Public Comment Sought for New Competition to Build, Develop and Expand High-Quality Preschool Programs

Posted February 26, 2014

Public Comment Section for the New Competition to Build, Develop and Expand High-Quality Preschool Programs Now Closed

Thank you to everyone who has submitted opinions, ideas, suggestions, and comments on this dedicated Web site pertaining to the new competition to build, develop and expand high-quality preschool programs.

We are no longer accepting input on our Web site for this blog post. We will be providing additional opportunities for public input in the near future.

Please subscribe to our list serv at www.ed.gov/early-learning for updates.

Thank you.

 

The FY14 Consolidated Appropriations Act, 2014 (Public Law 113-76) makes important education investments, including $250 million in new Race to the Top to States grants for improving early childhood care and education.

On February 4, 2014, U.S. Secretary of Education Arne Duncan announced on a call (Read the transcript, or listen to the call Audio icon) with U.S. Secretary of Health and Human Services Kathleen Sebelius that the Administration plans to use the $250 million for a major new competition to build, develop and expand high-quality preschool programs, working with local communities and with states across the country, including the District of Columbia and Puerto Rico.

Note that this new Race to the Top competition is distinct from the Race to the Top – Early Learning Challenge (RTT-ELC), an initiative that currently supports 20 states as they design and implement an integrated systems of high-quality early learning programs and services to increase the number and percentage of children from low-income families that enter kindergarten ready for success, from birth through age five.  This year’s Race to the Top funding will support President Obama’s call to provide high-quality preschool for all 4-year-olds from low- and moderate-income families through a new competition to expand and enhance preschool programs across States and communities.

Specific competition requirements, priorities, and selection criteria will be developed consistent with the language in the FY 2014 Consolidated Appropriations Act, 2014 (Public Law 113-76):

“Provided, That $250,000,000 shall be available through December 31, 2014 for awards to States, in accordance with the applicable requirements of section 14006 of division A of Public Law 111–5, as amended:

Provided further, That the Secretary, jointly with the Secretary of HHS, shall use all funds made available under the immediately preceding proviso to make competitive awards in accordance with such section 14006 to States for improving early childhood care and education, except that, notwithstanding sections 14006(a) and 14005(d)(6) of such division, such awards may be limited to activities that build the capacity within the State to develop, enhance, or expand high-quality preschool programs, including comprehensive services and family engagement, for preschool-aged children from families at or below 200 percent of the Federal poverty line:

Provided further, That each State may subgrant a portion of such grant funds to local educational agencies and other early learning providers (including but not limited to Head Start programs and licensed child care providers), or consortia thereof, for the implementation of high-quality preschool programs for children from families at or below 200 percent of the Federal poverty line:

Provided further, That subgrantees that are local educational agencies shall form strong partnerships with early learning providers and that subgrantees that are early learning providers shall form strong partnerships with local educational agencies, in order to carry out the requirements of the subgrant:

Provided further, That, notwithstanding the second proviso, up to 3 percent of such funds for improving early childhood care and education shall be available for technical assistance, evaluation, and other national activities related to such grants:

Provided further, That not later than 30 days prior to the announcement of a competition under such section 14006 pursuant to the requirements of this Act, the Secretary shall submit a report outlining the proposed competition and priorities to the Committees on Appropriations of the House of Representatives and the Senate:

Provided further, That the Secretary shall administer State grants for improving early childhood care and education under such section jointly with the Secretary of HHS on such terms as such Secretaries set forth in an interagency agreement:”

The FY14 Appropriations Report states:

“The bill includes $250,000,000 for Race to the Top, which shall be available for obligation through December 31, 2014. Funds may be used for competitive awards to States to develop, enhance, or expand high-quality preschool programs and early childhood education programs for children from low- and moderate-income families, including children with disabilities.

If awards are made to States to build capacity related to high-quality preschool programs, the Secretary of Education shall award two types of grants to States, one to low-capacity States with small or no State-funded preschool programs and another to high-capacity States that have a larger State-funded preschool program.

Additionally, new bill language specifies that high-quality preschool programs should include comprehensive services and family engagement. As such, it is expected that funds will be used to help programs meet and sustain nationally recognized standards in those areas. Funds may also be used to help early childhood educators to attain higher credentials and degrees.

The bill does not provide authority for funding to be used for construction, renovation, modernization, or related activities. In addition, the bill permits States to determine the amount of funding distributed in subgrants to eligible entities for implementation of high-quality preschool programs from low- and moderate-income families.

A State receiving an award for this purpose shall ensure that any use of assessment conforms with the recommendations of the National Research Council’s reports on early childhood. The bill also requires that the Secretary submit a report outlining the proposed competition and priorities to the House and Senate Appropriations Committees.

It is expected that the Department will consult with the House and Senate Appropriations Committees, Committee on Education and Workforce, and the Committee on Health, Education, Labor, and Pensions (HELP), prior to the submission of the required report, including on the criteria to be used under a competition to define a high-quality preschool infrastructure and program. In addition, the Secretary shall continue to provide, on a timely and periodic basis, the findings from evaluations, including impact evaluations and interim progress evaluations, of activities conducted using any Race to the Top funds to the House and Senate Appropriations Committees.”

In addition, the FY14 Appropriations Report also provides that “Departments and agencies should be guided by the language and instructions set forth in Senate Report 113-71 accompanying the [Senate] bill, S. 1284, unless specifically addressed in this statement.”) The Senate Report 113-71 states:

“This program will award competitive grants to States to support their efforts to expand or create high-quality preschool systems for 4-year-olds from low- and moderate-income families, including children with disabilities. Preschool Development Grants will complement the administration’s Preschool for All proposal, which will provide matching mandatory funds to States for improving access to such high-quality preschool systems. The Department will award two types of grants, one to low-capacity States with small or no State-funded preschool programs and another to high-capacity States that have a larger State-funded preschool program. These grants will help States address fundamental needs including workforce development, quality improvement efforts, and the scale-up of proven preschool models. The bill allows States to subgrant funds to LEAs and to LEAs in partnership with other early learning providers. The Committee directs the Department to require any use of child assessments to conform to the recommendations and cautions of reports by the National Research Council on assessments of children.”

The two departments are very interested in your input. We encourage all interested parties to submit opinions, ideas, suggestions and comments pertaining to the new competition below.

This document will be posted for public input until 5:00 PM EDT on February 26, 2014, at which time the input section will be closed and we will begin considering comments received as we develop requirements, priorities, selection criteria, and definitions. Once the initial input from the field is collected and reviewed, we will draft an executive summary and post for comments that will, in turn, inform the final NIA.  In order to run a rigorous competition and obligate funds to grantees before December 31, 2014, ED plans to waive rulemaking on this new program, pursuant to its authority in the General Education Provisions Act.

This is a moderated site.

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

The fine print

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

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

Department of Education’s linking policy

Department of Education’s disclaimer of endorsement

479 Comments

  1. The government is trying to take away all our rights and is getting into areas they don’t belong. We know they want to try to control the minds of youth so they can push their socialist/communist agenda.
    Americans do NOT want or need the government to take control of preschools or other education. School policies should be on a state lever, not federal.
    Common core is a socialist agenda, that needs to be eliminated in all states.

  2. It’s interesting that all these letters of support are from groups which ultimately will receive funding in some way if more kids are shoehorned into what is obviously intended to become mandatory preschool.

    As the publisher of a national homeschooling magazine, Practical Homeschooling, we do NOT support states foolishly chasing after the lure of federal dollars, and thus giving the federal government even more control of their education programs.

    Though under the Constitution the federal government has no role in education, here the federal government is projecting its goals and standards via federal funding. In this case, federal funding “on the cheap,” as not all states will receive the money, even if they totally comply with the “vision” of 4-year-olds presented with developmentally inappropriate training.

    Kindergartners are already suffering stress, thanks to Common Core lessons produced by people who are not early childhood experts. Pushing increased academics into earlier ages is not the answer.

    We can clearly see the agenda here, of providing more consumers for well-connected corporations and molding children’s minds to what central planners desire. And the words “comprehensive services” should send a shiver up the spine of everyone who has ever dealt with a bureaucracy.

  3. You have no right to use our taxpayer money for a project such as this – bassinet through college education for all children required by the federal government. It is a parent’s right to decide when the child should start school and it should be the parent’s right to send their children to an elementary and high school that best reflects the values of the parent and the needs of their children. At the very most, only the states should have the control you are seeking for yourselves at the federal level to educate our American children.

  4. If the current Common Core “standards” (I use that term loosely) are so great why are Obama’s and Arne Duncan’s kids in private schools that do not use the Common Core? The Federal Government needs to keep out of our local schools and stop using our kids as experiments.

  5. Thank you for the opportunity to comment on the latest round of funding for Race to the Top Early Learning Challenge. We are requesting the Departments of Education and Health and Human Services to use these funds to fund additional states that submitted applications for the 3rd round of the Race to the Top Early Learning Challenge Grant competition.
    1.) Several non-winning states (e.g., Arizona, New York, Arkansas) received scores that were close to the scores of states that won Early Learning Challenge Grants. The states that came close but did not win a grant have proven that they have taken the steps needed to build a high-quality early childhood system of services and deserve the opportunity to implement their proposals.
    2.) States that received Early Learning Challenge Grant funding will be at a considerable advantage for the preschool development grants, because they have been able to develop the systems that will make high-quality preschool programming possible. This could result in a growing split between states that have been funded to build high-quality early childhood education systems and those that have not been funded.
    3.) There are significant costs associated with conducting another round of proposals for the both the federal government and the states that submit applications. The state teams that recently developed applications for the 3rd round of the Early Learning Challenge Grant spent several intense weeks working full time on the application. Many of these state teams were augmented by grant writers that were hired at a considerable expense to help develop competitive proposals. The federal government also incurs significant expense in administering a competition and since the last competition was held so recently it seems that this expense would be wasteful. The costs associated with a 4th round of grants would be better spent by directing the funding to states that scored just out of the running for a grant during the 3rd round.
    New York State’s latest proposal adheres to the new bill language which specifies that high-quality preschool programs should include comprehensive services and family engagement. Implementation of existing proposals such as ours would simply be a quicker and more cost effective way means to achieving the goals set forth by this administration. Thank you for your consideration and dedication to this issue.

    Sincerely,
    David Voegele
    Executive Director
    Early Care & Learning Council
    New York State

  6. I encourage an avenue of financial support to create affordable, quality childcare for working families. While the focus on very low income children is laudable, the next income level bracket constitutes the working backbone of our communities. This segment of the population rarely receives any assistance. If we can assist them in self-selecting approved, high quality education childcare, they will likely take the savings and put in back into the economy – new shoes, tires for the car, a home etc. Scholarship assistance (20-30% of cost) can improve education AND the economy. This, complimented by a tat deductible employer contribution can create a double benefit of employee retention. Thank you for your consideration.

  7. Dear Secretaries Duncan and Sebelius,

    Thank you very much for the opportunity to comment on such an important and exciting initiative. Based on our in-depth research and conversations with dozens of early childhood experts across the country on approaches for increasing kindergarten readiness, the need to improve quality—especially for a subset of high-risk populations—in pre-K settings is important theme that should be strongly considered in this competition. With this focus on quality improvement in mind, our recommendations include:

    (1) Prioritize state plans that propose spending at least 50% of funds on improving the quality of existing programs vs. building/expanding new programs. Only five states meet all ten of the National Institute for Early Education Research’s quality standards (which include, among other factors, teacher education and training requirements, class sizes, and state quality assessments). Research has shown that something is not better than nothing: only moderate to high-quality programs produce positive effects on children’s school readiness.

    (2) Focus on quality improvement approaches that are evidence-based, especially those that enhance teacher-child interactions. Research has shown that the high-quality structural features (e.g., highly qualified teachers (with BAs), learning goals tied to the K-12 system, class sizes of no more than 20 children, child/staff ratios of 10:1 or smaller, and full-day pre-K service) are necessary, but not sufficient to deliver kindergarten readiness. Additional “process” features that focus on the quality of the caregiver/child interaction are considered even more important: intentional learning opportunities and a research-based curriculum that engages children; a nurturing environment with room for individual attention; sufficient time spent on and intensity of interaction with children who are behind to make sure that they have time and space to catch up. QRIS systems that include Environmental Rating Scales such as CLASS and that subsequently fund quality improvement plans for pre-K classrooms to improve CLASS scores are a step towards integrating these process features. Instructional supports and coaching programs that rotate master teachers through under-performing classrooms have been successful in Connecticut, for example.

    (3) Help states build shared data and evaluation systems (integrated with QRIS) that track development of children from 0-5 and that link standards between pre-K and K-12. According to our analysis of the Early Childhood Longitudinal Survey, about one-third of children who were in pre-K at age 4 (~650K) are not on track to be kindergarten ready. States need assessment systems and kindergarten readiness measures to understand how quality improvements are improving outcomes for this population and to continuously improve based on this data. Maryland Model for School Readiness contributed to a 35% increase (from 51% to ~70%) in kindergarten readiness rates for children on free and reduced price meals. Increasing the number of states that include child assessment (with a focus on kindergarten readiness) as part of QRIS should be a goal of this process. Given that this effort is focused on low-income four year olds, it is important that states develop strategies for integrating/aligning Head Start evaluation and quality improvement efforts with QRIS so that all pre-K settings serving four year olds are working toward and measuring the same goal.

    (4) Help states incentivize meeting higher quality standards. Through QRIS, states are already creating tiered reimbursement structures and incentives for improving quality. Pennsylvania’s rating system (STARS) ensures that only sites with high quality ratings can compete to participate in the state’s pre-K program. The number of sites moving up the rating system is growing by 20 to 30 percentage points each year, and the percentage of children participating in high-quality early learning programs has doubled. In addition to financial incentives for pre-K programs, professional development incentives and other educational supports should be offered to teachers seeking to improve their capacity.

    (5) Encourage states to develop strategies for addressing sub-populations with unique needs. In addition to targeting low and moderate income 4 year olds, pre-K programs should consider evidence-based approaches for serving high-risk, low-income sub-groups in any given states. For example, while Hispanic children account for ~30% of children that are not expected to be ready for kindergarten, they are less likely to be enrolled in pre-K programs. Only 25% of Hispanic 3-year-olds attend pre-K, compared to 45% of non-Hispanic 3-year-olds. Targeted enrollment efforts and instructional methods to better serve this population may be necessary in some states. Pre-K programs in Red Bank (NJ) and Montgomery County (MD) achieved positive outcomes through bilingual classrooms, focused ESL instruction, and specialized progress tests. In addition, given that ~65% of low-income children are behind in either academic or behavioral domains, state plans to implement evidence-based curricula for both academic and SEL domains (e.g. Tools of the Mind, Incredible Years, Triple P, PATHS) are important.

    (6) Facilitate learning across states to disseminate best practices. States such as Maryland and Minnesota that have demonstrated improvements in kindergarten readiness can share experiences so that other states are not reinventing the wheel.

    (7) Consider sustainability planning—Given the temporary nature of this funding, prioritizing investments in one-time infrastructure or systems-building costs that can put states on a path to improved quality and that are otherwise difficult to fund may also be worth prioritizing.

    Best of luck in this process,
    Christina

  8. These comments are being submitted on behalf of the IDEA Infant & Toddler Coordinators Association (ITCA) to the Administration for the implementation of the $250 million in state grant funds appropriated under the FY14 Consolidated Appropriations Act, 2014 (Public Law 113-76) to improve early childhood care and education. 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 supports the implementation of these expanded funds for states as an important part of ensuring all young children and their families have access to quality early learning opportunities. ITCA asks the Administration to support and enhance state efforts toward inclusion of IDEA, Part C and Preschool Special Education in these efforts and notes the reference to children with disabilities in the Report language accompanying the funding allocation for this investment.

    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 early learning grants. This 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 recommendations:

    • ITCA strongly encourages 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 including 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.

    • By expanding new early education opportunities for children from birth to five, it is expected that the identification of infants, toddlers and preschoolers with disabilities will also increase. Additional resources for early intervention and preschool special education services are critical to ensure full participation of children with disabilities in these new opportunities. ITCA recommends a percentage of funding to support IDEA’s Part C and Section 619 Preschool Special Education be set-aside from the $250 million allocation to ensure that appropriate services and supports can be provided to achieve this purpose.

    • ITCA recommends that states include measurable targets toward fully including children with disabilities in the expanded learning opportunities in their applications plan. Public reporting of data demonstrating improved performance toward targets and annual determination of data-based decisions on strategies to increase full participation is critical to success.

    • ITCA recommends that language be included in the application package to ensure that IDEA Part C and Preschool Grant programs are fully integrated into grant activities throughout the funding;

    • ITCA recommends the application require a signed partnership Memorandum of Understanding (MOU) with state partners representing Part C and Section 619 Special Education. We recommend specific requirements for the MOU include how:
    o Each state partner will coordinate their state specific early learning efforts with other state partners to ensure maximization of all federal, state and local resources;
    o All state partners, including IDEA Part C and Section 619 Preschool Grant systems, will be included in the implementation of grant activities;
    o Grant resources, funds and activities will be directed to include all state partners, including Part C and Preschool 619;
    o All partners, including the Part C and 619, will be involved in grant leadership and decision-making; and
    o The project will evaluate and report to the federal office periodically on the implementation of all partnership efforts. This should include any changes that will ensure that grants implement partnership activities as planned and proposed in the application.

    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

  9. Dear Secretaries Duncan and Sebelius,

    Thank you very much for the opportunity to comment on such an important and exciting initiative. Based on our in-depth research and conversations with dozens of early childhood experts across the country on approaches for increasing kindergarten readiness, the need to improve quality—especially for a subset of high-risk populations—in pre-K settings is important theme that should be strongly considered in this competition. With this focus on quality improvement in mind, our recommendations include:
    (1) Prioritize state plans that propose spending at least 50% of funds on improving the quality of existing programs vs. building/expanding new programs. Only five states meet all ten of the National Institute for Early Education Research’s quality standards (which include, among other factors, teacher education and training requirements, class sizes, and state quality assessments). Research has shown that something is not better than nothing: only moderate to high-quality programs produce positive effects on children’s school readiness.

    (2) Focus on quality improvement approaches that are evidence-based, especially those that enhance teacher-child interactions. Research has shown that the high-quality structural features (e.g., highly qualified teachers (with BAs), learning goals tied to the K-12 system, class sizes of no more than 20 children, child/staff ratios of 10:1 or smaller, and full-day pre-K service) are necessary, but not sufficient to deliver kindergarten readiness. Additional “process” features that focus on the quality of the caregiver/child interaction are considered even more important: intentional learning opportunities and a research-based curriculum that engages children; a nurturing environment with room for individual attention; sufficient time spent on and intensity of interaction with children who are behind to make sure that they have time and space to catch up. QRIS systems that include Environmental Rating Scales such as CLASS and that subsequently fund quality improvement plans for pre-K classrooms to improve CLASS scores are a step towards integrating these process features. Instructional supports and coaching programs that rotate master teachers through under-performing classrooms have been successful in Connecticut, for example.

    (3) Help states build shared data and evaluation systems (integrated with QRIS) that track development of children from 0-5 and that link standards between pre-K and K-12. According to our analysis of the Early Childhood Longitudinal Survey, about one-third of children who were in pre-K at age 4 (~650K) are not on track to be kindergarten ready. States need assessment systems and kindergarten readiness measures to understand how quality improvements are improving outcomes for this population and to continuously improve based on this data. Maryland Model for School Readiness contributed to a 35% increase (from 51% to ~70%) in kindergarten readiness rates for children on free and reduced price meals. Increasing the number of states that include child assessment (with a focus on kindergarten readiness) as part of QRIS should be a goal of this process. Given that this effort is focused on low-income four year olds, it is important that states develop strategies for integrating/aligning Head Start evaluation and quality improvement efforts with QRIS so that all pre-K settings serving four year olds are working toward and measuring the same goal.

    (4) Help states incentivize meeting higher quality standards. Through QRIS, states are already creating tiered reimbursement structures and incentives for improving quality. Pennsylvania’s rating system (STARS) ensures that only sites with high quality ratings can compete to participate in the state’s pre-K program. The number of sites moving up the rating system is growing by 20 to 30 percentage points each year, and the percentage of children participating in high-quality early learning programs has doubled. In addition to financial incentives for pre-K programs, professional development incentives and other educational supports should be offered to teachers seeking to improve their capacity.

    (5) Encourage states to develop strategies for addressing sub-populations with unique needs. In addition to targeting low and moderate income 4 year olds, pre-K programs should consider evidence-based approaches for serving high-risk, low-income sub-groups in any given states. For example, while Hispanic children account for ~30% of children that are not expected to be ready for kindergarten, they are less likely to be enrolled in pre-K programs. Only 25% of Hispanic 3-year-olds attend pre-K, compared to 45% of non-Hispanic 3-year-olds. Targeted enrollment efforts and instructional methods to better serve this population may be necessary in some states. Pre-K programs in Red Bank (NJ) and Montgomery County (MD) achieved positive outcomes through bilingual classrooms, focused ESL instruction, and specialized progress tests. In addition, given that ~65% of low-income children are behind in either academic or behavioral domains, state plans to implement evidence-based curricula for both academic and SEL domains (e.g. Tools of the Mind, Incredible Years, Triple P, PATHS) are important.

    (6) Facilitate learning across states to disseminate best practices. States such as Maryland and Minnesota that have demonstrated improvements in kindergarten readiness can share experiences so that other states are not reinventing the wheel.

    (7) Consider sustainability planning—Given the temporary nature of this funding, prioritizing investments in one-time infrastructure or systems-building costs that can put states on a path to improved quality and that are otherwise difficult to fund may also be worth prioritizing.

    Best of luck in this process,
    Christina

  10. It is foolish to fund preschool in this environment. We have cut “encore” classes to the minimum to graduate in our school district and next year may cut Kindergarten…what is the point of government funded preschool/play?

  11. Dear Secretaries Duncan and Sebelius,

    Thank you very much for the opportunity to comment on such an important and exciting initiative. Through in-depth research and conversations with dozens of early childhood experts across the country on approaches for increasing kindergarten readiness, the need to improve quality—especially for a subset of high-risk populations—in pre-K settings is an important theme that should be strongly considered in this competition. With this focus on quality improvement in mind, our recommendations include:

    (1) Prioritize state plans that propose spending at least 50% of funds on improving the quality of existing programs vs. building/expanding new programs. Only five states meet all ten of the National Institute for Early Education Research’s quality standards (which include, among other factors, teacher education and training requirements, class sizes, and state quality assessments). Research has shown that something is not better than nothing: only moderate to high-quality programs produce positive effects on children’s school readiness.

    (2) Focus on quality improvement approaches that are evidence-based, especially those that enhance teacher-child interactions. Research has shown that the high-quality structural features (e.g. highly qualified teachers (with BAs), learning goals tied to the K-12 system, class sizes of no more than 20 children, child/staff ratios of 10:1 or smaller, and full-day pre-K service) are necessary, but not sufficient to deliver kindergarten readiness. Additional “process” features, which focus on the quality of the caregiver/child interaction are considered even more important: intentional learning opportunities and a research-based curriculum that engages children; a nurturing environment with room for individual attention; sufficient time and intensity to ensure that children who are behind have time and space to catch up. QRIS systems that include Environmental Rating Scales such as CLASS and that then fund quality improvement plans for pre-K classrooms to improve CLASS scores are a step towards integrating these process features. Instructional supports and coaching programs that rotate master teachers through under-performing classrooms have been successful in Connecticut, for example.

    (3) Help states build shared data and evaluation systems (integrated with QRIS) that track development of children from 0-5 and that link standards between pre-K and K-12. According to our analysis of the Early Childhood Longitudinal Survey, about one-third of children who were in pre-K at age 4 (~650K) are not on track to be kindergarten ready. States need assessment systems and kindergarten readiness measures to understand how quality improvements are improving outcomes for this population and to continuously improve based on this data. Increasing the number of states that include child assessment (with a focus on kindergarten readiness) as part of QRIS should be a goal of this process. Given that this effort is focused on low-income four year olds, it is important that states develop strategies for integrating/aligning Head Start evaluation and quality improvement efforts with QRIS so that all pre-K settings serving 4 year olds are working toward and measuring the same goal.

    (4) Help states incentivize meeting higher quality standards. Through QRIS, states are already creating tiered reimbursement structures and incentives for improving quality. Pennsylvania’s rating system (STARS) ensures that only sites with high quality ratings can compete to participate in the state’s pre-K program. The number of sites moving up the rating system is growing by 20 to 30 percentage points each year, and the percentage of children participating in high-quality early learning programs has doubled. In addition to financial incentives for pre-K programs, professional development incentives and other educational supports should be offered to teachers seeking to improve their capacity.

    (5) Encourage states to develop strategies for addressing sub-populations with unique needs. In addition to targeting low and moderate income 4 year olds, pre-K programs should consider evidence-based approaches for serving high-need sub-groups within the low-income population. For example, while Hispanic children account for ~30% of children that are not expected to be ready for kindergarten, they are less likely to be enrolled in pre-K programs. Only 25% of Hispanic 3-year-olds attend pre-K, compared to 45% of non-Hispanic 3-year-olds. Targeted enrollment efforts and instructional methods to better serve this population may be necessary in some states. Pre-K programs in Red Bank (NJ) and Montgomery County (MD) achieved positive outcomes through bilingual classrooms, focused ESL instruction, and specialized progress tests. In addition, given that ~65% of low-income children are behind in either academic or behavioral domains, state plans to implement evidence-based curricula for both academic and SEL domains (e.g. Tools of the Mind, Incredible Years, Triple P, PATHS) are important.

    (6) Facilitate learning across states to disseminate best-practices. States such as Maryland and Minnesota that have demonstrated improvements in kindergarten readiness can share experiences so that other states are not reinventing the wheel. Maryland’s Model for School Readiness contributed to a 35% increase (from 51% to ~70%) in kindergarten readiness rates for children on free and reduced price meals.

    (7) Consider sustainability planning—Given the temporary nature of this funding, prioritizing investments in one-time, infrastructure or systems-building costs that can put states on a path to improved quality and that are otherwise difficult to fund may also be worth prioritizing.

    Best of luck in this process,
    Christina

  12. Thank you for providing leadership and resources to get all children off to a strong start. I’m disappointed by the variety of negative comments here and hope that they do not dissuade from this initiative going full force. I see quality family education through home visiting and quality early education through a multi-sector delivery system (including faith-based early childhood programs) not as government involvement, but as family support and building strong future citizens. Thanks for allowing public comments on the next set of grant opportunities.

    I’m writing from a state that is an RTT-ELC round 1 recipient and want to emphasize the importance of federal grant competition insisting on and incentivizing multi-sector collaboration, and compliment the federal modeling of the DoE and HHS partnership on RTT-ELC. It has been transformative for some states to work more in this direction, leading to more creative ideas, better uses of resources, better public perception of government, and, most importantly, better access to quality programs for more at-risk kids.

    Here are three pieces that I see as opportunities for the federal leadership to build into these next grants that could have important local impact:
    1) Please consider more rigorous requirements or incentives for schools to partner with the child care providers (licensed and unlicensed) and head start/early head start in their local communities. There are some promising small initiatives like this but not enough, and not enough is known and communicated about impactful models. Especially for birth to three year olds, school-based programs are rarely the best setting for supporting parents and children. Additionally, schools have existing guaranteed revenue (though it may not be “enough”) and have ways to raise additional revenue that other sectors – most especially child care – do not have. Requiring school partnerships with child care and early head start/head start, evaluation of promising models or frameworks for making these connections, and communicating those models broadly could fill a very important gap in our local and regional implementation of mixed sector early education delivery.
    2) Please consider more targeted support for training new Americans to be quality early childhood providers, especially as family child care providers. We know that transforming parents’ lives is one of the best ways to support children’s development. We know that we don’t have enough cultural and linguistically diverse child care providers. We know that most parents prefer family child care to a center for birth to three year olds. Why not build up models that would be a “four-for.” These kinds of initiatives would 1) support the skills of the adults who are already caring for kids, but who have the most challenges ensuring their children are “ready for school”; 2) do this in a way that provides a clear pathway to those adults becoming small business owners by way of opening quality (part of a QRIS) family child care, supporting their own family economics; 3) which also increases the number of culturally and linguistically diverse providers allowing more members of culturally and linguistically diverse communities to be satisfied with child care, supporting more their ability to go to school or work; 4) which in turn increases the number of culturally and linguistically on track kids. Maybe another round of grants that are collaboration among DoE, HHS, and DoL?
    3) Please consider some requirement or incentive for private matching dollars.
    Early education would benefit from having more local, regional, and maybe even state specific pathways for individuals and institutions to contribute to the cause and/or to individual children’s participation. We would benefit from developing models that are akin to higher education where public AND private money is used, both on the demand side (to supplement tuition by grants, loans, and scholarships) AND on the supply side (for bricks and mortar and other operating costs) to ensure all kids have the chance to be ready for K. With the buzz about the importance of early childhood we have an opportunity to capture the enthusiasm of many individuals and institutions to contribute, but there is literally not a pathway to do that right now. For example, most of us give to our alma matter and corporations and wealthy individuals have buildings and programs named after them for their important contributions. Incentives for states or regions to build structures that would allow that to happen in early childhood are sorely needed.

  13. ZERO TO THREE appreciates the opportunity to comment. We have previously joined with other organizations to offer a set of principles to inform the design of the new preschool program. Here, we would like to highlight issues important to infants and toddlers who will ultimately be entering the prekindergarten system. We urge you to use this opportunity to help ensure they arrive on target developmentally.

    We want to reiterate that hese new preschool funds should augment the total investment in early childhood. States should not be allowed to scale back state or federal funding as a result of receiving these funds, and in particular, they should not undermine services for infants and toddlers.

    We recommend that the Departments require states to show that new preschool efforts will not result in a diminution of services or quality improvement efforts for infants and toddlers in the geographic areas served by expanded preschool services.

    Along with other organizations, we believe the Departments should encourage states to provide a trajectory of high quality programs for children from the prenatal period: We know that children begin learning at birth and that children have the best outcomes when they receive high-quality early learning for multiple years. States should use these funds to help build a pipeline of services for children from birth to kindergarten entry.

    Criteria that support this principle include:
    States should describe how they will align and coordinate preschool programs with services for infants and toddlers, including Early Head Start, CCDBG, and home visiting.
    States should describe how they will promote continuous access to high-quality programs from the prenatal period to age five (including home visiting and Early Head Start).

    In following these principles, we urge the Departments to allow states, especially those with stronger prekindergarten programs and research pointing to poor quality infant-toddler child care to propose using these funds to support the birth-to-five continuum.

    Finally, urge the Departments to require states to ensure that early intervention and preschool special education are viewed as integral parts of their early learning systems and allow states to spend some of these new preschool funds to enhance and expand the systems that provide these services and not simply allocate program slots for children with special needs.

    We note that one of the outcome measures often discussed for high quality prekindergarten programs is a reduction in the need for special education services. The developmental delays and disabilities that often result in the need for such services have their roots in the infant-toddler years. If identified and addressed at time, they are easier to ameliorate and therefore prevent or reduce the need for subsequent special education services. Yet, the early intervention system, funded in part through Part C of the Individuals with Disabilities Education Act, is stretched and cannot meet the needs of all children who could benefit from services. It is doubtful that waiting until children reach prekindergarten to identify and address special needs will have the desired impact.

  14. The Department of Education should have been abolished years ago. It has no constitutional standing. Dumbing down our already dumbed down schools is a dreadful idea. Is the Constitution even taught today? Grammar certainly isn’t.

  15. We appreciate the opportunity to provide comments regarding the United States Department of Education (USDOE) plan to use $250 million that was included in the FY14 Consolidated Appropriations Act for a major new competition to build, develop and expand high-quality preschool programs. We strongly believe that the $250 million should be used to fund additional states that submitted applications in the October 2013 Race to the Top Early Learning Challenge Grant Competition.

    Our Office is represented on New York State’s Early Childhood Advisory Council (ECAC) which is comprised of Governor-appointed representatives of state agencies, advocacy groups, foundations, higher education, unions and other key organizations concerned with the well-being of young children and their families. New York’s early childhood programs are operated by a diverse delivery system of school districts, high quality child care programs, Head Start programs and licensed private nursery schools. Therefore, we support the language in the Bill which allows diverse delivery systems to remain intact.

    However, the ECAC has raised concerns with the plan for USDOE to issue a new Race to the Top Competition designed to build, develop and expand high-quality, preschool programs, working with local communities and with states across the country. We support the ECAC’s position that the USDOE and the Department of Health and Human Services use the $250 million to fund additional states that submitted applications in the October 2013 Race to the Top Early Learning Challenge Grant Competition. We believe the New York proposal was highly competitive and, if funded, it would help ensure that children across the State acquire the foundational knowledge and skills to be ready for Kindergarten and necessary for success in elementary school, as well as keep them on track to graduate from high school ready for college and careers. By using the 2013 Request For Proposals, we also believe that significant costs associated with conducting another round of proposals and a high number of staff hours would be saved at both the state and federal levels.

    New York State has demonstrated its commitment and capacity to build and develop high-quality preschool programs. As such, New York State stands ready and welcomes the opportunity to implement its plan articulated within the Race to the Top Early Learning Challenge Grant application submitted in 2013 to support the continued work of building, developing and expanding the state’s high-quality preschool programs, in collaboration with local communities and other partners across the State and country.

  16. The states should fund their own schools. Get the government out of the school system.That is what is wrong with the country,now. Their standards are not what the standards of the people have and were taught. We, an older generation, are better educated,overall, than todays children. They can’t even make change. Computers don’t create brains and education.They can learn that later in school. Reading,writing,arithmatic is more important.

  17. My children do NOT belong to the government. God gave them to our family and it is the parents responsibility to educate them and raise them to the best of their ability. The government is responsible, directly and indirectly, for the current dismal state of the family in this country. They seek to further this downward spiral and claim the children as state’s property.

  18. From what I have seen already with preschools funded by the federal government, is discriminatory and useless. I agree low income children should be given a chance but what about the struggling middle class or the children with disabilities. I do not like what the federal government is trying to do to our children and I am almost certain that if states take this money it will be just as bad if not worse than the last RTT monies which are already ruining our kids, teachers and families. The federal government needs to stay out of the education system and stop bribing their way into domination!

  19. The Chicago-based Latino Policy Forum works on closing the achievement gap for Latinos by focusing policy and advocacy efforts to increase access and equity to early care and education resources and services for children from birth to third grade in Illinois.

    Recent state population growth (one quarter of children under age 5 are Latino, U.S. Census 2010 decennial) and increased levels of child poverty (nearly one third of Latino children under age 5 live in poverty, 2013 Illinois Kids Count Report) call attention to the demand and opportunity for early care and education with respect to Latino children. However, these statistics are exacerbated by the lack of preschool enrollment by Latinos—only one in three eligible children are enrolled in preschool programs in Illinois (New Journalism on Latino Children, 2010). The federal investment in expanding and enhancing preschool programs will bolster the supply of available resources to help alleviate the growing demand.

    The Latino Policy Forum is pleased with the federal investment in preschool expansion, yet there are several recommendations we are advancing based on the state’s history with its own Preschool for All program and feedback from our Early Childhood Education Acuerdo members who are local providers and stakeholders serving the Latino community.

    Priority to Low-Income Populations: States should prioritize services to low income and hard to reach populations. Each state should be required to complete an analysis to determine the number of children without access to early childhood education by race/ethnicity, language, poverty status and geographic location and invest in bilingual programs in proportion to the diversity of their populations.

    Support Mixed Delivery Systems: States should provide direct funding to community based organizations (CBOs) and other early childhood education providers that meet high quality standards and provide services to low-income communities. Funding levels for CBOs must be sufficient to cover the full cost of care including, but not limited to:
    • Wages and benefits comparable to those paid to teachers by school districts
    • Part day, school day and long day schedules to meet the needs of all families
    • Provisions for continuum of services from birth to age five
    • Comprehensive family services, ESL and adult education, citizenship preparation
    • Transportation for hard to reach populations in both rural and urban settings

    Parental/family Leadership Development: Ensure and build meaningful partnerships between providers and families as a basic expectation as a measure of high quality, not the exception. Parents and families should be woven throughout the fabric and leadership of the program.

    Linguistic and Cultural Competence: Curriculum, instruction, and family services should be performed by biliterate and/or bicultural teachers, therapists, home visitors and counselors who understand the nuances of the community they serve and build upon cultural assets and linguistic strengths.

    High Staff Qualifications: State should provide adequate resources (i.e. incentives, tuition reimbursements and paid release time) and a reasonable timeline for teachers, including those whose primary language is not English, to pursue BA degrees in early childhood education or a closely related field. The existing workforce should have access to ongoing professional development, including training on cultural and linguistic competence, parent engagement, and state early learning guidelines and standards.

    Support for Higher Education Institutions: States should have access to resources to build the capacity of higher education institutions to respond to state specific needs in creating a highly qualified, linguistically, and culturally competent workforce.

    Assessments: States should develop multiple assessments that are appropriate for young dual language learners to guide instruction. Assessment results should be used for professional development and program improvement exclusively.
    Overall, the timing of this federal investment could not be better considering the budget woes our state faces. As a result, much of our progress could be undermined by budget cuts; however we perceive the federal investment as buoying our current and future investments.

  20. The National Center for Montessori in the Public Sector (NCMPS) shares a vision with many of the previous posters of high quality, fully implemented Montessori education as a viable and accessible means of early childhood education for all children.

    Research has shown that the high standards of Montessori education produce exceptional outcomes for children and families. Yet, the core elements of authentic Montessori—mixed age groupings, extended periods of uninterrupted work, specially trained teachers and entrance by age 3—often run counter to established preschool practices.

    Here we outline what we see as key policy issues in facilitating Montessori’s reach to publicly funded programs. Some of these would be helpful to any strong program; others are specifically targeted for Montessori classrooms.

    We ask that the following considerations be taken into account in order to not only include but encourage Montessori as the country moves forward with this most important work:

    • An uninterrupted early childhood continuum – Support integration of 0-3 and PreK/K programs so that families, caregivers and schools can benefit from consistency in relationships and approach. Whether these programs are run out of one government department or through a partnership, we urge that communication, processes and regulations across the age spans be seamless. Currently, public Montessori programs in most locations struggle to implement a full 3 – 6 year old program because funding, regulations and oversight departments are different for the younger and older of this age group. Any steps taken to smooth this gap would support and encourage the development of full continuum child and family-centered programs.

    • Braided funding streams—Take steps 1) to allow for a mix of private and public dollars and 2) to ease the burden of institutions dealing with multiple departments and funding streams. To achieve financially viable, socioeconomically integrated programs, we ask that regulations allow programs to draw on a mix of means-based tuition and public dollars. In this way, programs will be able to integrate rather than segregate students across socioeconomic lines, a practice that benefits all students and takes full advantage of Montessori’s appeal and effectiveness across varied demographics. Supporting braided funding streams also includes facilitating any given program’s access to public funding that spans across what are now imposed breaks between programs run out of the DOE and out of HHS.

    • Mixed-age classrooms—Assure that no regulations preclude mixed-age groupings and that all regulations are flexible enough to allow for, if not encourage, mixed-age groupings across the early childhood/K continuum. These regulations might include areas such as teacher certification, student:teacher ratio, classroom size and instructional program.

    • Teacher qualifications—Recognize accredited Montessori teacher training for 3 – 6 year olds as meeting most, if not all, the requirements for professionals working with this age group. Montessori teacher training is a rigorous program blending child development, classroom practice and Montessori theory. MACTE accredited Montessori training programs are already recognized by the DOE, and this recognition should be extended to preschool and programs run out of HHS and encouraged at the state level.

    • Program evaluation and accountability—Allow for program evaluation tools that are appropriate for assessing the quality of the unique Montessori setting
    o Student:Teacher ratio—flexibility in student:teacher ratio that takes into account the unique role of the teacher, environment and mixed-age classroom and allows for a larger student:teacher ratio (of up to 28:2 in a 3 – 6 year old classroom) than in conventional settings.
    o Classroom environment—environment assessment tools that are either designed specifically for Montessori classrooms or are flexible enough to recognize that some of the supplies, materials and activities one might look for in a conventional setting are not appropriate in a Montessori setting and vice-versa. For example, a Montessori classroom provides a language rich environment through the materials rather than word walls and nurtures creativity through open-ended work rather than dress-up corners.
    o Formative assessment – attention to teacher observation and detailed tracking of student progress.
    o Outcomes – attention to observable behaviors such as student engagement, independence and focus and developmentally appropriate measurable outcomes at the end of the 3-year cycle.

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

    While we recognize that the current funding proposal strictly addresses high quality preschool for 4 year olds, it is our deepest hope that the regulations and practices that come out of it support rather than preclude an ultimate vision for a continuum of uninterrupted, highest quality, family and child education for ages 0 – 6 and beyond. Every child should have access to highest quality care and education in a racially, ethnically and socioeconomically diverse setting without families needing to renegotiate applications, resources, settings, schedules or systems as their children grow.

    High quality Montessori education provides the foundation that children need to move forward in school, society and life. We appreciate your attention to the above considerations in crafting regulations that open the door and facilitate bringing this carefully honed, effective and loved method to all families.

  21. Colorado has long been a leader in early childhood care and education. We have a 25-year history of investing in a state preschool program that serves children in private community, Head Start and school district settings. We have had program quality standards in place since 1994, early learning guidelines established in 2000 and an early childhood assessment and outcomes program since 2003. Colorado’s accomplishments also have at their foundation a commitment to collaboration and systems work with regional early childhood councils, established in 1997, that focus on improving the quality of and access to early childhood programs. That commitment to quality continues with our current Early Learning Challenge Fund Grant priorities for investing in QRIS, work force development, new comprehensive birth to eight early learning and development guidelines and expansion of formative assessment into child care settings and kindergarten classrooms.

    On February 25, 2014, the Colorado Department of Education convened a group of stakeholders in order to discuss our shared vision for preschool development within our state’s early childhood system and our hopes relative to this new RTTT competition. The group was composed of individuals representing state education and human services agencies, private child care, Head Start, local school districts, a philanthropic foundation and a child and family advocacy group. We ask that you consider the following recommendations:

    1. Above all, keep the focus on quality. The promise of positive outcomes is only possible when preschool programs are of high quality. Strong curriculum and assessment, qualified staff with ample opportunities for professional development, well designed and provisioned environments, appropriately balanced and organized daily routines, high quality adult-child interactions and strong parent involvement are all essential elements. In addition, staff must have adequate time to prepare lesson plans, to prepare the environment for learning, to individualize instruction and to document and reflect on child progress.

    2. Permit states that have previously been successful in the Early Learning Challenge Fund grant competition to also compete in this new competition. We believe that this competition affords the opportunity to round out the considerable systems building made possible by the ELCF grant by focusing on state preschool development and its role within the larger early childhood system.

    3. Allow the flexibility for states to use the funds for enhancement of existing state preschool programs as well as for capacity building.

    4. Place funding priority on the comprehensive services for preschoolers and their families that are necessary to ensure the highest possible outcomes for children. This priority area should focus on partnerships with Head Start, private early childhood programs and other local agencies and should target family needs for wrap-around child care, mental health services, health and dental care.

    5. Place emphasis on:
    a. Braided funding models that promote inclusion, wise use of resources and reduction of silos
    b. Multiple-setting models that offer choices for families
    c. Models that encourage innovation and flexibility at the local level
    d. Systems approaches that foster collaboration and coordination
    e. Models that foster connection and coordination with early intervention and special education services
    f. Models that foster connection and coordination with birth to three programs and services and with kindergarten and first grade

    6. Place priority on proposals that focus on:
    a. Effective inclusion strategies for young children with disabilities
    b. Strengthening English language acquisition services and supports
    c. Strengthening preschool capacity to implement positive behavior intervention
    d. A commitment to engaging families in meaningful ways

  22. This is not about our children, it is about money, power and control. Removing rights from the parents down to living within the compounds of our homes without being monitored by home visits.

    WHEN PARENT’S SACRAFICE THEIR CHILDREN, THEY WILL SACRAFICE ANYTHING! God bless all our children that cannot defend themselves against tyranny. Read below: It can and will happen in America if parent’s don’t start looking outside of themselves and their needs to the needs of their children and our country.

    Dated February 21, 2014 – “Social Worker for Every Child”…In Edinburgh yesterday, the Scottish Parliament passed the “Children and Young People (Scotland) Bill” by a vote of 103-0 with 15 abstentions. This legislation, which is specifically intended to fulfill Scotland’s perceived obligations under the United Nations’ Convention on the Rights of the Child (CRC), includes a provision to assign a specific government worker to every child at birth. These “named persons” will be charged with safeguarding each child’s welfare and with representing the state to the family. Giving a state actor, in place of or alongside parents, responsibility for children is a drastic measure usually reserved for cases of child abuse or neglect – but Scotland has deemed it necessary to guarantee the “best interests” of every child as called for in the CRC.

  23. The federal government should reduce its impact on education, not expand it. Ever since the Feds got involved in education, students’ test scores have decreased and the performance of US students vs. the rest of the world has declined. More money will not solve the problem. The federal government’s own studies have shown that programs such as Head Start have no lasting impact on students’ abilities to succeed educationally.

  24. The BUILD Initiative is pleased to submit this letter to inform the upcoming competition to assist states in developing high quality early learning opportunities for young children.

    Before moving on to specific recommendations regarding what is being called a competition regarding preschool for all four-year olds, BUILD will make one last attempt to convey our strong recommendation that some of the money be used first to fund the next three states from the last RTT-Early Learning Challenge Competition. These states would need to be asked to amend their proposals since full funding would not be available. In those amendments, the Department of Education and the Department of Health and Human Services could require an added focus on preschool if it would like to make it directly connected with the proposed new RTT competition.
    RTT-Early Learning Challenge is now allowing 20 states to accelerate systemic work to support children birth to five with high needs. The systemic focus of Early Learning Challenge is efficient and makes great sense for what could be one time money. In addition, our early efforts to document the impact of Early Learning Challenge are extremely encouraging. States are building the infrastructure, making system component revisions, and testing ways to improve quality so that the early learning system can thrive and be sustained. Please do not abandon this systemic, effective approach.

    In the same vein, the Early Head Start/Child Care Partnerships and the new preschool competition should be viewed and treated by states and by the grants administrators as part of a whole. These efforts are inter-related. Each should be viewed and judged as part of a state’s efforts to build a system of systems to support our youngest children.

    We urge that in both of these competitions that state leaders are given decision-making power over how funds flow to local communities.

    In the preschool competition, BUILD recommends:
    1. Funds flow to the state. The state should determine how funds flow to local communities. This is important to connect to state-level quality improvement efforts and to align with the other state mechanisms for determining, improving, financing and monitoring quality. t to preserve the mixed delivery system
    2. Awarding priority points to states that show evidence of existing or planned integration of preschool into a continuum of high quality supports and services from birth (although including prenatal care would be even better) to kindergarten entry. Many states have been working at dizzying rates to create infrastructure, build capacity, advance integration and develop a comprehensive continuum of supports and services. This competition should reward this work and incent others to take it on. Preschool plans should not be viewed in isolation of this systems perspective. Specifically, priority points might be awarded if plans include:
    a. Demonstration that the state is making attempts to marry the Early Head Start/Child Care Partnership funding to strengthen the supports and learning opportunities for infants and toddlers and their families with preschool funding for four-year olds, and overall systems integration and alignment efforts for children from birth to kindergarten age.
    b. Evidence that the preschool funding will be connected to and build on the Quality Rating and Improvement System if the state has one.
    c. Demonstration of planned or already existing links between preschool and early childhood and K-12 data systems.
    d. Demonstration of planned links between the new preschool funding and the state’s professional development system.
    e. Evidence that the preschool funding will be connected to and build on concerted efforts to engage families.
    3. For states with QRIS, require that the preschool programs participate in the QRIS.
    4. Again for the purpose of promoting alignment, consider requiring application approval by multiple leaders including the chair(s) of the State Early Childhood Advisory Council and state agency leaders with jurisdiction over home visiting and CCDBG.
    5. Maintain existing investments in early childhood. Given the underfunding of so many early childhood related programs, it is critical that the new funding augment rather than replace a state’s total early childhood investment. Please include the “supplement not supplant language of RTT-ELC.
    6. Ensure that funding addresses racial, ethnic, cultural and linguistic disparities. Applicants should be required to describe past and future efforts to ensure than expansion of services is targeted to underserved or unserved areas and includes thoughtful approaches to meet the needs of children of color, cultural minorities, and children in families where English is not the home language, etc.
    7. Set high quality standards and expectations. These standards should include well-trained teachers with professional compensation, rigorous curricula and developmentally and culturally appropriate assessments; measures of environmental quality and adult-child interactions; comprehensive services; family engagement; and low adult to child ratios. The expectations should include increased inclusion of children with disabilities in all preschool classrooms.
    8. Include money for workforce investments. States should describe how they will make investments in the workforce to support early childhood educators in all settings to meet education standards and to receive professional development. States should be provided incentive points to consider cultural and linguistic diversity and competency in the workforce. The Appropriations Committee Reports includes language that allows a portion of development grants to be used for teacher training and education, and inclusion of this in state plans should be a priority for awarding grants.
    9. Related to workforce investments, to increase the number of minority and dual language learner participants in preschool, grant applications should address the need to create a workforce that is representative of children served in these programs. States should be required to provide plans to maintain or increase the diversity of the preschool teacher workforce. Additionally, states should be required to describe plans to prepare all teachers to effectively support learning needs of diverse learners such as dual language learners and children with special needs.
    10. Promote (or even require) a mixed delivery system. Preschool expansion should include a wide range of early childhood providers that meet high quality standards. A mixed-delivery system enhances parent choice and increases access. It addresses some of the facilities’ issues and it is cost effective. Most importantly, it engages all he potential expertise of the early learning community.
    11. stimulate preschool investments in states with no program. One mechanism might be to create a priority for states with a high proportion of children with high needs that lack access to high-quality preschool.

    Thank you for the opportunity to provide comments. We are excited about the new investments and look forward to more great state work that will support young children, particularly those with high needs, by building supportive communities, engaging families, and expanding access and quality to early learning opportunities in manifold settings from birth to school entry and into the early elementary years.

  25. No, this is not a good idea. This will lead to federally mandated preschool. There should be no educational mandates on the federal level per the 10th amendment. Education needs reform, but adding more top-down policies is reforming in the opposite direction of what we need. Get local control back!

    Preschool should not be required. It seems that the government schools are trying to take children away from their parents earlier and earlier.

    As for the money, this gets buildings and furniture, but who is paying for the staffing? Oh, the people paying taxes on the local level – the people who have no say in this whatsoever.

    I appreciate the opportunity to make comments, but the truth is that this administration has gotten so out of control that they will do what they want anyway with their “pen and phone”. Please start listening to the people and start following the legislative process as it was set up by our founding fathers!

  26. New York City’s Administration for Children’s Services (NYC ACS) appreciates the opportunity to comment on the use of the $250M included in the Omnibus Appropriation bill for a major new preschool initiative. As you know, New York State scored well on the Race to the Top Early Learning Challenge Grant Competition but unfortunately did not win. We at NYC ACS are committed to the US Department of Education and Health and Human Services’ mission to build and expand high-quality preschool programs. As such, NYC ACS requests that the Departments offer these funds to additional states that submitted applications for the 3rd round of the competition. New York City is well positioned to make the proposed expansions in developing a continuum of quality education starting with infancy through early childhood and primary school as put forth in our state’s proposal.

    This initiative would build on EarlyLearn NYC, NYC ACS’s ground-breaking education model that merges child care, Head Start, and Universal Prekindergarten (UPK) funding and quality standards into a single seamless system of Early Care and Education. EarlyLearn NYC calls for the use of a comprehensive quality assessment system that address children’s developmental and health needs. New York State has taken the steps needed to build a high-quality early childhood system of services. Similar to the Race to the Top proposal, EarlyLearn NYC contains family support services targeting health, nutrition, and the social-emotional development of young children. The additional funding for the new Race to the Top competition would be effectively used if high scoring states such as New York had the opportunity to implement their proposals.

    NYC is pleased to see the additional funding for the Federal Race to the Top Early Learning Challenge grant. However, we are concerned about a growing divide between states that have been funded to build high-quality early childhood education systems and those that have not been funded. States that receive grant funding will be at a considerable advantage for the preschool development grants, because they have capacity to develop the systems that will make high-quality preschool programming possible. By not funding those states that came significantly close to obtaining grants, the system would reproduce unequal access and undermine the primary efforts of the proposal. NYC ACS hopes that the Departments of Education and Health and Human Services uses the funds to support and develop quality child care services for our most vulnerable families. NYC is confident that given another opportunity we can provide for local systems of high-quality early childhood and education.

    In order to maximize contribution and costs, the $250M should fund states that scored just out of the running for a grant during the 3rd round, rather than conducting another round of proposals for both the state and the federal government. New York State spent several intense weeks working full-time on the application. Our state teams were augmented by grant writers that were hired at a considerable expense to produce competitive proposals. Since the last competition was held very recently, it would prove wasteful for the federal government to incur a significant expense when there are qualified candidates available for funding.

    NYC supports the President’s call to provide high-quality preschool education for all 4-year-olds from low and moderate income families. We applaud your efforts to enhance early childhood programs and wish to continue our strong partnership in quality early education.

  27. The National Association for the Education of Homeless Children and Youth (NAEHCY) is a national membership association working to ensure success for children and youth whose lives have been disrupted by homelessness.

    Public schools have documented a 10% increase in child and youth homelessness between the 2010-2011 and the 2011-2012 school years, and a 72% increase since the 2006-2007 school year. More than half of all children who enter a federally-funded homeless shelter are under the age of six.

    Homeless children are more likely than poor housed children to experience developmental delays, as well as chronic and acute health problems that compromise their growth and learning. Homeless children also score lower on academic achievement tests than children who are low-income, but housed. Homelessness is an additional risk factor beyond poverty, and that exacerbates other risk factors.

    Preschool programs play a critical role in mitigating the ill effects of homelessness and poverty, and helping homeless children get back on track and ready to learn. Yet homelessness creates barriers to enrolling and participating in early education programs. Lack of records and transportation; the high mobility that accompanies homelessness; lack of available slots/programs; and lack of awareness and outreach efforts by early childhood programs often prevent homeless children from accessing early education programs.

    We urge ED and HHS to develop requirements, priorities, selection criteria, and definitions on homelessness for the new Race to the Top state grants that match those included in the Strong Start for America’s Children Act of 2013. Specifically:

    1. Include the definition of homelessness contained in Subtitle VII-B of the McKinney-Vento Act, which is the same definition used by public schools and Head Start programs

    2. Give priority to States that include a detailed, comprehensive plan for increasing access to and continuity of preschool for homeless children

    3. Require States to give priority to local applicants who demonstrate a detailed, comprehensive plan for increasing access to and continuity of preschool for homeless children, including through collaboration with school district homeless liaisons

    4. Require local applications to adopt policies and procedures that require outreach to identify homeless children; immediate enrollment while records are obtained; continuous enrollment and participation, even if a child moves out of the service area, if that is in the child’s best interest, including providing transportation when necessary; professional development on homelessness for prekindergarten staff; and collaboration with homeless liaisons and service providers

    Thank you for the opportunity to provide input on ways to ensure that the new Race to the Top initiative reaches some of the nation’s most vulnerable children.

  28. Thank you for the opportunity to comment on the new Race to the Top (RTT) competition to build, develop, and expand high-quality preschool programs.

    New Leaders is a national nonprofit organization that develops transformational school leaders and designs effective leadership policies and practices for school systems across the country. Research shows—and our experience confirms—that strong school leaders have a powerful multiplier effect, dramatically improving the quality of teaching and raising student achievement in a school. As we continue to make strong progress in closing achievement gaps that persist in the K-12 education system, we are deeply cognizant of the power of effective pre-K to narrow these achievement gaps in the first place.

    As the U.S. Department of Education develops the specific competition requirements, priorities, and selection criteria, we offer recommendations in the following areas to ensure a high-quality, high-impact RTT program:

    (1) PRINCIPAL SUPPORT & EMPOWERMENT
    School leaders are critical to the successful implementation of any education reform initiative. We believe student learning and achievement can increase when elementary schools have close ties to early learning programs. Elementary school principals require appropriate training and support around early childhood instruction, as outlined in (2) below, as well as resources and flexibility to pursue innovative partnerships with early learning programs, including the opportunity to open preschools in their buildings – increasing consistency in curriculum, instruction, and culture along the critical preschool through high school continuum. Therefore, school leaders – particularly elementary school principals – are an essential component of any preschool expansion effort. For example, many New Leader Principals have worked with their communities to bring early childhood education programs into their buildings and have integrated preschool programming with their schools’ practices (e.g., by providing opportunities for collaboration among pre-K teachers and K-3 grade teachers).

    WE RECOMMEND THAT STATES BE REQUIRED TO INCLUDE IN THEIR APPLICATIONS A DESCRIPTION OF HOW SUB-GRANTEES WILL ENGAGE, PREPARE, AND SUPPORT SCHOOL LEADERS IN EFFORTS TO EXPAND AND ENHANCE HIGH-QUALITY PRESCHOOL PROGRAMS AS WELL AS OTHER SUPPORTS THEY WILL PROVIDE PRINCIPALS TO ENSURE CONSISTENCY ALONG THE P-12 CONTINUUM OF LEARNING.

    (2) P-12 TEACHER & LEADER EFFECTIVENESS
    New Leaders believes all children – including those in preschool – should have access to excellent teachers who are supported, developed, and managed by great school leaders. There is much progress to be made within and across states in terms of ensuring well-trained and supported preschool teachers. And early childhood educators – just like teachers and leaders in the K-12 space – need high-quality training that includes real practice in an authentic school setting along with ongoing feedback and support from a coach. To ensure high-quality teaching and learning occurs for all students, we believe every preschool educator should be well-trained, have access to a rigorous curriculum, and earn comparable compensation to K-12 educators.

    WE RECOMMEND INCLUDING A COMPETITIVE PRIORITY FOR APPLICANTS THAT INCLUDE AS A KEY COMPONENT IN THEIR APPLICATION A FOCUS ON IMPROVING THE EFFECTIVENESS OF PRESCHOOL TEACHERS AND LEADERS – INCLUDING, BUT NOT LIMITED TO, ENSURING THAT ALL PRESCHOOL EDUCATORS ARE WELL-TRAINED, HAVE ACCESS TO A RIGOROUS CURRICULUM, AND EARN COMPARABLE COMPENSATION TO K-12 EDUCATORS.

    (3) LOW-INCOME CHILDREN, FAMILIES, AND COMMUNITIES
    New Leaders believes that all children should have access to high-quality preschool programs that will prepare them for success in kindergarten and beyond. Research shows that children who participate in high-quality pre-K programs post better academic results in the primary grades and beyond – and these results are particularly strong for children from low-income families, who demonstrate the highest gains and greatest reductions in achievement gaps.

    WE RECOMMEND INCLUDING A COMPETITIVE PRIORITY FOR APPLICANTS THAT INCLUDE AS A KEY COMPONENT IN THEIR APPLICATION A FOCUS ON IMPROVING ACCESS FOR CHILDREN FROM LOW-INCOME FAMILIES AND COMMUNITIES.

    (4) USE OF DATA
    New Leaders supports the Department’s on-going commitment to promoting the effective use of data. We believe that the best education interventions differentiate indicator and outcome data and use both types of data appropriately for single and double loop learning as well as program evaluations. Tracking indicators of success and evaluating outcomes of this RTT program is a vitally important management strategy for states and sub-grantees. To help differentiate their uses, we encourage the Department to distinguish outcome data from indicator data in the selection criteria. Outcome data is important for evaluating success, whereas monitoring the right indicators of success helps programs stay nimble and approach implementation in a way that responds in real time to challenges and hurdles. For indicators to be most helpful they must be tailored to the grantee and sub-grantee strategy and theory of change.

    In addition, we encourage the Department to look for opportunities to build state and district capacity to support coherent early childhood data systems through this RTT program.

    WE RECOMMEND INCLUDING A LIST OF SAMPLE INDICATORS THAT MAY HELP STATES AS THEY UNDERGO THEIR OWN PROCESS OF DEFINING AND ADOPTING MEASURES OF SUCCESS. TO FACILITATE HIGH STANDARDS AND CROSS-GRANT EVALUATION AND TO STRENGTHEN THE FIELD’S UNDERSTANDING OF WHAT WORKS, WE RECOMMEND RETAINING A PRESCRIBED LIST OF OUTCOME DATA. FINALLY, WE RECOMMEND INCLUDING A COMPETITIVE PRIORITY FOR APPLICANTS THAT INCLUDE AS A KEY COMPONENT IN THEIR APPLICATION A FOCUS ON STRATEGICALLY COLLECTING DATA ON STUDENTS’ KINDERGARTEN READINESS AND ENSURING THAT INFORMATION IS ALIGNED AND SHARED SEAMLESSLY BETWEEN PRESCHOOL PROGRAMS AND THE K-12 SYSTEM.

    Respectfully submitted by New Leaders.
    http://www.newleaders.org

  29. We parents do not want any more government intrusion into our lives! ESPECIALLY our kids’ lives. Ultimately this will just be earlier data mining and indoctrination of our kids. Education is supposed to be controlled at a local level and our SD Governor, Arnie Duncan and the DOE and BOE have sold our kids out. This is NOT acceptable. These are our kids and it is up to us to make sure they have every chance to have the same non agenda driven opportunities that we had!!

  30. The Association of Public Television Stations is pleased to have the opportunity to comment on the Department’s “New Competition to Build, Develop and Expand High-Quality Preschool Programs.”

    The nation’s public television stations help bring high-quality educational materials to young children and elementary students every day and we applaud the Department of Education for continuing to make early learning a priority. We believe that preparing our children for school, particularly children from low-income families, is critical to building a nation of students who grow up ready to learn and succeed in today’s world.

    We applaud the allocation of $250 million in Race to the Top Funds “to provide high-quality preschool for all 4-year-olds from low- and moderate-income families through a new competition to expand and enhance preschool programs across States and communities.” We are especially supportive of the statutory language under the FY 2014 Consolidated Appropriations Act (PL 113-76) that requires strong partnerships between local educational agencies and early learning providers regardless of who is the subgrantee.

    Effective external partners can help build critical capacity, bringing additional expertise and resources to early learning so that students can excel. We strongly believe that these partnerships must include public television stations. We are proud of the successful partnerships several public television stations have had with their states in coordination with previous Race to the Top grant awards. Stations have been able to leverage their high quality, educational media resources, established community relationships, and trusted brand to help states and localities meet their formal K-12 educational needs. Given stations’ extensive work in early childhood education, they would also be strong partners in this space as they deliver proven effective educational content on a variety of media platforms, help bridge the home-school divide, and are the educational media brand parents trust most (2014 Public Opinion Poll, CARAVAN ORC International).

    Public television stations are already playing a critical role in local communities and within districts. Using public media’s renowned programming, educators around the country are finding new and innovative ways to personalize learning and positively impact student achievement. PBS Learning Media, which is a free service, is an example of leveraging multi-media content to enhance learning. PBS Learning Media provides over 36,000 interactive digital learning resources, including 1,000 specifically for preschool teachers and students. These include videos, interactive games, and lesson plans, all derived from the best of public television’s content in conjunction with the Library of Congress, the National Archives, NASA, the National Science Foundation and other partners. More than 138 local public television stations collaborate with PBS to impact 1.4 million educators and 30.8 million students in 51 states and territories.

    Research confirms the effectiveness of public television’s multiplatform programming and services, which are available on television, online, through mobile devices and apps, and as classroom resources. A 2012 WestEd study found that engaging low-income parents and their preschool children at home with PBS KIDS content and games boosts math learning and helps prepare children for entry into kindergarten. Public television stations have created early literacy and math initiatives in partnership with libraries, day care centers, public preschools, health clinics, and other community-based organizations in order to capitalize on strategic opportunities to help disadvantaged children master the fundamentals of reading. Through technology, public television stations also have the ability to reach harder to serve students, including those in rural areas.

    In addition to direct student services, public television stations have expertise in providing professional development to educators. Public television stations provide training programs and strategies through high-quality digital resources. The Association of Public Television Stations strongly believes that teachers should have access to high-quality digital resources for professional development, including distance learning programs and on-the-ground community-based programs.

    Public television stations also have the ability to strengthen family engagement and community outreach. These local stations are critical community resources that can provide outreach services to hard-to-reach neighborhoods and homes, through both digital broadcasting and on-the-ground interaction. Local media can help raise awareness of issues and solutions, and public broadcasting stations can provide additional resources to the community.

    It is also essential to note that public television stations have exceptional resources to offer as partners in this initiative. Public media’s award-winning early learning content and outreach resources that support local partnerships are based on developmentally-appropriate educational frameworks, and provide scientific evidence of gains in children’s learning, family engagement, and teacher growth. Through the Corporation for Public Broadcasting (CPB) and PBS Ready To Learn Initiative (RTL) underway in partnership with the U.S. Department of Education, recent studies have rigorously evaluated the impact of PBS KIDS and RTL early math and literacy content in key areas of a child’s life including preschool, home and out of school time settings. Primary findings from these studies reveal that public media is a leader and partner in early learning, with a focus on narrowing the achievement gap for America’s low income children:

    • Out of School Time (2011, WestEd): Students made significant gains in math, vocabulary, numeracy and phonics skills.

    • Preschool Home (2013, WestEd): Children’s math scores improved and parents increased their support of children’s math learning while using Ready To Learn content.

    • Prekindergarten Math (2013, Pasnik & Llorente): Ready To Learn content improved children’s understanding of early math, and increased educator content knowledge.

    • Prekindergarten Literacy (2009, EDC Inc. and SRI International): Ready To Learn content significantly enhances children’s early literacy skills.

    Both the Senate and House bills, entitled the Strong Start for America’s Children Act of 2013, include provisions encouraging coordination of local eligible entities with appropriate media programs, and we strongly encourage the Department of Education to ensure this concept is reflected by including public television stations as partners in the implementation of this initiative.

    Thank you in advance for your consideration of these comments. Please contact the Association of Public Television Stations if you have any questions or for more information on the research citations.

    The Association of Public Television Stations
    2100 Crystal Drive, Suite 700
    Arlington, VA 22202

  31. Dear Secretaries Duncan and Sebelius,

    As the nation’s largest historic civil rights and urban advocacy organization—with 95 affiliates across 36 states and the District of Columbia—the National Urban League (NUL) supports universal access to high-quality pre-kindergarten. We know that a strong start in school will prepare students to succeed in college, work and life and many of our 95 affiliates across 36 states provide early childhood supports through Head Start and other programs. We thank the administration for its emphasis on improving access to early childhood education and appreciate the opportunity to shape the new preschool-focused Race to the Top grant.

    The National Urban League believes that every child should be ready for college, work and life, and look forward to improving the Preschool Race to the Top Grant process through the following recommendations.

    Eligible Subgrantee Recommendations
    We recommend that community-based organizations with a strong history of providing early childhood programming be considered as eligible subgrantees.

    For applicants that already provide preschool, we recommend that only those that have quality state accreditation be considered as eligible subgrantees.

    Recommended Possible Use of Funds for States
    We recommend that states be able to subgrant funds to support capacity-building in areas that do not have a history of preschool programming. These funds can be used to support the development of new preschool programs including those within community-based organizations that have a strong history of providing education programming in high-need communities.

    Proposed Absolute Priority Recommendations
    Research shows a strong connection between parent engagement and multiple student outcomes, including student achievement. We recommend that states be required to include and embed effective parent engagement practices throughout their preschool expansion plan at the state, district and school level. By building strong parent engagement practices in early childhood, schools and districts can build a foundation for stronger parent engagement throughout students’ K-12 education. We recommend that such plans for parent engagement go beyond “traditional” parent engagement practices, such as parent-teacher conferences and include effective research-based practices such as home-visiting, workshops for parents and providing information about grade-level achievement expectations and student performance.

    We strongly recommend that states and districts utilize community-based organizations and other non-profits as partners to develop their parent engagement strategy and to provide technical assistance to implement their strategy.

    We recommend that this priority be addressed throughout a state’s application.

    Competitive Priority Recommendations
    Research shows that achievement gaps begin as early as nine months. As such, we recommend that there be a competitive priority for states with the largest achievement gaps, as determined by gaps between ESEA subgroups. We know that building a strong early learning foundation will have a significant and positive impact on student achievement later in life, and thereby help mitigate the perpetuation of current and future achievement gaps.

    Selection of Subgrantee Recommendations
    Additionally, we would like the Department to require states to create a subgrantee selection priority for districts with the largest achievement gaps, as determined by gaps between ESEA subgroups.

    Subgrantee Requirements Recommendations
    We recommend that subgrantees be required to:
    - Have a prior history and/or a clear plan to ensure that culturally and linguistically responsive strategies are utilized in teaching and learning and for parent engagement.
    - Employ highly-qualified and credentialed teachers and paraprofessionals that are able to provide students with culturally and linguistically responsive pedagogy and curricula.
    - Employ highly-qualified and credentialed leaders and administrators that have training and experience utilizing cultural and linguistic responsive strategies

    General Application Recommendations and Guidance
    In weighing state applications, we recommend that the Department consider both the number of students the state plans to reach utilizing this grant and the state’s plan to ensure that these students receive a high-quality preschool education.

    To ensure a seamless provision of early childhood services, we recommend that eligible child care subsidy recipients be allowed to participate in the Preschool Race to the Top Grant program. This will help ensure that children receive services throughout the day without gaps in supervision.

    We thank you again for the opportunity to comment on the direction of the new Preschool Race to the Top application process and look forward to discussing our recommendations with you in more detail.

    Sincerely,

    Marc Morial
    President and CEO
    National Urban League

  32. I am fed up with the Fed. Gov’t. sticking their nose in our business claiming they can do things better than state or local gov’t.. Obama has stated he doesn’t trust the states to handle education as if he and the Feds. know how. For the Federal Govt. it is indoctrination and control instead of education. Do away with Fed. Dept. of Education and return it to the States and Local Governments. Sorry for the “attitude” but it is time Congress start listening once in a while.

    • You are right on! We do not want OR NEED Obama and the federal government involved! Education is a LOCAL issue and to be left for us to decide!

    • I’m with you Doyle, not only is education none of the Federal Government’s business, it is totally unconstitutional for it to be involved in educating our children. This is totally derived from the Communist Manifesto!

  33. On behalf of the Gesell Institute of Child Development, whose mission is to promote the principles of child development for all decision making about young children, the following are essential considerations for awarding and distributing the money in this program.

    Principle Number 1: The most important thing for any program for young children is to base the curriculum on how children develop and learn. As Dr. Arnold Gesell first discovered and our 2011 national research study confirms, all children proceed on the same path of development, but each child has his/her own rate and pace of development with many bursts and regressions, and starts and stops. For example, the average age that children start walking is 12 months; 50% before, 50% after. Some begin as early as 9 months and some not until 14 or 15 months—this all falls within a normal range of development. All of us would agree that early walkers are not better walkers than later walkers. The second example is that the average age at which children learn to read independently is 6.5 years; 50% before, 50% after. Some begin as early as 4 years and some not until age 7 or later. Research confirms that early readers are not better reader than later readers at the end of third grade. What principle 1 means is that a one-size-fits-all curriculum is not good for children and earlier is not necessarily better when it comes to individual mastery of some skills.

    Principle Number 2: Young children in the preoperational stage of development (ages 2-7 years) learn differently than older children. What does this mean? Children need to learn through doing—not sitting being force fed isolated facts. “Doing” involves using all of their senses including being physical, being active and interactive, investigating and manipulating, exploring and researching, and learning and using new vocabulary. These children are pre-logical and do not think in the abstract. Rather, they think in the “here and now.” This age group does not learn well, and maybe not at all, through sitting for long periods of time at desks, trying to memorize facts that are abstract, and therefore meaningless to them. Young children need to be active and interactive with others in order to learn and construct new knowledge based on old knowledge.

    Quality programs must be led by qualified administrators especially when these programs are in public schools. Leadership in early childhood education requires an understanding of the learning needs for age three to Grade 3 learners, which is usually missing in public schools. Leaders must recognize that these young learners have special requirements and that a continuity of learning happens only when preschool works together in harmony with K-3.

    In order to get the results we want from preK programs must be quality! Quality also means developing the whole child—social, emotional, physical as well as cognitive. So assessments for preK must look at all domains–not just math and literacy! As Dr. Gesell is oft quoted, “A child is more than a score.”

    • Decisions about educating a child before adulthood are no one’s business but the parents’s, and it is totally unconstitutional (illegal) for the Federal Government to mandate anything concerning education period! Even if it were government’s responsability to educate a child (it isn’t), what would they be educated to do, mow lawns? Government interference by making policies that hurt small business, and not doing one of the very few things (control imigration) that it is supposed to do, has driven enough business out of this country and into nations where education is at an even lower level than here, where our system of education has been all but trashed by government. Government get out of education, and allow local control by parents, we know our children better, we know what works with them!

  34. GreatSchools is the nation’s leading provider of preK-12 school information for parents, reaching more than 52 million annual unique visitors and over half of American families. We are expanding our work in early childhood education by developing information guides for parents about quality preK options in their community, as well as providing parents with resources to support early learning in the home.

    We believe our work can help to inform this particular pre-school grant, as well as advancing three important Department of Education initiatives: (1) OMB’s Open Data policy outlined in Memorandum M-13-13 (May 9, 2013); (2) the Department of Education’s (ED) New Framework for Improving Family Engagement (December 2012); and (3) the new amendments to ED’s General Administrative Regulations (EDGAR) to establish better data and performance measures as a condition of federal grants (78 FR 49337 (August 13, 2013).

    While there are many lessons we would like to share with ED, three themes stand out:

    • Transparency: Collecting the Right PreK Program Data. PreK licensing and oversight agencies should collect data on program characteristics and quality, as this is critical to helping parents identify programs that fit the needs of their families. Information should include:
    - Basic information, such as capacity, ages served, hours of operation, enrollment guidance
    - Programmatic information, such as facilities, program description, child-to-staff ratio
    - Quality information, including quality ratings and/or accreditation

    • Access: Supporting Open Data for PreK. The Obama administration has been leading the way on encouraging open data from government. We strongly support applying these ideas to preK, and ensuring that data collected about early childhood programs can be made available to third parties that can help parents understand their school options.
    - In particular, early childhood licensing and oversight agencies should develop API’s that will facilitate efficient access to accurate information about preK options via open and machine-readable data.

    • Informed Decisions: Provide Parents with Access to Engaging Content to Support Learning at Home. To support the family engagement goals established in the grant, preK providers should collaborate with partners that develop parent-centered tools to support early learning at home.

    Thank you for the opportunity to submit comments and we look forward to supporting ED as it help to expands high quality preschool programs in our communities.

  35. The Race to the Top expansion of early education programs for four year olds is an investment in the future of our country. High quality preschool programs are an important component in preparing children for the workforce of tomorrow.
    However, early childhood education occurs not only in preschool classrooms, but just as importantly, in homes with parents teaching their children and reinforcing their learning. Engaging parents from all walks of life as their children’s first teachers and mentors strengthens family involvement and student achievement in later educational settings. A study by the National School Boards Association Center for Public Education found that, “Of those that work, parental actions that support children’s learning in the home are most likely to have an impact on academic achievement in school.”
    The research and evaluation studies of Home Instruction for Parents of Preschool Youngsters (HIPPY), an evidenced-based home visiting program, also support this approach. As a two-generation model that provides books and school readiness activities to parents who then work with their own preschool-aged children, HIPPY has more than 25 years of experience helping parents prepare children for success in school.
    We encourage the Department of Education to make meaningful parent engagement a part of the criteria of the program. Given the tools and skills to create homes where reading is part of day-to-day life, learning is fun, and expectations are high, parents can help their children reach their goals in school and in life.
    Lia Lent
    Executive Director
    HIPPY USA

  36. Stay out of our childrens lives. Children should be taught by there parents not forced to be taught by government ran schools. The same government who can not run a simple website or even pay off debt

  37. Sunnyside Parents As Teachers (SUSD PAT) is an affiliate of the international Parents As Teachers program and uses an evidence based, home visiting model to promote parents’ engagement in their child’s education and to create a strong and lasting partnership between the home, school and the community. I strongly support the federal administration in any and all attempts to invest in high quality early learning and parent education. As a professional who has worked for many years advocating for early childhood in the business community as well as in the legislature, I thank you for the opportunity to comment on this effort.
    Sunnyside Unified School District is located in the south part of Tucson Arizona. The district serves 17,800 students, which includes 81% Hispanic, 76% qualify for free/reduced lunch. All of the district elementary, middle and high schools schools qualify as Title 1 schools.
    Since it’s inception in 1995, SUSD PAT has served 6000 local families and 6,400 children and currently serves 353 district families with 462 children. SUSD PAT continues to work to promote the language and literacy skills of it’s diverse community, which is; 80% low income, 66% parents not high school graduate Sunnyside Parents As Teachers provides personal visits, parent group meetings, parent/child time together, child health and developmental screenings, library/story hour, an award winning program for fathers and community resource referrals. The PAT model is built around three areas of emphasis; developmental-centered parenting, family well-being, and parent-child interaction. I encourage the administration to include parenting education services (including evidence based models such as PAT and adaptations of the model for delivery by preschools, Early Head Start and licensed child care centers) in the application. These services have had the following positive impact on parent and family engagement and closing the achievement gap at kindergarten entry.

    SUSD PAT has been able to demonstrate the following outcomes:
    • PAT graduates have continued to score 20% above district average on the Arizona Instrument for Measuring Standards, a state wide assessment.
    • PAT program has demonstrated a cost avoidance of $350,000 in special education costs for the past five years for students who avoided that placement as a result of being in the PAT program.
    • 80 % PAT graduates were rated by kindergarten teachers as coming to school with good readiness skills 2012-13.
    • PAT parents advocate for their children at district governing board meetings and Town Hall meetings

    SUSD PAT collaborates with non-profit centers, other school districts, Pima County Health Department, Early Head Start, local child care providers, hospitals, libraries, and medical centers to provide a systems approach to serving families and children in our community. Parents As Teachers programs are now state wide and will continue to impact the lives of thousands of children and families in Arizona.

    I strongly encourage the administration to ensure that parenting education is clearly recognized as a critical, quality component in high-quality preschool programs.

  38. So we spend 250 million to build these schools. Now you have buildings, classrooms, furniture. Now where does the money come from to staff these buildings? Local taxes. A school district that can’t afford their current schools won’t be able to afford additional schools. We somehow believe that throwing more money at schools will solve the problem. It won’t. We can start solving the problem by holding parents responsible for raising their kids, teaching them the skill sets appropriate for their age. Now it’s a problem when the parents are also uneducated. President Obama could stop the cycle of ignorance that seems to go hand in hand with low income by enforcing his health care related mandate of giving birth control to all women & by paying for abortions for unwanted children. Give them the pill, make them take them.

  39. To Secretaries Duncan and Sebelius:

    The National Association for the Education of Young Children (NAEYC) is pleased to present the following recommendations to the Administration for the implementation of the $250 million in Race to the Top (RTT) funds to develop, enhance, or expand high-quality preschool programs. NAEYC supports the initiative and the Strong Start legislation with the shared goal of more capacity to provide additional low-income children access to high-quality early childhood education across settings that can meet high-quality standards. In addition to joint comments NAEYC submitted with other organizations, we wish to emphasize the following (prefaced by language from the appropriations legislation and joint explanatory text):

    * Each state may subgrant a portion of such grant funds to local educational agencies and other early learning providers (including but not limited to Head Start programs and licensed child care providers), or consortia thereof, for the implementation of high-quality preschool programs for children from families at or below 200 percent of the Federal poverty line.

    The viability of a continuum of high-quality early childhood development and learning depends on a robust mixed delivery system from birth to kindergarten. Early childhood education helps children receive developmental and educational experiences and it helps families work. A mixed delivery system of high-quality choices of settings and providers supports both of these important goals.

    The federal government should not dictate or prioritize the subgrant of funds to local providers in a way that would disrupt current mixed delivery systems in states or in the future preclude a mixed delivery system that allows high quality providers across all settings to participate. The majority of states that currently fund prekindergarten programs use a mixed delivery approach: high quality child care, Head Start, and school settings. To maintain and expand the broadest options for families, implementation should include a mixed delivery system of providers who want to volunteer to participate (child care, Head Start, and schools) and can meet high-quality standards. States without a state-funded prekindergarten program (low-capacity states) should be required to show how they will accomplish expanded access through a mixed delivery system. One way to maximize a mixed delivery, high-quality system is to prioritize programs that show a commitment to quality either through national accreditation or highest level/points on the state’s quality rating and improvement system. Local recipients – child care, Head Start, and schools – should be required to participate in a state’s quality rating and improvement system if such a system exists in the state.

    * If awards are made to States to build capacity related to high-quality preschool programs, the Secretary of Education shall award two types of grants to States, one to low-capacity States with small or no State-funded preschool programs and another to high-capacity States that have a larger State-funded preschool program.

    Preschool is one component of a system of early childhood education and its efficacy is in part determined by high-quality infant and toddler services, particularly for low-income children. Regardless of whether a low or high-capacity state for purposes of this grant, all states should describe how these funds build on their work toward an integrated, cross-sector system of early childhood education, including quality rating and improvement systems and early childhood professional development systems. They should describe how these funds will build on the state’s use of its Early Learning Challenge, Child Care Development Fund, TANF, IDEA Part C and 619, and locally, Title I resources. States that submitted applications and did not receive an Early Learning Challenge grant should get priority for low-capacity state grants to create more equity of resources among states for the important work of building strong systems of quality across all settings and for all children.

    * Funds may also be used to help early childhood educators to attain higher credentials and degrees.

    It is essential for both low and high-capacity states to use resources to support the early childhood workforce in community settings. A key component of a quality program is the knowledge and skill of teachers interacting with children and families and directors who can support and scaffold their staff to ensure ongoing program quality.

    To facilitate programs attracting, supporting, and retaining quality educators, proposals should demonstrate how a state will coordinate these funds with state professional development systems, including expanding the number of early childhood education degree programs aligned to the NAEYC Professional Preparation standards, articulation agreements between two and four-year degree programs and other professional development and experience, and compensation parity for community-based providers.

    Using these funds to provide scholarships, release time, and transportation assistance is an essential priority for proposals. Directors in community-based settings may also need assistance in meeting higher standards and in professional development as program managers and leaders.

    While building greater capacity for and access to high-quality preschool education and educators, the importance of quality of infant and toddler programs is critical to laying a strong foundation for preschool success. States should also give assurances that these efforts will not diminish support for improving the professional knowledge and skills of early childhood educators working with infants and toddlers in child care, voluntary home visiting, and Early Head Start.

    NAEYC looks forward to advancing this initiative and other core programs and services at the federal, state, and local levels that support young children’s successful preparation for school and life success.

    • The Federal Department of Education was created to establish:

      1) Creating a system that actually dumbs down the children of this nation, while pretending it is to give them better oportunities in life throug quality education, while actually doing just the opposite.

      2) Creating a system where Government, has a captive audience, where they can push Socialist ideas into the heads of children, while gathering and storing information concerning every single issue that goes on in every household in America.

      3) Controling every American through this indoctrination, while creating a Fascist state where the average household will barely be able to keep it’s head above the economic water.

  40. The government should stay out of stuff especially schools. They are not doing what they say or have promised in the past. They will only hurt the existing school system we have now and more than likely in the future diminish what they built up for theses schools. They need to fix what they presently have their hands on and not go back on their promises no matter what the cost is. They should be giving up their pay to help with the government issues!!!!!!!!!!!!!!

    • Their goal appears to be to “nationalize” all the school systems in America by diminishing the control of school boards, teachers ability to choose what is best for their students to be learning, and the state school boards.

  41. Based on the Constitution, the Federal Government has no authority in Public Education. That authority remains in the States, and it is the people of those States that have the power to determine the standards and curriculum to be implemented in the education system.
    Arne Duncan has made it clear that he intends to transform education in America to take control over the lives of all children from birth to adulthood. He intends to extend school hours to 12 hours every day, to have the schools involved in all areas of the community, to indoctrinate children to socialist reforms through programs such as Common Core. Socialists know that in order to take control of the people, you must take control of the schools.
    Just because you were able to dupe Governors across the country with bribes to accept Federal money to adopt these standards, even though they had not yet been written, and were forced on schools and children without even being tested, without parents being notified or consulted, and without being approved by credible educators, you have not been able to dupe the parents who really do know what is best for their children.
    Public education needs to be controlled by the people in which the school resides. Control of what is taught, how it is taught and when, not to mention, having the flexibility to adjust to the needs of the children. This all needs to be evaluated and controlled at a local level where educators are part of the community. We do not need, or want, some bureaucrat dictating education standards that are being promoted by a group of business’s that see a cash cow in the form of expanding a nationwide system at the expense of the tax payer.
    Furthermore, the Common Core Standards are flawed and actually do not raise the education bar, they actually lower it. It is a one size fits all approach and eliminates any possibility of being adapted to the individual needs of the student. Many key components are missing or are taught in an inappropriate structure.

    • I completely agree. All of these well written proposals and requests for Federal Government funds should be a mute point. Have any of the people running these organizations ever read our Constitution? The Federal Government has no authority over our schools or their funding. They are illegally funding schools. We are a Country $17 trillion, plus, in debt. We should be eliminating Federal funding of these programs, not creating more. Those vying for these sorts of funds should be ashamed of themselves for supporting these efforts by our Federal Government.

  42. The federal government needs to stay out of our local preschools. The federal control that ALWAYS comes with these initiatives is not worth any amount of money.

  43. Dept. of Education,
    As common core fails our children… how can we possibly justify producing another disaster? Education is best handled at the local level, without federal interference. [sigh.] It comes as no surprise that D.C. is, yet again, attempting the unconstitutional.

  44. The evidence shows there is no advantage to children starting school early. Knowing that, there is no reason to spend money on pre-school. Children need their parents influence, not government’s.

    This is clearly being pushed to wrest control of our children as soon as possible. More and more parental rights are being eroded by the government.

  45. I am a retired School Psychologist with other 40years experience. During that time I have seen a deterioration of our Education System; at the same time the Bureaucracy and Top-Down control have increased exponentially. These are not unrelated phenomena. When control of Education returns to the local and state level, we will again have quality education in this country. Therefore I strongly oppose Federal Government Programs such as RTTT and Very Strongly oppose the extension of this program to the preschool level.

  46. On behalf of the America Forward Coalition (http://www.americaforward.org), thank you for the opportunity to provide comments on the new competition to build, develop and expand high-quality preschool programs.

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

    We are eager to help drive systems change to help ensure universal school readiness by kindergarten and respectfully ask you to consider the following recommendations as you develop the new competition to build, develop, and expand high-quality preschool programs:

    Encourage Effective Partnerships – Effective external partners provide a range of solutions that can help to provide the full array of supports and assistance needed to remove barriers to learning and build teachers’ and leaders’ capacities that are critical to improving education systems and results for children. Accordingly, the America Forward Coalition believes that new early learning programming should provide incentives for effective partnerships between school districts and external partners. Too often school districts are required or incentivized to use federal funding internally when quality external partners could provide effective solutions to pressing needs and supports for pervasive problems.

    While the FY 2014 Consolidated Appropriations Act (PL 113-76) allows a State to subgrant funds to LEAs and other early learning providers, the America Forward Coalition asks that the Department ensure that such partnerships be encouraged to focus efforts on joint goals (among all partners); provide evidence of success (including through supporting research and evaluation, providing documentation of successful implementation, and providing evidence of impact); focus on program implementation (including joint use agreements and a definition of roles for members of the partnership where appropriate); and monitor program impact by identifying specific impact indicators, providing instruments to collect impact data, and systematically monitoring impact data.

    Reward Results by Investing in What Works – Early learning programming should focus on results and encourage programs and organizations that have achieved success. It is critical in a time of limited resources that we invest in a variety of approaches that focus on rigorous data, evidence and better results. In particular, the America Forward Coalition recommends that the Department encourage evidence-based and effective reform strategies that include services and capacities that reduce barriers to learning, support the needs of the whole child, and build a culture for learning and growth.

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

    Pay for Success flips the equation, linking payments to outcomes. Under this funding model, government dollars are paid out only if providers achieve intended results for the people they serve. The America Forward Coalition believes that programs designed to “pay for success” have several advantages: (1) by emphasizing outcomes rather than rules and regulations, fewer resources are wasted on compliance and bureaucracy so more funds can go to program delivery; (2) by focusing on results and creating incentives for cost-effective interventions, programs will emphasize more effective prevention strategies over remediation; (3) by providing flexibility in choice of intervention and emphasizing results, these designs encourage innovation to identify the most effective strategies; and finally, (4) government, and therefore taxpayers, only end up paying for effective programs.

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

    Accordingly, we ask that the program provide enough flexibility to states and school districts so that they can allocate funds towards what works for their students, including support for effective external partners. This also includes supporting technical assistance, data-sharing and capacity-building for districts, schools and community partners committed to working in integrated and coordinated ways to achieve positive student outcomes.

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

    Support Effective Teachers and Leaders – The America Forward Coalition believes all students should be served by effective teachers that are knowledgeable about data-driven instruction and are able to develop learning pathways for individual students as well as strong leaders who are able to attract, retain, and support a motivated instructional team, build a strong positive culture, use data to inform every day decision making, and engage families and communities to assemble the comprehensive resources, research-based instructional support and services children need to be engaged learners. In addition, the America Forward Coalition believes new early learning programming should support evidence-based professional development on effective interventions that address cognitive, social, emotional, and behavioral barriers to student achievement and success for all students.

    Thank you again for the opportunity to comment. Please contact me if you need any information or have any questions related to our recommendations.

    Sincerely,
    The America Forward Coalition Education Task Force

  47. In the 2010 state report card on child homelessness, provided by the National Center on Family Homelessness, it was stated that 1 in every 45 children are homeless in a year. The effects of homelessness are far reaching and impact a child for years to come if there are not supports in place to be able to provide safe places, nurturing environments and strategic interventions to support a child’s development.
    Today I am speaking for the children in our nation that are homeless and live in a states where limited funding and access to quality preschool programs is unavailable. I am advocating that funding be made available to states to build, develop, support, and expand high- quality preschool programs for homeless children. I have the opportunity to direct the children and youth services, to include a state licensed and nationally accredited child development center, at the largest family homeless shelter in my state. A majority of our child development center is funded by private dollars as state dollars continue to diminish. None of our families are required to have child care subsidy. (Our state waiting list to provide for child care subsidies is 6000 in length.) Through aggressive fundraising our program has been able to be sustained. However I know this is not the case for many other programs.
    The impacts that we have seen in being able to provide a high quality program for the children that live here at the shelter have proven to be substantial. Through the collection of data from the ongoing assessments we do on our children, 100% of the children that enter the child development center program at our shelter, improve in one or more developmental areas (social, emotional, cognitive, fine and gross motor, communication). To have been able to support this growth our child:teacher ratio is low, we have highly qualified teachers and we have been able to provide an environment that is safe, nurturing, and intentional in all aspects.
    Our children may stay in our program for a few days up to two years (upon exit from the shelter). The descrpancy in this lies with that after having received high quality preschool, when our children leave the shelter there are limited programs that they are able to attend. I am advocating that the U.S. Department of Education release funds to support quality programs and are almost null and voide due to the lack of funding in particular states. Our program is a demonstration that high quality provided for homeless children IS effective and funding is needed to target the aspects that make it high quality and effective.

  48. Of the dozen reports I have read about pre-school programs, there seems to be very little value for the money. Comments largely center on the hope of some parents to have tykes occupied for a time during which they don’t have to be bothered by them…. such as the programs that get the kids out of the way for breakfast. National standards would be counter-productive. Teachers’ unions see it as a reuirement for more hiring, raising salaries. Head start has had little benefit, although some say there is improvement for a couple of grades. Certainly a federal standard dangerously erodes states’ authority and responsibility.

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