(C)(1) Developing and adopting a common, statewide set of tiered Program Standards

The extent to which the State and the Participating State Agencies have developed and adopted, or have a High-Quality Plan to develop and adopt, a Tiered Quality Rating and Improvement System based on a common set of tiered Program Standards that--

  1. Are clear and measurable, meaningfully differentiate program quality levels, and demonstrate high expectations of program excellence commensurate with nationally recognized standards* that lead to improved learning outcomes for children; and
  2. Are linked to the State licensing system.

* See such nationally recognized standards as: U.S. Department of Health and Human Services. (2009). Head Start Program Performance Standards. Washington, DC: U.S. Department of Health and Human Services. U.S. Department of Defense. (2009). Sure Start Program Guide: Department of Defense Education Activity. Washington, DC: U.S. Department of Defense. Retrieved from: http://www.dodea.edu/curriculum/docs/sureStart/programGuide/guide_surestart.pdf. American Academy of Pediatrics, American Public Health association, and National Resource Center for Health and Safety in Child Care and Early Education. (2011) Caring for Our Children: National Health and Safety Performance Standards; Guidelines for Early Care and education Programs. Elk Grove Village, IL; American Academy of Pediatrics.

Comments

  • Add: (C)(1)(c) “are aligned with existing state program standards for children’s programs”

The quality of the licensing requirements for states forms the baseline for rating, monitoring and improving programs that are already in the system, and that strengthening the licensing system will also lift the QRIS.

In addition, just as all children should have access to the highest quality programs, we believe that all programs should aspire to the highest quality rating. We suggest that a strong state submission should include an incremental and realizable plan for how non-licensed and license exempt programs will be incorporated into an uncompromised licensing system.

We recommend that States be required to solicit meaningful parent input on the Program Standards through, for example, community cafés, parent surveys, focus groups, and/or participation of parents in the design, review and adoption of the standards. The Program Standards should align with and link to the Family Leadership and Support Standards that we recommend be required as part of a successful State Plan.

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

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: While we support the Administration’s effort to encourage States to develop Tiered Quality Rating and Improvement Systems and Standards that improve learning outcomes, we recommend clarification of the specific requirements under this section. Specifically:
• A common statewide set of tiered Program Standards. Different early learning and development programs are governed by different standards. For example, there are national models for home visiting that set forth specific program standards. While States can seek to align program standards, it is not clear what the Administration means by a common statewide set of program standards. We recommend that the Administration clarify that States should articulate how they will align and link early learning and development programs, but that a common or unified set of standards is not required.
• Linking the tiered Quality Rating and Improvement System to the State licensing system. We recommend that this requirement be amended to provide that QRIS and licensing systems should be linked “as appropriate.” Again, it is important to recognize the wide variation in purpose and design of different early learning and development programs. For example early intervention services provided under Part C of IDEA, home visiting programs and some Pre-K programs are not necessarily part of State licensing systems. While the goal is to improve the quality and alignment of all early learning and development programs, it is important to be mindful of the critical differences among these programs, and how they fit within a State’s quality rating and licensing systems.