.11)

    2. We understand that a grant recipient must spend 10% of its funding on program infrastructure and quality improvements. Could part of this 10% be used for quality coaching (for early education professionals) and other efforts to build and enhance the early education workforce? (p.11)

    3. We recommend that non-profit organizations be included in the definition of “early learning providers” so that these entities may subcontract with lead agencies in order to improve access to and quality of state early education systems. (p.22)

    4. Some families do not need or want full-day preschool, and many providers lack the resources to offer a full-day program. Consequently, we recommend that the expansion grant application be amended to say that while states must provide families with part-day preschool and wraparound services (which include developmentally appropriate activities), it is not a requirement for all high-quality preschool providers to offer full-day preschool. (p.23)

    5. Many preschool teachers have years of experience in the classroom but have not earned bachelor’s degrees. Consequently, we recommend that high-quality preschool providers still be funded if all of their teachers do not have bachelor’s degrees, as long as there are pathways and incentives in place for the degrees to be obtained. (p.23)

    6. In many states, preschool instructional staff salaries are not comparable to the salaries of kindergarten through twelfth grade staff. It will be very difficult for sweeping salary changes to be made by the grant application deadline. (p.23)

    7. We recommend that a state’s application be looked upon more favorably if the preschool providers the state hopes to fund (with Preschool Development Grant dollars) have class sizes that are less than 20 and staff-child ratios that are smaller than 1:10. (p.23)

    8. Some states do not have longitudinal data systems that link early childhood data with the state’s K-12 data system. Developing such systems demands substantial time and resources and it is doubtful that the systems will be created in a few short months. We recommend that the time frame for developing a longitudinal data system be expanded, and that the U.S. Department of Education direct states to examples of data systems that can be emulated. (p.19)

    9. We recommend that the U.S. Department of Education provide guidance regarding how a lead agency can “monitor” (p.16) and “hold each of its Subgrantees accountable for fully adhering to all program quality components that are part of the definition of a High-Quality Preschool Program.” (p.8) We want to note that the QRIS model can be used as an assessment tool for some of the elements listed under the Department’s definition of “high-quality preschool program.” (p.23)

  21. I could not agree more with this statement from the American Association of Christian Schools:

    “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.”

    Thank you for your consideration!

  22. Easter Seals Comments to US Departments of Education and Health and Human Services
    regarding the Preschool Expansion 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- Increase Access to High-Quality Preschool Programs in High Need Communities: 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 5: 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. In addition, Easter Seals concurs with the requirement that grantees ensure that approximately 5 percent of enrolled children between the ages of 3 and 5 are children with disabilities who are eligible and receive services under section 619 of IDEA. Research from the Maternal and Child Health Bureau indicates that more than as many as 20 percent of all preschoolers will have a developmental delay or other special need. Thus, the 5 percent bar should be a floor and not a ceiling.

    Definitions: 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.
    Definitions: Early learning Intermediary Organization: Easter Seals and its national affiliate network should be listed among these entities. Easter Seals has lead the field in the delivery of inclusive child care serving children with and without disabilities in full day, full year care.
    Definitions: High-Quality Preschool Program: Easter Seals concurs that the full inclusion of students with disabilities is an essential element to determine the quality of a preschool program.
    Thank you for considering our views.

    Katy Beh Neas
    Senior Vice President, Government Relations
    Easter Seals
    1425 K Street NW, Suite 200
    Washington, DC 20005

  23. 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.

  24. I am saddened and horrified to learn that grants are not currently available for US Territories. Having consulted for the Community Foundation of the Virgin Islands, volunteered and donated towards the US Virgin Island’s efforts to promote Early Childhood Education it is perplexing to me that a country so large and wealthy should turn its back on its own citizens – especially those in most in need. Given the purpose of the grant to impact children in “High- Need Communities” I respectfully ask the Department of Education to explain how they came to exclude the US Territories? Furthermore, given that the need is great, but the scale small, cannot the DoE carve out funding for Territories before their children fall further behind?

  25. I am concerned that the outlying territories, particularly the United States Virgin Islands, are being excluded from this grant application. Please include the territories as all American families, regardless of where they live, should have access to preschool opportunities.

  26. I am very disappointed the the Virgin islands and other smaller territories are not included in this initiative. There is often talk about “all children” – yet our children are part of “all children” – they are citizens of the United States. We too have a “tremendous unmet need for high-quality early learning programs.” Additionally, this initiative is intended to enable states and territories to become better prepared to participate in the new Preschool for All funding stream that is on the horizon. By not allowing the territories to participate in this program, we will be put at a disadvantage when it comes to participating in the next initiative. I urge the Departments of Education and Health and Human Services to reconsider our eligibility – and, if that is not possible, to identify other funding streams or discretionary funds that would enable the territories to provide for high quality early learning and development programs for our children.

  27. Good Day,
    I am shocked and amazed that this grant program would be denied to the US Virgin Islands. Surely if the program is needed in Puerto Rico it is equally needed in the other territories as well. As an early childhood educator for many years I know first hand the value of early intervention. I now work at a university in the Virgin Islands where we see the outcome of both excellent pre-school preparation and the dearth of pre-school education in our incoming students. Please right the wrong of denying this vital program to the US Virgin Islands. It is critical for our young students to have the support of early intervention with excellent pre-school programs. Thanks for your time and consideration.

  28. Pennsylvania Partnerships for Children (PPC) is a statewide, independent, non-partisan and non-profit child advocacy organization committed to improving the education, health and well-being of children in Pennsylvania. We appreciated the previous opportunity to provide comments on the new competition to build, develop and expand high-quality pre-k programs and again value the chance to provide our point of view on the revised draft of the competition requirements. We are providing comments on the expansion grant executive summary, as Pennsylvania is eligible to apply for this grant category.

    As PPC mentioned previously, Pennsylvania’s pre-k programs are operated by a mixed delivery system of school districts, high-quality child care programs, Head Start programs and licensed private nursery schools. Therefore, we strongly support the language in the draft which would allow the mixed delivery system to remain intact through a sub-granting process and appreciate its inclusion.

    Likewise, we strongly support the continued focus on important components of a high-quality pre-k program, including teachers with bachelor’s degrees, small class sizes and tight teacher/student ratios, a developmentally-appropriate curriculum linked to early learning standards and comprehensive services for children. These components are critical to ensure eligible children are participating in programs which will prepare them for school success and that we are using government funds on research-based criteria. While Pennsylvania’s programs meet the vast majority of the standards, there are some areas in which the commonwealth falls short. For instance, Pennsylvania’s Pre-K Counts program does not require health or developmental screenings, nutritious meals or staff salaries comparable to K-12 staff. We certainly have room to improve and could use the expansion sites to model an even higher-quality program and use the 10 percent set aside for these quality improvements. PPC also appreciates the focus on children under 200 percent of poverty and living in high-need communities.

    Our previous comments noted concern regarding two potential obstacles to states being willing to apply/accept this funding. The first was that this is a one-time funding stream. While the draft requirements note states may develop proposals for a four-year timeframe, continuation funds will be provided in years two-four based on the availability of dollars. We believe governors will be concerned about expanding pre-k opportunities for children if they are unable to sustain enrollment numbers at the same level into future years. In addition, this competition, as well as the president’s initial early learning proposal and the Strong Start for America’s Children legislation, requires a state match to receive federal pre-k funds. PPC believes requiring a match for this new pre-k funding stream could cause some states not to apply. However, PPC appreciates the current draft includes the match as a competitive priority, with points applied on a sliding scale, and allows new state funds allocated in the 2014 to count towards the match. This approach should be encouraging to Pennsylvanians as the requirements state Pennsylvania’s maximum award could be $20 million and the governor’s proposal for our state fiscal 2014-15 budget includes a $10 million increase in high-quality pre-k funding. At least for this year, the match language is reasonable and appears to be less of an obstacle to applying for the funds.

    Thank you again for the opportunity to comment.

  29. Citizens’ Committee for Children of New York (CCC) is grateful for the opportunity to submit comments on the Preschool Development Grant program of the U.S. Department of Education and the U.S. Department of Health and Human Services. CCC is a multi-issue, independent child advocacy organization dedicated to ensuring that every New York child is healthy, housed, educated, and safe. Because New York has already invested significant state and local funds into preschool, our comments focus on the Expansion Grants portion of the program.

    CCC appreciates the recognition of the critical importance of a strong system of services for children ages birth to eight. In that spirit, we suggest that the definition of “eligible children” be changed to allow states and localities the flexibility to serve three-year-olds with these funds if a state or local program achieves universality (likely 75%) in serving four-year-olds. New York City is launching a new full-day pre-kindergarten program in September 2014, with the goal of serving all four-year-olds in the city. New York State is also expanding its program. We would welcome the opportunity to serve three-year-olds in high-needs communities in preschool programs with federal funding once all four-year-olds are served, as part of a strong early childhood services continuum.

    CCC is also very supportive of the Administration’s efforts to help states expand quality preschool. We especially appreciate the expansion grant’s focus on increasing capacity in high-needs districts, as well as the requirement for states to use a percentage of grant funds to ensure program quality. Of particular importance to program quality is ensuring that the early education workforce is well-trained and well-compensated. We urge you to ensure that programs funded with these grants adequately compensate their staff, and that they do so in a manner that does not incentivize the teaching of four-year-olds over of children ages 0-3.

    Moira Flavin
    Policy Associate, Early Childhood Education, Education and Youth Services
    Citizens’ Committee for Children of New York, Inc.
    cccnewyork.org

  30. 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 Expansion 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.

  31. Expansion of preschool initiatives that will benefit American Indian tribes and communities and/or operate on tribal lands need to consider the critical concerns for Native language maintenance and in some cases language regeneration. The challenge of maintaining and generating younger speakers from these language communities is increasingly viewed as a vital aspect of early childhood education in many tribes. Definitions of eligibility, programmatic requirements, and selection criteria, etc.. must therefore be carefully weighed and if necessary, aligned to meet the intent of the Native American Languages Act passed by Congress which fully supports the development and preservation of America’s Indigenous languages.

  32. are private nonprofit agencies allowed to apply for any of these grants?

  33. My name is Monica Ochoa, I’m really interesting in apply for this grant, is neccesary fora coaching.

  34. I support initiatives to build, develop, and expand high quality PRESCHOOL FOR ALL. The nation needs to look no further than The Los Angeles Universal Preschool (LAUP) model. It is already inclusive of all the issues and requirements outlined in both the Preschool Development and the Preschool Expansion Grants and Executive Summaries. It has been tested and the results exceeded our expectations. Our children are thriving under its jurisdiction and leadership.

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