Priority 2: Absolute Priority - Using Tiered Quality Rating and Improvement Systems to Promote School Readiness

To meet this priority, the State's application must demonstrate that it is implementing and validating or will implement and validate a Tiered Quality Rating and Improvement System with the purpose of (1) increasing the number of High-Need Children in high-quality Early Learning and Development Programs, (2) increasing participation in the Tiered Quality Rating and Improvement System across Early Learning and Development Programs (including programs with full-day, full-year care) particularly publicly funded programs, (3) supporting programs in improving the quality of Early Learning and Development Programs, and (4) communicating program ratings to parents and the public.

Comments

  • Add “This Rating and Improvement System may be aligned with other existing State rating and improvement systems for child and youth services.”

We support establishing Tiered Quality Rating and Improvement Systems as an Absolute Priority. As several States that are implementing the Strengthening Families approach demonstrate, a QRIS is an effective mechanism to support implementation of Family Leadership and Support Standards in programs. More than a dozen States are incorporating the Strengthening Families Protective Factors into their QRIS quality indicators. Doing so opens opportunities to also tie-in training and professional development requirements related to Family Leadership and Support. It also offers an entry point for Family, Friend and Neighbor care, as we discuss under Priority 3 below.

In many cases, States are involving parents directly in the design, review, and implementation of the QRIS. Strengthening Families States have many examples and strategies to offer as models for how to this can be done effectively.

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

WI is slow to enter the arena of Tierred Reimbursement systems. I appreciate the committment such a system requires, on the part of stakeholders. I think we need to be careful that we create flexibility about how quality looks and is measured. I also believe that we need to encourage quality through a willingness to reimburse state funded care at a rate that truly represents the cost of quality for those programs ranked at the highest levels as well as a willingness to set a minimal reimbursement rate for programs unwilling to participate and/or scoring poorly in the rating system (minimal care = minimal or possibly no reimbursement). In order for the tierred system to work, we need to: be very clear about the message we send early care and education centers (group and family) about quality, be willing to invest heavily in imporving care (though technical assistance, formal education, and materials grants), and ensure that parents know how to shop wisely for child care.

(a) To meet this competitive priority it appears that the states plan must address changing their licensing and registration laws to include 'all programs not otherwise regulated by the state'. In addition, the number of unrelated children being cared for should increase from two or more to four or more.
(b) This priority requires programs such as Head Start, IDEA, and State Pre-K to submit to multiple monitoring and accountability systems. Will the federal government waive requirements in these federal programs to reduce the burden on state and local programs?

We fully agree that a quality improvement system must include all programs serving children birth to age five. We request that you clarify the meaning of “validating” the QRIS linked to the progress children make in relation to the tiers. We know the overall objective is the highest quality for all children. States should develop the general plan for all children but then strengthen how specific objectives meet the needs of High Risk children.

However, we suggest that states do not yet have the research on which to base the assumption that children do better and better in each respective tier. The ELC should require successful applicants to evaluate, revise and consequently validate their QRIS systems.

State plans should state explicitly how they will use programs standards for collaboration/alignment, and where there is not a direct one-on-one equivalency – how they will provide “cross-walk” advice or system anchors.

The tools for monitoring and evaluating system effectiveness have yet to be developed. States should set ambitious yet achievable objectives. However, all states could use clarification on what that might look like and federal guidance on how to demonstrate reasonable progress.

The LRE requirements in IDEA apply to children with disabilities and address their education with non-disabled peers. However, educating children with disabilities only with other High-Need Children does not provide the full benefits of inclusive education in a classroom with children of all abilities and backgrounds. To ensure that children with any disability (including intellectual disabilities) have increased opportunities to attend early learning programs that are not solely for High-Need Children, the National Down Syndrome Society recommends adding a new (2) to this priority [renumbering the current (2)-(4) as (3)-(5)] as follows:

To meet this priority, the State's application must demonstrate that it is implementing and validating or will implement and validate a Tiered Quality Rating and Improvement System with the purpose of (1) increasing the number of High-Need Children in high-quality Early Learning and Development Programs, (2) increasing the number of children with disabilities, from all the disability categories in the Individuals with Disabilities Education Act, in high-quality Early Learning and Development Programs that are not solely for High-Need children, (3) increasing participation in the Tiered Quality Rating and Improvement System across Early Learning and Development Programs (including programs with full-day, full-year care) particularly publicly funded programs, (4) supporting programs in improving the quality of Early Learning and Development Programs, and (5) communicating program ratings to parents and the public.

I would recommend the guidelines add to (2) a qualifier at the end "and those that serve significant proportions of High Need Children" and to (2) a qualifier at the end "with appropriate strategies to ensure that these programs reach High Need Children."

It is important to make high quality early learning and development programs available to all children, but it would be a mistake to assume that expansions in the numbers of programs meeting high quality standards necessarily will benefit High Need Children. There may be substantially less of a "trickle down" impact upon High Need Children from incentives designed to enable early learning and development programs to reach the highest rating levels on QRIS -- unless there is explicit attention within the state framework supporting QRIS for doing so.

Creating a tiered system is a complex and resource intense process. It is incumbent on us to utilize the existing systems and supports within a state or from national resources to do this. Utilizing an excessive amount of precious state and federal resources to create infrastructure, without including structures (programs, tools, systemic supports) that already exist would be wasteful and ineffective. In particular national accreditation systems should be used to reduce states’ bureaucratic systems, which can really level the playing field because they apply the same standards across all programs in all states. It would also be useful I would think to ask these systems to provide aggregate state level data to be used for planning supports and allocating resources toward needed improvements.
We need to be talking about how to align across states as well as how to make the tiers or levels within states meaningful. MA offers a great example of this. Their licensing standards are very high…a program at the lowest level in MA looks very different from the program at the lowest level in many other states. Wouldn’t it be more productive to use nationally recognized effective systems and tools and apply them consistently within and across states?
If the goal is to provide parents with meaningful ratings, how can we achieve the goal when 50 states will utilize different methods and strategies to deliver ratings that cannot be aligned across states?

In Massachusetts, like in many states, after years of planning and development, we have just piloted (2010) and launched (2011) our updated QRIS. We have communication materials under development for programs, families and interested stakeholders, to be disseminated. To that end, there is still work to be done to develop and engage in communication strategies that effectively reach all applicable families/interested parties in the state. It would be detrimental to the QRIS System to release information about ratings before ensuring that the context behind what the ratings represent has been sufficiently provided and received and a shared understanding exists regarding what each quality level represents. In MA, our licensing standards are high and provide a strong foundation for our QRIS to build upon; a program that meets our high licensing standards could be defined as a Level One program. The common consumer experience with a “Level One” or “One Star” product generally indicates an inferior product – this does not translate to a low level of program quality in this early education scenario. We would also like to ensure that programs participate in the QRIS even if they are a Level One program and are not deterred from doing so by this potential policy. We would like to suggest that before making it mandatory that states release program ratings to meet this priority - that an alternative(s) be provided to allow states to first ensure that education and outreach is sufficient to provide an accurate consumer understanding of the System.
- Massachusetts Department of Early Education and Care (EEC)

This is an absolutely critical component. The elephant on this table is the poor to mediocre quality of many early care and education programs. It will continue to be argued that much time and persuasion is needed to convince programs to participate.

As a state agency that funds programs for highly vulnerable young children, we are moving quickly to performance based contracting. It is not easy to agree on measurement outcomes, but it IS essential.

The first years of life constitute the period where brain growth is most dramatic. Poor quality programs impair that development. Now that we know this, it is unreasonable, unwise and unacceptable for governmental funding to continue to pour into programs that do not meet a good to excellent quality standard.

JM Gruendel, CT

PS. Program quality in this field is linked to the quality of the workforce. The cost of assuring a quality workforce is the twin elephant on the table. We cannot run away from it much longer.

Accountability is a "touchy" subject. As a nation, we are setting standards for student achievement and, yet, we have difficulty setting standards for our performance as educators and childcare providers. We MUST EXPECT that the quality of early childhood care and education will improve and that grants such as this one will provide the funding to put systems in place that monitor quality.

Participation in a quality monitoring system cannot be optional. Yes, it may take time to implement these systems AND we can work alongside educators (teachers, teaching assistants, etc.) and administrators (principals, directors, childcare facility owners and directors) to ensure that we all have a common understanding of quality and the expectations for all providers. We (teachers, administrators in public and private settings) must have a clear understanding of expectations. Resistance is often a by-product of confusion brought about by a lack of clarity of expectations.

Communicating to parents a new definition of quality is the first step in implementing quality rating and improvement systems. If we really believe they are to improve, it may take time to encourage programs to enter and get intial ratings. Then they should have the opportunity to improve. The ratings are short hand for a series of activities and behaviors we want families to extend into the home life of the child and observe and expecct in the program.