Definitions

Common Education Data Standards (CEDS) means voluntary, common standards for a key set of education data elements (e.g., demographics, program participation, transition, and course information) at the early learning, K-12, and postsecondary levels developed through a national collaborative effort being led by the National Center for Education Statistics. CEDS focus on standard definitions, code sets, and technical specifications of a subset of key data elements and are designed to increase data interoperability, portability, and comparability across early learning programs and agencies, States, districts, and postsecondary institutions.

Comprehensive Assessment System means a coordinated and comprehensive system of multiple assessments – each of which is valid and reliable for its specified purpose and for the population with which it will be used – that organizes information about the process and context of young children's learning and development in order to help Early Childhood Educators make informed instructional and programmatic decisions. A Comprehensive Assessment System includes, at a minimum--

  1. Screening Measures;
  2. Formative Assessments;
  3. Measures of Environmental Quality; and
  4. Measures of the Quality of Adult-Child Interactions.

Note: The use of these assessments must conform with the recommendations of the National Research Council's reports on early childhood.

Data System Oversight Requirements means policies for ensuring the quality, privacy, and integrity of data contained in a data system, including--

  1. A data governance policy that identifies the elements that are collected and maintained; provides for training of system users in internal controls; establishes who will have access to the information and how the information may be used; sets appropriate internal controls to restrict access to only authorized users; sets criteria for determining the legitimacy of data requests; establishes processes that verify the accuracy, completeness, and age of the information elements maintained in the system; sets procedures for determining the sensitivity of each inventoried element and the risk of harm if that information was improperly disclosed; and establishes procedures for disclosure review and auditing; and
  2. A transparency policy that informs the public, including families, Early Childhood Educators, and programs of the existence of data systems that house personally identifiable information, explains what data elements are included in such a system, enables parental consent to disclose personally identifiable information as appropriate, and describes allowable and potential uses of the data.

Early Childhood Educator means any professional working in Early Learning and Development Programs, including but not limited to center-based and family child care providers, infant and toddler specialists, early intervention specialists and early childhood special educators, home visitors, related service providers, administrators, Head Start teachers, Early Head Start teachers, preschool and other teachers, teacher assistants, family service staff, and health coordinators.

Early Learning and Development Program means any (a) State-licensed or State-regulated program or provider, regardless of setting or funding source, that provides early care and education for children from birth to kindergarten entry, including, but not limited to, programs operated by child care centers and in family child care homes; (b) preschool programs funded by the Federal government, State or local educational agencies (including Individuals with Disabilities Education Act-funded programs); (c) Early Head Start and Head Start programs; and (d) any non-relative child care providers not otherwise regulated by the State and regularly cares for two or more unrelated children for a fee in a provider setting.

Early Learning Intermediary Organization means an organization (statewide, regional, or community-based) that represents networks of Early Learning and Development Programs in the State that have influence or authority over those Early Learning and Development Programs, including, but not limited to, Child Care Resource and Referral Agencies, State Head Start Associations, Family Child Care Associations, State affiliates of the National Association for the Education of Young Children, State affiliates of the Council for Exceptional Children's Division of Early Childhood and, where appropriate, the National Migrant and Seasonal Head Start Association, the National Tribal, American Indian, and Alaskan Native Head Start Association, and the National Indian Child Care Association.

Early Learning and Development Standards means a set of expectations, guidelines, or developmental milestones that describe what all children from birth until kindergarten entry should know and be able to do and their disposition toward learning. These standards must be appropriate for each age group of infants, toddlers, and preschoolers and English learners, and for children with developmental delays and disabilities. In addition, the standards must cover all the Essential Domains of School Readiness, and must be developmentally, linguistically, and culturally appropriate.

Essential Data Elements means the critical child, program, and workforce data elements of a coordinated early learning data system, including--

  1. A unique statewide child identifier or another highly accurate, proven method to link data on that child to and from the Statewide Longitudinal Data System, including kindergarten entry assessment data;
  2. A unique statewide worker/teacher identifier;
  3. A unique program site identifier;
  4. Child and family demographic information;
  5. Early Childhood Educator demographic information including data on educational attainment and State credential or licenses held, as well as professional development information;
  6. Data on the program's structure, quality, child suspension and expulsion rates, staff retention, and work environment, including all applicable data reported as part of the State's Tiered Quality Rating and Improvement System; and
  7. Child-level program participation and attendance data.

Essential Domains of School Readiness means the domains of language and literacy development, cognition and general knowledge (including early mathematics and early scientific development), approaches toward learning, physical well-being and motor development, and social and emotional development.

Formative Assessment means assessment questions, tools, and processes that are specifically designed to monitor children's progress along the Early Learning and Development Standards and to guide and improve instructional practice, and are valid and reliable for their intended purposes and their target populations.

High-Need Children means children from birth until kindergarten entry who are from low-income families or otherwise in need of special assistance and support, including children who have disabilities or developmental delays, who are English learners, who reside on "Indian lands" as that term is defined by Section 8013(6) of the Elementary and Secondary Education Act, of 1965, who are migrant, homeless, or in foster care; and other children as identified by the State.

High-Quality Plan means a plan that includes, at a minimum, the following components--

  1. A description of the current policies, practices, and resources;
  2. The key goals of the plan.
  3. The key activities to be undertaken and rationale for the activities, which include why the specific activities are thought to bring about the change envisioned and how these activities are linked to the key goals of the plan, and an explanation of how the policies, practices, and resources described in (a) will change as a result of implementing this plan, if applicable.
  4. The timeline for implementing the activities;
  5. The party or parties responsible for implementing each activity;
  6. The information requested in the performance measures, where applicable;
  7. The information requested under the selection criteria as supporting evidence, if any, together with any additional information the State believes will be helpful to peer reviewers in judging the credibility of the plan; and
  8. Any specific elements of the plan that describe how the State will meet the unique needs of the following categories of High-Need Children (as applicable): children who have disabilities or developmental delays, who are English learners, who are living in Tribal communities, and who are homeless or in foster care; and other children as identified by the State.

Lead Agency means the State-level agency designated by the Governor for the administration of the grant; this agency is the fiscal agent for the grant. The Lead Agency must be one of the Participating State Agencies.

Measures of Environmental Quality means valid and reliable indicators of the overall quality of the early learning environment.

Measures of the Quality of Adult-Child Interactions means the measures obtained through a valid and reliable process for observing how teachers and caregivers interact with children. The process should be designed to promote child learning and to identify strengths and areas for improvement for early learning professionals.

Participating State Agency means a State agency that administers public funds related to early learning and development and is participating in the State Plan. The following State agencies must be Participating State Agencies: the agencies that administer or supervise the administration of the Child Care Development Fund (CCDF), the Individuals with Disabilities Education Act Part C and Part B Section 619, State-funded preschool, Home Visiting, Title I of the Elementary and Secondary Education Act of 1965 (ESEA), the Head Start State Collaboration Grant, the State Advisory Council on Early Care and Education, and Title V Maternal and Child Health Block Grant; and the State's Child Care Licensing Agency and the State's Education Agency. Other State agencies, such as the agencies that administer or supervise the administration of Child Welfare, Mental Health, Temporary Assistance for Needy Families, Community-Based Child Abuse Prevention, the Child and Adult Care Food Program, and the Adult Education and Family Literacy Act (AEFLA), are encouraged to participate in the State Plan.

Participating Program means an Early Learning and Development Program that elects to carry out activities described in the State Plan.

Program Standards means the standards that serve as the basis for a Tiered Quality Rating and Improvement System and define levels of quality for Early Learning and Development Programs. Program Standards are expressed, at a minimum, by the extent to which--

  1. Early Learning and Development Standards are implemented through evidence-based activities, interventions, or curricula that are appropriate for each age group of infants, toddlers, and preschoolers;
  2. Comprehensive Assessment Systems are used routinely and appropriately to improve instruction and enhance program quality by providing robust and coherent evidence of--
    1. Children's learning outcomes and development; and
    2. Program performance;
  3. A qualified workforce improves young children's health, social, emotional, and educational outcomes;
  4. Strategies are successfully used to engage families in supporting their children's development and learning, including but not limited to: parent access to the program, ongoing two-way communication with families, parent education in child development, outreach to fathers and other family members, training and support for families as children move to preschool and kindergarten, social networks of support, intergenerational activities, linkages with community supports and family literacy programs, parent involvement in decision-making, and parent leadership development;
  5. Health promotion practices include developmental, behavioral, and sensory screening, referral, and follow up; promote physical activity, healthy eating habits, oral health and behavioral health; and support health literacy among parents;
  6. Effective data practices include gathering Essential Data Elements and entering them into the State's Statewide Longitudinal Data System or other early learning data system, using these data to guide instruction and program improvement, and making this information readily available to families; and

Screening Measures means age- and developmentally appropriate, valid, and reliable instruments that are used to identify children who may need follow-up services to address developmental, learning, or health needs in, at a minimum, the areas of physical health, behavioral health, oral health, child development, vision, and hearing.

State Plan means the plan submitted as part of the State's Race to the Top-Early Learning Challenge application.

Statewide Longitudinal Data System means the State's longitudinal education data system that collects and maintains detailed, high-quality, student- and staff-level data that are linked across entities and, over time, providing a complete academic and performance history for each student. The Statewide Longitudinal Data System is typically housed within the State educational agency but includes or can be connected to early childhood, postsecondary, and labor data.

Tiered Quality Rating and Improvement System means the system through which the State uses a set of progressively higher Program Standards to evaluate the quality of an Early Learning and Development Program and to support program improvement. A Tiered Quality Rating and Improvement System consists of four components: (1) tiered Program Standards with multiple rating categories that clearly and meaningfully differentiate program quality levels; (2) monitoring to evaluate program quality based on the Program Standards; (3) supports to help programs meet progressively higher standards (e.g., through training, technical assistance, financial support); and (4) public availability of program quality ratings; and includes a process for validating the system.

Workforce Knowledge and Competencies means the set of expectations that describes what Early Childhood Educators (including those working with children with disabilities and English learners) should know and be able to do. These must, at a minimum, be evidence-based; incorporate knowledge and application of the State's Early Learning and Development Standards, the State's Comprehensive Assessment System, child development, and strategies for working with families; and incorporate feedback from experts at the State's postsecondary institutions and other early learning and development experts.

Comments

High-Quality Plan
Add (i) “An explanation on how this plan aligns with and builds upon existing State plans related to children.”

Lead Agency
In many if not most states, the best entity to serve as a lead for an interagency efforts is one that is neutral from any particular agency, such as the Governor’s Office, Lieutenant Governor’s Office, the First Spouse’s Office. However the current definition of Lead Agency states that it must be one of the Participating State Agencies, which in turn is defined as “a State agency that administers public funds related to early learning and development.” It is not clear that the Governor’s Office, Lieutenant Governor’s Office, or the First Spouse’s Office would qualify under that definition. Likewise it is not clear that existing interagency efforts (which may be housed in the Governor’s office or similar non-agency entity) would be eligible under that definition.  Recommendation:

  • In the definition of Lead Agency, after “…must be one of the Participating State Agencies” add “or the Governor’s Office, Lieutenant Governor’s Office, or an existing interagency governance structure such as a children’s cabinet, council or commission.”

Comprehensive Assessment System:

We encourage the Administration to require States to include a valid and reliable tool to measure the extent to which programs and professionals are meeting the Family Leadership and Support Standards. By way of example, we offer CSSP’s Strengthening Families Program Self-Assessment as a model for such a tool. The Self-Assessment is a valid and reliable instrument for measuring the extent to which a program uses seven strategies that our field research identified as used by exemplary programs to support families:

1. Facilitate friendships and mutual support
2. Strengthen parenting
3. Respond to family crises
4. Link families to services and opportunities
5. Facilitate children’s social and emotional development
6. Observe and respond to early warning signs of child abuse or neglect
7. Value and support parents

CSSP has developed an on-line version of the Self-Assessment that enables programs to compile responses from staff, parents and administrators, compare responses over time, and develop an action plan for continuous improvement. Data can be aggregated across programs and at the State level to provide snapshot information, monitor trends, and inform policy. This tool demonstrates the realistic potential to include Family Leadership and Support measures within a comprehensive Assessment System.

Early Childhood Educator:

We recommend the inclusion of
• Family, Friend and Neighbor (FFN) care providers (also known as non-licensed or informal care)
• parent educators
• Family Leadership and Support specialists / coordinators, or other similarly defined professionals who directly support parents at the program level (or help other professionals to do so), and/or who support parents in their roles as partners in governance, policy formation, program oversight, etc. at the program and State policy level.

Early Learning and Development Program:

We reiterate our previous recommendation related to the criteria language and encourage the secretaries to modify the definition of Early of Early Learning and Development Programs to: 1) reflect the importance of children’s successful transition into kindergarten; and 2) encourage strong relationships and coordination between Early Learning and Development Programs and public schools.

To this end, we recommend replacing “from birth to kindergarten entry” with “from birth through transition to kindergarten, ” as follows:

“Early Learning and Development Program means any (a) State-licensed or State regulated program or provider, regardless of setting or funding source, that provides early care and education for children from birth through transition to kindergarten. “

We also assume that the definition proposed by the secretaries includes Family, Friend and Neighbor care providers (also known as non-licensed or informal care). If not, then we recommend that it do so.

Early Learning Intermediary Organization:
We recommend adding State Children’s Trust and Prevention Funds to this list. Many of these etities administer State and federal child abuse prevention and family support funding to community-based programs, including early learning and development programs. In many States, the Trust Fund is a lead partner in encouraging programs to adopt the Strengthening Families approach. They are also supporting policy and systems change to help programs incorporate the Protective Factors into their goals and performance measures, and ultimately to better support and serve families. The Trust Funds are a critical partner in the Strengthening Families initiative and offer a wealth of experience and knowledge about how programs can support parents as decision makers and leaders.

Early Learning and Development Standards:

As we have discussed in previous comments, we recommend the addition of a definition for Family Leadership and Support Standards that describe what all families need and what programs, professionals, and systems should do to optimize parents’ role as their children’s first teachers and value them as decision makers and leaders. These standards must be appropriate for all families and be linguistically and culturally appropriate.

We recommend that the Strengthening Families approach and Protective Factors Framework be considered as a model and starting point for the creation of these standards, and offer available implementation tools to support replication of effective strategies across states.

Essential Data Elements:

We recommend including data from the proposed Family Leadership and Support assessment tool among the essential data elements. This could include child-, family-, and/or school-level data on Family Leadership and Support activities; data on the number of parents engaged in various leadership roles in the program, policy, evaluation and oversight of the system; the types and frequency of training and other supports provided to parents in these roles.
We also recommend inclusion of aggregate and disaggregated data (by school district) on the number and percentage of young children who: are in foster care and the differential response system; have been referred to child welfare; are receiving Part C Early Intervention services; are children of teen parents; have been exposed to domestic violence in the home; and children whose parents suffer from depression, other mental health problems, or substance abuse.

High-Need Children:

We recommend that the definition of High-Need Children include children of teen parents; children who have been exposed to domestic violence in the home; children who are or have ever been connected to the child welfare system (not just those currently in foster care), including those in families served through a State’s differential response system; children who are at risk of developmental delays or disabilities (not just those who already demonstrate delay, for example, those with extremely low birth weight and who required prolonged neonatal intensive care); and children whose parents suffer from depression, other mental health problems, or substance abuse.

We also recommend that the definition also include children who belong to racial and ethnic groups associated with persistent achievement gaps.

Measures of the Quality of Adult-Child Interactions:
We recommend including within this definition or as a new item a definition related to Measure of the Quality of Adult-Adult (or Teacher/Caregiver – Parent) Interactions. This would mean the measures obtained through a valid and reliable process for observing how teachers and caregivers interact with parents. The process should be designed to promote effective Family Leadership and Support strategies (aligned to the Family Leadership and Support Standards) and to identify strengths and areas for improvement for early learning professionals and programs.

Participating State Agency:
As we mention in previous comments, to support our recommendation that States be required to develop a specific plan for ensuring access to high quality early learning and development programs for the most vulnerable young children (e.g., those in foster care, those with disabilities, etc.), the Administration should require that State Child Welfare agencies, Medicaid and/or State Children’s Health Insurance Program agencies, and Community-Based Child Abuse Prevention agencies be included as required Participating State Agencies to help develop this plan.

Program Standards:

We recommend that the definition of Program Standards also specify that they are expressed by the extent to which
Family Leadership and Support Standards are implemented through research-based activities and strategies that are linguistically and culturally appropriate for all families, as described in (d).

Workforce Knowledge and Competencies:
We recommend that the definition of Workforce Knowledge and Competencies explicitly refer to incorporation of “knowledge and application of the State’s Family Leadership and Support Standards” in place of “strategies for working with families.”

Thank you again for this opportunity to offer our suggestions on Race to the Top - Early Learning Challenge. We look forward to supporting the secretaries and States as they continue designing and implementing this important opportunity.

Signed,
Frank Farrow, Director, Center for the Study of Social Policy
Judy Langford, Senior Fellow and Director, Strengthening Families Initiative, Center for the Study of Social Policy
Teresa Rafael, Executive Director, National Alliance of Children's Trust and Prevention Funds

Please consider adding "adaptive development" to the definition of Essential Domains of School Readiness.

Heather Kilgore
Public Policy Director
PACER Center
(952) 838-9000

On behalf of the Office of the Governor of the State of Illinois, the Illinois State Board of Education and the Illinois Department of Human Services: Under Program Standards (c), we recommend replacing the current: "A qualified workforce improves young children's health, social, emotional and educational outcomes" with "A qualified workforce equipped with the requisite knowledge, skills credentials and ongoing professional development they need to be effective educators."

We request that you further define “Lead Agency” so that fiscal agency does not preclude joint applications among agencies.

The Early Intervention Family Alliance (EIFA) is a national group of family leaders dedicated to improving outcomes for infants and toddlers with disabilities and their families. The EIFA represents family leaders involved in Part C programs in states and other jurisdictions implementing the Individuals with Disabilities Education Act (IDEA) Part C for infants and toddlers with disabilities and their families.

Essential Domains of School Readiness
We were surprised that the adaptive domain was not included in the definition of essential domains of school readiness. The adaptive domain is one of the five domains (cognitive, communication, physical, social-emotional adaptive) required in multi-disciplinary evaluations of infants and toddlers to determine developmental delay under Part C of IDEA. The adaptive domain refers to self-help skills. When newborns develop different cries to indicate their different levels of engagement or frustration they are learning their first self-help skills. Being able to assist with dressing, feeding and having the ability to self-soothe are all key skills that children need to possess in order to be ready for the work of kindergarten. Without these skills children, and the adults who work with them, will be frustrated an unable to focus on language, literacy, mathematics or scientific discovery.

High-Need Children
We would encourage the Administration to use the people first language, and change this to Children with High-Needs. Further, we would request that this phrase be used whenever referring to the targeted population for this grant. We note that in the cover letter the phrase low-income children appears before the term High-Needs Children, however that term is never defined in the grant application and we believe that use of that term may result in the failure by some to address the significant needs of a variety of children who while their incomes may not be low, have barriers to access to programs and supports for early learning and development and fit the definition of Children with High-Needs.

Please consider adding, “including…children with significant behavioral difficulties” to the definition of High-Need Children.

Across America, more and younger children with social-emotional difficulties and/or trauma exposure exhibit very challenging behaviors that disrupt the emotional climate of early childhood classrooms and seriously impede the Early Childhood Educator’s ability to promote development and maintain a quality program. Adding this specific problem to the definition of High-Need Children will acknowledge the impact that challenging behavior has within early childhood settings and help states justify the expenditure of resources on intervention strategies, such as early childhood mental health consultation, to avert the problem.

Thank you,
Mimi A. Graham, Director
Florida State University
Center for Prevention & Early Intervention Policy
Tallahassee, FL

The National Down Syndrome Society recommends the following changes to definitions

---Comprehensive Assessment System: add a reference to universal design for learning as follows to ensure that all children can accurately demonstrate their learning and development.

Comprehensive Assessment System means a coordinated and comprehensive system of multiple assessments – each of which is developed using the principles of universal design for learning and valid and reliable for its specified purpose and for the population with which it will be used – that organizes information about the process and context of young children's learning and development in order to help Early Childhood Educators make informed instructional and programmatic decisions. A Comprehensive Assessment System includes, at a minimum--

---Early Learning and Development Standards: Early Learning and Development Standards as defined in this grant should be aligned with the early childhood outcome indicators for children with disabilities used for OSEP monitoring rather than creating a separate track for these children and asking States to collect data on two sets of outcomes indicators that are not aligned. The Standards should also be developed using the principles of Universal Design for Learning to ensure that all children have an equal opportunity to learn and demonstrate attainment of the standards. The changes to definition that are recommended by the National Down Syndrome Society are incorporated below.

Early Learning and Development Standards means a set of expectations, guidelines, or developmental milestones that describe what all children from birth until kindergarten entry should know and be able to do and their disposition toward learning. These standards should be developed using the principles of universal design for learning; must be appropriate for each age group of infants, toddlers, and preschoolers and English learners, and for children with developmental delays and disabilities; and should be aligned with the Early Childhood Outcomes for children with disabilities described at http://www.fpg.unc.edu/~eco/pages/fed_req.cfm . In addition, the standards must cover all the Essential Domains of School Readiness, and must be developmentally, linguistically, and culturally appropriate.

---High Quality Plan: Add a reference to universal design for learning in section h of the definition as follows:

High-Quality Plan means a plan that includes, at a minimum, the following components--
h. Any specific elements of the plan (e.g. universal design for learning) that describe how the State will meet the unique needs of the following categories of High-Need Children (as applicable): children who have disabilities or developmental delays, who are English learners, who are living in Tribal communities, and who are homeless or in foster care; and other children as identified by the State.

---Program Standards: Add a reference to universal design to learning in section a of the definition and add a new section g as follows

Program Standards means the standards that serve as the basis for a Tiered Quality Rating and Improvement System and define levels of quality for Early Learning and Development Programs. Program Standards are expressed, at a minimum, by the extent to which--

a. Early Learning and Development Standards are implemented through evidence-based activities, interventions, or curricula that are consistent with the principles of universal design for learning and appropriate for each age group of infants, toddlers, and preschoolers;
g. Strategies are successfully used to increase the number of High-Need children in high-quality Early Learning and Development Programs, including those that are not solely for High-Need children

---Workforce Knowledge and Competencies: Incorporate a reference to skills needed to work with High-Need children in programs that are not solely for High Need children in the definition as follows

Workforce Knowledge and Competencies means the set of expectations that describes what Early Childhood Educators (including those working with children with disabilities and English learners) should know and be able to do. These must, at a minimum, be evidence-based; incorporate knowledge and application of the State's Early Learning and Development Standards, the State's Comprehensive Assessment System, child development, strategies for working with families and incorporate skills (e.g. knowledge of universal design for learning) needed to work with High-Need children in programs that are not solely for High Need children; and incorporate feedback from experts at the State's postsecondary institutions and other early learning and development experts.

As members and funders of the Early Childhood Data Collaborative (ECDC), we welcome the opportunity to comment on the Race to the Top - Early Learning Challenge (ELC). We commend the Administration and Congress for the vision to make early learning a priority, giving the U.S. Departments of Education and Health and Human Services joint oversight for these grants, and the robust inclusion of coordinated early care and education data systems as a critical part of state’s delivery of early childhood education.

Specifically, we support language in the data systems-related criteria for selection that ensures states’ early learning data systems will:

• Be coordinated and interoperable with the state’s longitudinal data systems, many of which were built with support from the Statewide Longitudinal Data Systems Grant Program, also administered by the U.S. Department of Education;
• Include a comprehensive set of child, program, and workforce data elements that will ensure these coordinated early learning data systems provide the foundation for answering critical policy questions;
• Use standard structures, data formats, and data definitions to ensure interoperability with other systems; and
• Be guided by data governance and transparent policies that will ensure the quality, privacy, and integrity of early learning data.

We offer one suggestion to ensure that these data systems are as effective as they can be in informing continuous improvement of early learning and development programs that serve children from birth to kindergarten entry.

Definition of “Essential Data Elements”

We propose that the definition of “Essential Data Elements” include “child-level data on development and learning from birth to kindergarten entry.” The current definition explicitly calls for data systems to include kindergarten readiness assessment data. While these assessments would provide important information about a child’s development that could inform continuous improvement efforts, they only capture the data at a particular point in time. For state leaders and local stakeholders to understand how young children are progressing before kindergarten, the requirements in the RTTT-ELC for Essential Data Elements should include data about child development and learning at multiple points in time from birth to kindergarten entry. This would allow policymakers to know which policies and strategies ensure children are on track to succeed, give educators information they need to tailor instruction and interventions, help kindergarten teachers understand any special needs or circumstances that were part of children’s developmental trajectory, and support program administrators in their efforts to improve the quality of their programs to better meet each child’s unique needs. States should have the flexibility to determine the specific times at which data should be collected and to select the specific assessment instruments, so long as they are valid, reliable, developmentally-appropriate and used for formative and continuous improvement purposes. However, if and when states assess child development, they should ensure that these data are captured in their state early childhood data systems.

The members and funders of the ECDC look forward to continuing to work with the Administration and states as they implement this program.

Lisa Klein, Executive Director
Birth to Five Policy Alliance

Tom Schultz, Project Director, Early Childhood Initiatives
Council of Chief State School Officers

Aimee Guidera, Executive Director
Data Quality Campaign

Marci Young, Project Director
Pre-K Now, a campaign of the Pew Center on the States

The National Down Syndrome Society recommends the following changes to definitions

---Comprehensive Assessment System: add a reference to universal design for learning as follows to ensure that all children can accurately demonstrate their learning and development.

Comprehensive Assessment System means a coordinated and comprehensive system of multiple assessments – each of which is developed using the principles of universal design for learning and is valid and reliable for its specified purpose and for the population with which it will be used – that organizes information about the process and context of young children's learning and development in order to help Early Childhood Educators make informed instructional and programmatic decisions. A Comprehensive Assessment System includes, at a minimum--

---Early Learning and Development Standards: Early Learning and Development Standards as defined in this grant should be aligned with the early childhood outcome indicators for children with disabilities used for OSEP monitoring rather than creating a separate track for these children and asking States to collect data on two sets of outcomes indicators that are not aligned. The Standards should also be developed using the principles of Universal Design for Learning to ensure that all children have an equal opportunity to learn and demonstrate attainment of the standards. The recommended changes to the definition are incorporated below.

Early Learning and Development Standards means a set of expectations, guidelines, or developmental milestones that describe what all children from birth until kindergarten entry should know and be able to do and their disposition toward learning. These standards should be developed using the principles of universal design for learning; must be appropriate for each age group of infants, toddlers, and preschoolers and English learners, and for children with developmental delays and disabilities; and should be aligned with the Early Childhood Outcomes for children with disabilities described at http://www.fpg.unc.edu/~eco/pages/fed_req.cfm . In addition, the standards must cover all the Essential Domains of School Readiness, and must be developmentally, linguistically, and culturally appropriate.

---High Quality Plan: Add a reference to universal design for learning in section h of the definition as follows:

High-Quality Plan means a plan that includes, at a minimum, the following components--
h. Any specific elements of the plan (e.g. universal design for learning) that describe how the State will meet the unique needs of the following categories of High-Need Children (as applicable): children who have disabilities or developmental delays, who are English learners, who are living in Tribal communities, and who are homeless or in foster care; and other children as identified by the State.

---Program Standards: Add a reference to universal design to learning in section a of the definition and add a new section g as follows

Program Standards means the standards that serve as the basis for a Tiered Quality Rating and Improvement System and define levels of quality for Early Learning and Development Programs. Program Standards are expressed, at a minimum, by the extent to which--

a. Early Learning and Development Standards are implemented through evidence-based activities, interventions, or curricula that are consistent with the principles of universal design for learning and appropriate for each age group of infants, toddlers, and preschoolers;
g. Strategies that are successfully used to increase the number of High-Need children in high-quality Early Learning and Development Programs, including those that are not solely for High-Need children

---Workforce Knowledge and Competencies: Incorporate a reference to skills needed to work with High-Need children in programs that are not solely for High Need children in the definition as follows

Workforce Knowledge and Competencies means the set of expectations that describes what Early Childhood Educators (including those working with children with disabilities and English learners) should know and be able to do. These must, at a minimum, be evidence-based; incorporate knowledge and application of the State's Early Learning and Development Standards, the State's Comprehensive Assessment System, child development, strategies for working with families and incorporate skills (e.g. knowledge of universal design for learning) needed to work with High-Need children in programs that are not solely for High Need children; and incorporate feedback from experts at the State's postsecondary institutions and other early learning and development experts.

The Measure of Adult-Child Interactions needs to be more specific by including the most important relationship in a child's life, and that is with their parent. Early experiences with parents are critical in fostering and supporting the child's ability to self-regulate. This area or some area in these Standards must address and hold not only "caregivers and teachers" accountable; we must also hold the parent accountable for their child's early experiences, which shape human development. I see a great need in our country for effective Parenting Education Programs. PEPs need be included in the way we Measure Adult-Child Interactions.

I concur with Samuel Meisels’ comment: “The Comprehensive Assessment System (CAS; see section (B)(2) and definition) is potentially misleading in that it unhelpfully combines measures of child development and learning with measures of program effectiveness,” and his recommendations.

In addition, the definition of “Essential Domains of School Readiness” should include something on “social studies,” as the Maryland early childhood assessment properly does.

Monty Neill, Ed.D.
Executive Director
National Center for Fair & Open Testing (FairTest)
Boston, MA
http://www.fairtest.org

Early Childhood Educator: While the definition includes "administrators," in order to minimize confusion and ensure that those in a leadership capacity such as, "directors," supervisors," and/or other supervisory positions, are part of this definition, they should be added to it.