Selection Criteria

Selection criteria are the focal point of the application and peer review. States address the selection criteria in their application narrative and a panel of peer reviewers will evaluate the applications based on the extent to which the selection criteria are addressed.

Comments

(A) Successful State Systems

See “General recommendations” above related to changing this criterion to foster successful local systems and providers as well.

Similar to Criterion F(1) in the original Race to the Top program (“Making Education Funding a Priority”), the Department should include a criterion that prioritizes not only past but also future investments by states in early childhood education, development or care programs that benefit children from birth through age eight. And to ensure stable and comprehensive funding commitments among the applicants, the Department should buttress the wording in the RTT-ELC application and provide separate guidance to require strict adherence to supplement not supplant and maintenance of effort provisions.

(B) Promoting Early Learning and Development Outcomes for Children

No comments.

(C) High-Quality, Accountable Programs

In general, Criterion C emphasizes standards, rating and monitoring of programs but does not--with the exception of sub-criterion (C)(3)(c) (“Developing and implementing practices and policies that support and provide incentives for Early Learning and Development Programs to continuously improve”)--adequately prioritize the support and development of employees and leadership as a critical aspect of high-quality, accountable programs. While Criterion D does address the workforce generally, Criterion C should also include and cross-reference sub-criteria related to supporting and developing personnel and leadership, and to fostering a culture of continuous self-evaluation and improvement.

Criterion (C)(1) should specifically call for program standards that

• require that early childhood education policies and resources be integrated across the sectors, including Head Start, Early Head Start, center-based child care, family child care, state- or locally-funded prekindergarten, and early intervention programs;
• foster the transition of children from home and/or preschool to the public kindergarten or first grade, including communication and collaboration among parents/guardians, preschool staff and public school staff;
• call for appropriate facilities conducive to teaching and learning;
• require programs to address the physical, social, mental and emotional health and nutritional needs of children;
• link the education program to a full continuum of services for parents/guardians and children;
• set clear parental and family engagement goals and expectations;
• fully address ECE-special education and ELL children; and
• establish appropriate staff/child ratios.

(D) A Great Early Childhood Education Workforce

In general, Criterion D should more comprehensively address the workforce pipeline and a system of supports for the early education workforce, including workforce recruitment, preparation, professional development (including facilitating the pursuit of further credits, degrees and coursework), mentoring, and other technical assistance.

Criterion (D)(1) should foster the retention of educators, administrators, and education support professionals who possess postsecondary credentials in, and a deep understanding of, child development and specialized training in early childhood education. The program should foster the ability of teachers or instructional assistants to obtain the requisite credentials without compromising quality of education and increasing costs for families. This criterion should also encourage the maintenance of a strong core licensing and monitoring system that ensures the health and safety of children in all child care settings.

Criterion (D)(3) should include partnering with elementary schools to enhance kindergarten entry and the alignment between preschool and elementary programs.

Donna Harris-Aikens, Director
Education Policy and Practice
National Education Association

(A)(2) The extent to which the state has demonstrated its commitment to investing resources should be changed to January 2008 or 2009. State budgets were better in January 2007 and it is unreasonable to require states to maintain that level of funding in the current economic environment.
What federal requirements will be waived allowing states to re-purpose or reallocate IDEA or Head Start funds?

Our organizations commend the U.S. Department of Education and U.S. Department of Health and Human Services for their collaborative effort to reform and improve our nation's early learning programs through the Race to the Top Early Learning Challenge.

Among the many commendable reforms the administration has proposed is the establishment of performance standards that measure the number and percentage of high-need children participating in high-quality early learning and development programs and whether a state has improved the performance of these children when they enter kindergarten.

We know concentrated poverty exhibits a multiplier effect on the challenges that these children face. Several studies have shown that even when controlling for a student's own socioeconomic status, children who live in concentrated poverty do worse on measures of student achievement. For this reason, we recommend that states and communities connect the Early Learning Challenge to a larger educational continuum that stretches from birth through college to career and other initiatives that address the interrelated issues of education, employment, financial security, housing, economic development, physical and behavioral health, and community and household safety.

The Obama administration, through the Neighborhood Revitalization Initiative and programs like Choice Neighborhoods, Promise Neighborhoods, Byrne Criminal Justice Innovation, Community Health Centers and Behavioral Health Services, has recognized the importance of an integrated, coordinated approach that includes early learning as a central element. The Notice Inviting Applications for the FY 2011 Promise Neighborhoods program includes a “Competitive Preference Priority” for applicants who can demonstrate that their proposed project includes a Comprehensive Local Early Learning Network. We hope to also see these ideas of integration and coordination incorporated into other federal and state programs, including early learning programs.

To that end, we recommend that the Obama administration consider in its final requirements, priorities, selection criteria, and definitions, either as a competitive preference priority or selection criterion, the inclusion of preferences in state Race to the Top plans that promote coordinated work in neighborhoods of concentrated poverty.

Sincerely,

America’s Promise Alliance
Center for the Study of Social Policy
Coalition for Community Schools
Harlem Children's Zone
National Collaboration for Youth
PolicyLink
Purpose Built Communities
Strive
United Neighborhood Centers of America

Scoring - The comments about state's varying capacities are very relevant to Arizona. We also would like scoring to consider the relative progress a state has made compared to a starting point - indicating capacity and political will to build on current momentum. We also appreciate the discussion of the importance of non-federally funded programs in a state's overall capacity. We encourage the scoring, and and grant priorities, to encourage the contribution of all early childhood program partners.

Karen Woodhouse
First Things First
Arizona

I will here respond to some of the selection criteria, rather than in the various sub-sections, building on my comments to the opening statement on requirements and to the priorities.

Criterion B.1.

There are a number of pitfalls here:

a. How will the Department judge whether in fact the standards and the assessments really do meet these criteria: “Include evidence that the Early Learning and Development Standards are developmentally, linguistically, and culturally appropriate across each age group of infants, toddlers, and preschoolers, and cover the Essential Domains of School Readiness”? Experience with the realm of testing finds that often claims of validity, for example, rest on very shaky evidence, as tests incompletely and in distorted fashion cover the domains they purport to assess. What is needed here are clear statements as to what the Department actually means by these phrases, and how they will ensure that the real spirit that has animated appropriate education for young children is met.

b. When you require “Include evidence that the Early Learning and Development Standards are aligned with the State's K-3 academic standards in, at a minimum, early literacy and mathematics,” you run the risk of narrowing down to the two subjects and doing so in ways that become test preparation (as I discussed in response to Priority 4). This is already highly visible in K-2 schooling across the U.S. The emphasis should be ensuring developmentally appropriate, high quality, comprehensive schooling for all ages, here focusing on the continuum from pre-school through grade 3.

Criterion B.2.

High quality professional development is essential to ensuring strong and improving programs. The concern we have is that if the assessments are weak or inappropriate, teachers will be trained to use assessments they should not be using. This is likely to harm, not help, programs. As the assessments need to be sufficiently comprehensive and flexible to meet the common and varied goals on early childhood programs, so should the related professional development.

Criterion B.3.

FairTest questions whether it is necessary to have a single state-wide assessment. We note that No Child Left Behind itself allows for local assessments, provided that they can provide comparable evidence across a state. Such systems can be built (c.f. “Multiple Measures” at http://www.fairtest.org/fact-sheet-multiple-measures-definition-and-exampl). The essential criterion is that they cover the “Essential Domains.” Allowing states the flexibility to include local assessments that can provide reasonably comparable information for the low-stakes uses for which the assessments are intended would enable states to allow programs and localities to try out different approaches within the state and see which works and why, which could be a basis for improvement. As my earlier comments state, such assessments must meet strong quality criteria. What are needed in this case are clear standards for the assessments that would allow diversity, high quality and sufficient comparability for program evaluation and improvement.
More generally, the Department tends to conflate centralization with improvement. That link is at best unproven. So long as that is the case, then allowing a decentralized approach rooted in common key standards would be appropriate.

Criterion C.

C.3. It appears that ‘monitors’ are independent reviewers of programs. If states establish teams of ‘monitors’ to conduct comprehensive evaluations of programs, this could be a very valuable contribution. Clearly, such monitors must be very well prepared.

This approach is similar to the “Inspectorate” model used in England, Holland and New Zealand, and somewhat similar to the accreditation process used on colleges, frequently on high schools, and only rarely for elementary schools. Here it would be useful for the Department to carefully evaluate how states establish their monitoring systems and the benefits and drawbacks of each approach. Such information could be very valuable for establishing similar “school quality review” systems of the K-12 schools in states that chose to do so.

[I note that the Department’s “Blueprint” for the reauthorization of ESEA includes a positive reference to this approach. Gary Ratner and I have prepared material on SQR’s – c.f. this summary document at http://www.fairtest.org/sites/default/files/SQR-inspectorate-_working_pa... or more generally material at http://www.fairtest.org/k-12/accountability. In “Grading Education,” Richard Rothstein proposes development of SQR, including a discussion of costs.]

C.4. The validation required here is potentially far too narrow. States are now using inadequate assessments to determine student learning and school quality; it appears that such assessments could be the main component of validating early childhood programs. The multi-state consortia tests now being developed may be a modest improvement, but they a) will likely remain inadequate measures of the subjects covered, and b) will still only include two subjects.

A validation study should require far more, which is certainly allowed in this guidance. But allowing a richer array of validity studies is not the same as requiring them. Thus, the Department should make clear that validation will require significantly more than student test scores in a few subjects, and indicate possible sources for stronger validity.

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

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