Race to the Top - Early Learning Challenge (RTT-ELC) Program

Thank you to everyone who has submitted opinions, ideas, suggestions, and comments on this dedicated Web site pertaining to the draft executive summary of the draft requirements, priorities, selection criteria, and definitions for the RTT-ELC competition.

We received 349 Responses from the public.

We are no longer accepting input on our Web site. Later this summer, we will publish the Notice Inviting Applications (NIA) for the RTT-ELC Program in the Federal Register.

Please check our RTT-ELC Program page for updates.

Thank you.


Thank you for your interest in the RTT-ELC Program, the administration's signature early learning reform initiative. This program will be jointly administered by the U.S. Departments of Education (ED) and Health and Human Services (HHS).

In order to run a rigorous competition and obligate funds to grantees before the December 31, 2011 statutory deadline, ED will waive rulemaking for this new program, pursuant to its authority in the General Education Provisions Act. However, we want your input on how we implement the major elements of this program so we are posting this draft executive summary of the draft requirements, priorities, selection criteria, and definitions for the RTT-ELC competition on this Web site and we encourage all interested parties to share their comments with us. This document will be posted for public input until 5:00 PM EDT on July 11, 2011, at which time the input section will be closed and we will begin considering input received as we develop final requirements, priorities, selection criteria, and definitions. We will publish those requirements, priorities, selection criteria, and definitions in a Notice Inviting Applications in the Federal Register later this summer.

The RTT-ELC competition is a powerful tool that will help highly committed States provide more children from birth to age five from low-income families – with access to high-quality Early Learning and Development Programs. As with the first two rounds of Race to the Top, the bar to receive an RTT-ELC grant will be set high.

Through the RTT-ELC, we want to support breakthrough work that dramatically improves the quality of Early Learning and Development Programs serving High-Need Children. The competition will focus on key reforms, including aligning early childhood resources and systems and improving early learning and development standards and assessment, program standards, tiered rating and improvement systems, and early childhood educators. We will be looking to fund applications that demonstrate courage, commitment, capacity, and creativity.

In commenting on this document, we encourage potential applicants to identify barriers in current federal programs that may impede implementation of an ambitious, high-quality State Plan.

We are posting this document on a moderated site. That means all posts will be reviewed before they are posted. 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. Please do not include links to advertisements or endorsements, as we will delete them before we post your comments. Additionally, to protect your 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 comments. For more information, please be sure to read the "comments policy."

Please understand that posts must be related to the RTT-ELC competition and program, and should be as specific as possible. Each post must be limited to 1,000 words. All opinions, ideas, suggestions, and comments are considered informal input and ED and HHS will not respond to any posts. If you include a link to additional information in your post, we urge you to ensure that the linked information is accessible to all individuals, including individuals with disabilities. We look forward to receiving your ideas and suggestions. However, the input you provide in these posts might or might not be reflected in the final RTT-ELC requirements, priorities, selection criteria, or definitions, or the other policies that are enunciated in the final RTT-ELC NIA.

Again, thank you for your interest in this historic opportunity to support early learning. We look forward to hearing from you.

Note to reader: Defined terms are used throughout this document and are identified using initial capitalization. Definitions are provided later in the document.

Click the links below to read the draft requirements, priorities, selection criteria, and definitions; then click "Add a New Comment" at the bottom of the screen to tell us what you think about that item.


Comments

On behalf of the American Public Human Services Association (APHSA) and the National Association of State Child Care Administrators (NASCCA), we are submitting comments on the Race to the Top Early Learning Challenge (RTT ELC) grants program.

We appreciate the Departments of Education (DOE) and Health and Human Services’ (HHS) effort to dedicate $500 million from President Obama’s Race to the Top initiative to increase supports to improve early learning and development programs. These grants would allow states to raise the bar in promoting high-quality early care and education to help today’s children be school ready and prepared to be tomorrow’s leaders.

Our survey results show that approximately nine states are positioned to apply and a few other states have indicated that applying may be a possibility. The comments below highlight areas in the draft announcement that present potential barriers for some states that wish to apply and offer recommendations and solutions to these challenges.

Challenges and Solutions

1. Signatures and Assurances

The Draft Announcement Proposes:

The application must be signed by the Governor and an authorized representative from every participating state agency.

The Reason Why this is a Challenge:

This language would limit agencies who may want to apply, especially if a Governor’s office does not want to include the agency responsible for child care or early childhood programs.

Recommendation to Consider:

We propose that DOE and HHS ensure that there is sufficient openness and flexibility for all types of agencies to apply.

2. Award Information

The Draft Announcement Proposes:

The Department will not consider funding an application from a state that proposes a budget that exceeds the applicable cap set for that state. In addition, the selection of grantees may consider the need to ensure that systems are developed in states with large, high-poverty, rural communities and may grant awards to high-quality applications out of rank to meet this need.

The Reason Why this is a Challenge:

Because there is a set cap for each state, which is determined by the state’s ranking according to its share of the national population of children from birth through age five from low-income families, it may present a challenge for those states with high-poverty, rural communities who wish to extend services to properly address their needs without exceeding the capped amount for that state.

Recommendation to Consider:

We propose that the language regarding the exception to consider high-poverty, rural communities be clarified to address how the funding cap can be adjusted to meet the needs of this particular population.

3. Priority 2: Absolute Priority—Using Tiered Quality Rating and Improvement Systems to Promote School Readiness and

Priority 3: Competitive Preference Priority—Including all Early Learning and Development Programs in the Tiered Quality Rating and Improvement System

The Draft Announcement Proposes:

For Priority 2, states must demonstrate and validate (or will implement and validate) a Tiered Quality Rating and Improvement System (QRIS) whose purpose is to increase participation in the Tiered QRIS across Early Learning and Development Programs (including full-day, full-year care).

For Priority 3, to receive competitive preference under this priority, the state must demonstrate in its application that it has a licensing and inspection system that covers all programs that are not otherwise regulated by the state and that regularly care for two or more unrelated children...

The Reason Why this is a Challenge:

Some states have different regulations for a QRIS, especially those that require licensing for full-day, full-year care. Licensing for child care and Head Start programs may vary for full-day, full-year care according to a state’s law. Some laws may require a license for early care settings with a greater number of children enrolled in full-day, full-year care. Participation in QRIS in some states is also voluntary, which may be a challenge for some states that are not fully positioned to implement a Tiered QRIS as defined in this announcement.

Recommendation to Consider:

In order for certain states to meet the requirements listed in these priorities, we propose that the language be flexible and not require a certain number of unrelated children to be enrolled in licensed settings.

4. Selection Criteria (A)(5)—Developing a budget to implement and sustain the work of this grant.

The Draft Announcement Proposes:

The extent to which the budget included in the State Plan demonstrates how resources will be repurposed or reallocated from other federal, state, private and local resources to align them with the supporting and sustained activities that are described in the Plan. This includes how funds will be supplemented by repurposing or reallocating funds from other existing early learning and education sources, including how the quality set-asides in CCDF will be used to support and sustain activities described in the Plan.

The Reason Why this is a Challenge:

Because this language places great emphasis on the use of CCDF quality set-asides, state child care administrators are concerned that only child care—and not the federal funding sources of other early childhood programs—is highlighted in this section.

Today, federal child care funding levels are not aligned with program needs and expenditures related to child care costs. With the rise in inflation, this has become extremely problematic for states, especially since the CCDF has not been reauthorized since 2002. The tough economy combined with decreases in state and federal budgets have exacerbated the situation. Consequently, states will face fiscal challenges meeting the requirement to use quality set-asides to implement and sustain the work of this grant.

Recommendation to Consider:

To protect the limited amount of funding targeted to improve quality in child care, we recommend that this language be eliminated or be made more flexible to allow states to blend targeted funds to support these purposes. We also ask to waive a state match requirement due to the budgetary constraints.

We appreciate the opportunity to submit comments and urge you to consider our recommendations and provide some clarity in the final version of the RTT ELC grant program announcement.

Sincerely,

Tracy L. Wareing Lynette Rasmussen
Executive Director Chair
APHSA NASCCA

On behalf of the Heritage Christian School, I wish to express serious concern regarding certain proposed requirements in the Race to the Top - Early Learning Challenge. Heritage Christian School is a member of ODACS, which is a Virginia association of Christian schools, including a number of church preschools that operate under a religious exemption from licensure. Private Christian preschools are part of the solution to providing quality, affordable preschool to low-income families. As such, their autonomy should in no way be affected by RTT-ELC.

The proposed requirements for the RTT-ELC state that in order for states to be eligible they will have to have a plan to bring all early learning programs (including private and non-regulated) under their improvement system and licensing program. Specifically, the requirements explain that a goal of the state should be that all licensed or state-regulated programs will participate in the improvement plan, and that states should have a “licensing and inspection system that covers all programs that are not otherwise regulated by the State and that regularly care for two or more unrelated children for a fee in a provider setting.” This will inevitably bring the private and faith-based early learning centers and preschools under state and federal government control, even though they do not operate with public funds and already have a strong accountability system in place to ensure the quality of their programs.

Furthermore, the definition of Early Learning and Development Program in the proposed funding initiative includes any “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…” This appears to be a back door means for the federal government to gain control over the operations of private church preschools as well as over all preschools in the country. Despite any good intentions, control of our ministries is best left at the local level where programs can be run efficiently and inexpensively; federal involvement will inevitably decrease efficiency and effectiveness and increase operational cost.

In order to ensure that the existing privately-run and faith-based programs remain successful and able to operate, we strongly recommend that these proposed requirements undergo revision to ensure that they do not require states to infringe on the freedoms that are allowing excellent education to take place across the country in the privately-run and faith-based centers. A program designed to improve American education should not do so at the sacrifice of the existing, successful educational programs in our nation.

There is much to applaud in the guidelines, but we also see several ways that certain sections should be strengthened to promote meaningful connections between these programs and elementary schools.

In particular, we are pleased to see:

• The emphasis on statewide standards as a foundation for curricula, assessments and professional development (Priority 1 and Selection Criteria B). With this foundation in place, providers of all kinds will be more likely to “speak the same language” and work together toward common goals for children’s growth and development.
• The request for evidence that the standards are aligned with the state’s K-3 standards (Selection Criteria B-1-c). This alignment could help ensure that the content and concepts that children are taught in elementary school is not redundant or out-of-sync with what they have already learned.
• The multi-dimensional approach to the development of kindergarten-entry assessments, ensuring that they include social-emotional development and are not too narrowly focused on one academic area (Selection Criteria B-3-a).
• The requirement for strong evidence of state agencies working together, including the sharing of data (Eligibility requirements and Selection Criteria A-4).
• The emphasis on building an ambitious statewide system, including the building of an early learning data system that is part of or interoperable with a statewide longitudinal data system (Selection Criteria A)
• The emphasis on coordinating different screening programs to ensure that children who need additional services receive them, whether related to their health, behavior or overall development. (Selection Criteria B-4)
• The emphasis on promoting high-quality, accountable programs through the use of tiered quality rating and improvement systems; and the emphasis including all licensed or state-regulated programs in those systems (Selection Criteria C and Competitive Preference Priority 3).
• The recognition that states must build plans to develop their workforce of early educators through the use of policies and incentives to promote professional development and career advancement (Selection Criteria D).

All of this could go a long way toward better supporting children as they develop. At the same time, we see several areas that could also encourage states to pursue policies that would encourage more sharing up through the early grades, particularly in the realm of professional development and in ensuring that teachers are trained in the appropriate use of kindergarten-entry assessment data.

We offer five recommendations:

• Elevate Priority 4 to a Competitive Preference Priority.

• Under Priority 4, ask states to submit plans for workforce development that recognize the importance of including K-3 teachers and leaders in workshops on cognitive and social development; content areas such as language arts, science and math; coaching initiatives; leadership institutes; and any other professional development (PD) programs that inform educators about how to effectively engage young children in learning.

• Ensure that states are prepared to support elementary schools and kindergarten teachers in administering kindergarten-entry assessments.

• Include K-3 stakeholders in plans for organizing and aligning states’ early learning and development system.

• In pushing for improvements to the workforce, recognize that many credentialing systems are designed to span pre-kindergarten through the third grade.

This is a truncated version of our full comments, which are available at http://earlyed.newamerica.net/publications/resources/2011/comments_on_dr...

Thank you,
Lisa Guernsey
Director, Early Education Initiative
New America Foundation

The National Institute for Early Education Research (NIEER) applauds this early learning initiative and offers the following comments.

- The program calls for a focus on children from birth to age 5. This is an ambitious approach. It should be recognized that current federal and state policies are not adequate for 3- to 5-year-olds; states cannot simply assume this work is done and move on to children under age 3. Neither federal nor state programs for 4-year-olds are sufficiently effective, and 3-year-olds are basically ignored by most states’ early education policies. Yet, simultaneously improving all services for children from birth to age 5 would be a tremendous undertaking and states are hard hit now by the recession. States should be permitted to take on major investments in one sector or program at a time in the context of a broader plan for the entire system. They should not be pressed to produce unrealistic plans for creating seamless high-quality, birth to age 5 systems in a short time with inadequate resources.

- Far too much publicly subsidized and provided early care and education is of such low quality that it fails to significantly enhance child development. Some publicly funded services may even have modest negative impacts on children. The questionable quality of services provided by some public programs for young children makes quality enhancement a more pressing goal than expanding access. Increased enrollment should become a goal only after a program is good enough to substantially enhance learning and development. Infant-toddler care should have a particularly high priority for quality improvement.

- Quality Rating and Improvement Systems (QRIS) are not a proven approach to improving student learning. A QRIS can incentivize some programs to improve their quality for higher reimbursement rates, but those programs are likely to be the ones with the most resources from the start. Too often, programs that are struggling financially will be unable to raise their quality enough to earn the higher rate without more assistance than most QRIS provide. For various reasons QRIS may provide little more than window dressing with respect to improvements in quality or financial incentives for improvement. Ratings systems can become ineffectual. Increased investment in research is needed to learn from different state experiences as they develop and implement QRIS.

- Assessment is a useful tool in continuous program improvement, but must be used with caution. Assessments alone should not be used to make high-stakes decisions about individual programs or children. The regulations call for increasing understanding among educators as to the uses and limitations of various assessment types—this is paramount to ensuring data is collected and used responsibly to improve programs. Assessments aligned with standards can give useful information on what is and is not working in a program, and should be used to guide trainings, professional development, and technical assistance. Yet, many professionals do not sufficiently understand the strengths or limitations of various assessments and the appropriate purposes for which they may be used. For example, it is common to see screening tests used completely inappropriately. Beyond the particulars of assessment, it is important that early childhood professionals be educated about the difficulties in making causal inferences about programs from assessment data and the kinds of evaluation designs required for valid inferences.

- The development of the required kindergarten entry assessment for all students is an ambitious feat, and applicants may need significant guidance in implementing a strategy that works. Current regulations call for educators to implement assessments, though policymakers must be warned of the potential bias of not using third-party evaluators. A kindergarten entry assessment can also only supply so much information regarding readiness and progress without some prior assessment to use as a “baseline.”

- Developing valid and reliable assessments that can be used for every child entering public kindergarten by the 2014-2015 year is a large task with considerable expense. The federal government provided Race to the Top assessment grants for consortia of states to develop valid assessments for students in the upper grades. A similar grant program for early learning would enable states to work together on an early childhood assessment system that is valid, reliable, and manageable. Such an endeavor is likely to be unaffordable state by state; additionally, the field could benefit from collaborations among states so that information collected is comparable across state lines.

- Workforce development is an important goal in providing high-quality early learning experiences. We support the regulations’ focus on improving educators’ knowledge and competencies, and further professionalizing early childhood education to recruit and retain the best teachers. Collaborating with institutions of higher education is essential to ensuring credential requirements truly reflect the skills and knowledge needed to teach young children. Professional preparation and development efforts should formally integrate with higher education to permit seamless career development. Every child deserves a well-educated lead classroom teacher, and one route to this is a bachelor’s degree with an appropriate specialization. Teachers should be properly trained in curriculum, assessment, and pedagogy. Similarly, professionals benefit from supervision by properly trained administrators (e.g., principals, directors, coordinators). Furthermore, NIEER recommends that states address policies for scheduling and staffing patterns requiring adequate time away from children to plan curricula based on assessment and to engage in professional development.

- Judging states based on commitment and investment since 2007 may disadvantage those states whose attempts to develop early learning systems have been slowed by budgetary constraints, especially given the fiscal conditions of these last four years. These states could significantly benefit from additional funding and technical assistance offered through RTT-ELC. Peer reviews should use caution when measuring states against the criteria of prior commitment, as these funds may be exactly the “jump start” some states need to catalyze early learning investment.

NIEER looks forward to the release of the final regulations and to the chance for states to bolster their programs for the youngest learners.

- W. Steven Barnett
Co-Director, National Institute for Early Education Research (NIEER)

Such thoughtful comments. The point about needing more research around assessments struck a particular chord, and I like the idea of a RTT Assessment grant program that could help consortia of states to "work together on an early childhood assessment system that is valid, reliable, and manageable." Along a similar vein, at the Early Education Initiative, we have recommended that RTT-ELC provide some flexibility around professional development so that kindergarten teachers and other professionals in elementary schools (principals, curricula directors, etc) receive PD on exactly how to use the data from these kindergarten-entry assessments to "inform instruction" in meaningful and appropriate ways.

At the risk of taking on too much (I'm sensitive to that issue as you lay it out so well in your comments), we have also recommended that the invitational priority around "sustaining the gains" in K-3 be *elevated to a competitive priority.* This could ensure that states like New Jersey and Washington state could be rewarded for bringing forward strong initiatives to develop connections between elementary schools and birth-to-5 programs.

Having previously served as an appointee to the Virginia Child-Day Care Council (appointed by Governor Warner) and having worked for many years with church ministries that operate child care centers, two statements in this initiative cause signifcant heartburn. The first is found under Priority 3: "It has a licensing and inspection system that covers all programs that are not otherwise regulated by the State..." Some states currently choose not to license or regulate church-operated centers. This priority punishes them for taking that position, a position that has been thoroughly argued and considered in their state. With this priority, the Department attempts to force those states to either adopt the Department's political slant on this issue or give up their opportnity to compete for these funds. My second major heartburn also comes under Priority 3, the requirement that "All licensed or State-regulated Early Learning and Development Programs participate in the State’s Tiered Quality Rating and Improvement System, or that it has a High-Quality Plan to implement such a system by June 30, 2013." By this requirement, the Department forces competing states to bring essentially all child-care centers under a state-administered rating program and improvement system. Both provisions attempt to force states to comply with the federal vision for early education; taking from states their authority, from non-public childcares their independence, and from parents their choice.

Public Comments for Race to the Top – Early Learning Challenge
Dan Zacharias, Old Dominion Association of Church Schools

On behalf of the Old Dominion Association of Church Schools, I wish to express serious concern regarding certain proposed requirements in the Race to the Top - Early Learning Challenge. ODACS is a Virginia association of Christian schools, including a number of church preschools that operate under a religious exemption from licensure. Private Christian preschools are part of the solution to providing quality, affordable preschool to low-income families. As such, their autonomy should in no way be affected by RTT-ELC.

The proposed requirements for the RTT-ELC state that in order for states to be eligible they will have to have a plan to bring all early learning programs (including private and non-regulated) under their improvement system and licensing program. Specifically, the requirements explain that a goal of the state should be that all licensed or state-regulated programs will participate in the improvement plan, and that states should have a “licensing and inspection system that covers all programs that are not otherwise regulated by the State and that regularly care for two or more unrelated children for a fee in a provider setting.” This will inevitably bring the private and faith-based early learning centers and preschools under state and federal government control, even though they do not operate with public funds and already have a strong accountability system in place to ensure the quality of their programs.

Furthermore, the definition of Early Learning and Development Program in the proposed funding initiative includes any “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…” This appears to be a back door means for the federal government to gain control over the operations of private church preschools as well as over all preschools in the country. Despite any good intentions, control of our ministries is best left at the local level where programs can be run efficiently and inexpensively; federal involvement will inevitably decrease efficiency and effectiveness and increase operational cost.

In order to ensure that the existing privately-run and faith-based programs remain successful and able to operate, we strongly recommend that these proposed requirements undergo revision to ensure that they do not require states to infringe on the freedoms that are allowing excellent education to take place across the country in the privately-run and faith-based centers. A program designed to improve American education should not do so at the sacrifice of the existing, successful educational programs in our nation.

Race to the Top – Early Learning Challenge
Michigan Comments
July 11, 2011

Award Information
Regarding the selection of grantees to ensure that systems are developed in States with large, high-poverty, rural communities.

Strong consideration ought to be given to applications from states that have large, diverse, high-poverty populations across both urban and rural areas. The needs of these children and families differ as do the resources and supports to which they may have access. Different system building approaches are required to promote early learning and development outcomes given these realities.

Priority - 1
Regarding the requirement to administer a kindergarten entry assessment to all children entering public school kindergarten by the start of the 2014 – 2015 school year.

Even states with a high quality plan to administer a common kindergarten assessment that is aligned with the State’s Early Learning and Development Standards may have difficulty in meeting the deadline of administration to all children entering public school kindergarten by the start of the school year 2014-2015. Strong consideration should be given to allowing states to set ambitious but achievable targets that do not require a new mandate to be established with no long term resources from this competition to support it.

Priority -2
Regarding the need to implement and validate a tiered, quality rating and improvement system.

To assist states in successfully meeting this priority, an example of an acceptable set of tiered program standards that would meet the definition provided in the draft grant criteria would be most useful.

Priority – 3
Regarding all licensed or State-regulated Early Learning and Development Programs participating in the State’s Tiered Quality Rating and Improvement System by 6/30/13.

To assist states in meeting this priority, a definition of participation would be most helpful.

Selection Criteria
(A)(5)(i) Regarding developing a budget to implement and sustain the work of this grant.

Given that the programs listed as having potential for “repurposing and reallocating” are strongly categorical in nature, additional detail as to what the Federal government is prepared to do to support states to be able to make creative and courageous decisions would be most helpful. For example, will states be able to request waivers for Federal requirements that currently impede the use of these funds outside of a narrow purpose?

(A)(5)(ii) Regarding how funding levels will be sustained after the period of the grant.

Given current economic realities both within the states and in the country, this criterion is unreasonable. Strong consideration should be given to what is sustainable without additional funding and for states to focus on those pieces of this work that can be sustained regardless of a state’s economic situation many years into the future.

Definitions
Regarding the definition of High-Need Children

To assist states in successfully implementing the ELC grant, a definition of “low-income”, for example, as a percent of poverty rate, would be most helpful in determining the cohort of children to be supported under the auspices of this grant.

Thank you for your work to support high-quality learning opportunities for every child from birth through college. The Washington State Department of Early Learning and partners around the state are excited to apply for the Race to the Top – Early Learning Challenge grant. We believe that Washington is well positioned to submit a competitive proposal, as this opportunity builds upon key reforms that we have prioritized in Washington.

We respectfully urge your consideration of the following feedback that we believe will strengthen the final RTT-ELC application.

Priorities:

The invitational priorities are critical in terms of sustaining both ongoing funding and cognitive/developmental gains for children. I respectfully urge ED and HHS to consider these absolute priorities, rather than invitational.

Priority 4: Sustaining Program Effects in the Early Elementary Grades
To create lasting outcomes for children, it is necessary to plan for how the skills and developmental assets of young children align with those they learn as they get older. Recent research illustrates that alignment of standards, curriculum and assessment from prekindergarten through third grade can reduce fade-out and improve academic achievement (source: New America Foundation). Washington has developed successful P-3 models in key schools districts statewide that have created lasting change in child outcomes. Currently, state leaders are working to align P-3 policy during implementation to ensure highest-poverty children are served with a quality continuum of care (preschool, a kindergarten readiness assessment process, full-day kindergarten and lower class sizes in kindergarten through third grade).

Priority 5: Encouraging Private Sector Support
Ongoing partnership with the private sector is necessary in building a sustainable early learning system with widespread support. Washington’s public-private partnership, Thrive by Five Washington, serves as a catalyst for improvements to parenting education and support, child care, preschool and other early learning environments throughout our state.
I respectfully urge ED and HHS to consider including two examples of private sector support (a) private funding demonstrated in terms of grants and in-kind assistance, and (b) a public-private partnership, working with the state agency to fund and sustain key projects.

In terms of the absolute priorities, we are confident that the work we’ve done developing and testing our QRIS and a kindergarten assessment process will form the basis of a strong proposal for Washington. We have been focused on getting the models right, validating and evaluating, ensuring we have completed sufficient outreach, and making informed revisions before statewide roll-out. We are creating a deliberate system, one that is well-researched and tested, and then scaled. Other states have made decisions to roll out statewide models of lower quality, or make major revisions to their system after rolling it out. I urge ED and HHS to recognize efforts designed to create high-quality models from the outset. Additionally (related to absolute priority 2), I would ask the guidelines to consider a broader approach to communication so that we can include our parent and caregiver communications on finding quality care, rather than simply ratings.

Selection Criteria:

The following items are among the most critical to creating a high-quality early learning system and should therefore be emphasized in the final guidelines:

• (A)(1) The State’s ambitious early learning and development reform agenda and goals
• (A)(2) Demonstrating past commitment and investment in supporting Early Learning and Development Programs
• (B)(3) Understanding the status of children’s learning and development at kindergarten entry
• (C)(1) Developing and adopting a common, statewide set of tiered Program Standards
• (C)(3) Rating, monitoring, and improving Early Learning and Development Programs

Thank you for the opportunity to submit feedback. We look forward to competing for this opportunity.

As an organization committed to helping America achieve better education, health, and economic outcomes through investment in quality early childhood education for disadvantaged children, the First Five Years Fund applauds the Department of Education and the Department of Health and Human Services for the outline they have articulated for the Race to the Top – Early Learning Challenge.

Toward the important goals of increasing the number of high-need infants, toddlers, and preschoolers enrolled in high-quality early learning programs and building integrated systems of high-quality early learning programs and services, the Departments have outlined a bold, ambitious, and comprehensive vision focused on effective and efficient programs that make the best use of public investments, and, most importantly, deliver improved outcomes for children. FFYF is grateful for the $500 million commitment to this important program, for the thorough and thoughtful approach in the outline, and for the opportunity to comment on the proposed priorities and criteria. We appreciate the immense amount of work that has gone into the draft document and into identifying essential components. Further, we commend the recognition that it is necessary to link each of those components (for example, that child-level learning standards must be aligned with program and practitioner standards, as well as to data systems) and apply them uniformly across all early learning services.

The Departments’ approach to the RTT-ELC is clear in its focus on four key levers of change: building high-quality, accountable programs, measuring their outcomes with standards and assessments, developing the workforce necessary to deliver quality and outcomes, and supporting and integrating each of those components within an aligned system. These four levers, combined with the absolute and competitive priorities, provide a sound approach to this work that we believe will allow states to creatively and meaningfully advance the goals of the Early Learning Challenge and make progress in meeting the early learning and development needs of vulnerable infants, toddlers, and preschoolers. We recommend that the Departments make it explicit that applicants must make progress in each of the four selection areas.

Within each of the four selection criteria components, we make selected recommendations for the final document that we hope will yield higher-quality planning and implementation and additional clarity for applicants. In some instances, those recommendations are summarized here and detailed within that section’s comment area.

The draft requests participation, coordination, and integration among a broad array of state agencies with oversight over early learning programs and funds. FFYF lauds this list for its comprehensiveness, as we believe giving each of these stakeholders both a seat at the table and a clear expectation for executing the state’s plan is essential for proper oversight and for meaningful collaboration. The draft also highlights the important work to develop and implement the early learning data system that aligns with the State Longitudinal Data System; we support the outlined approach. We recommend four areas for clarification and modification in the final requirements; additional detail regarding each can be found in the appropriate comment section.

We are pleased with the attention given to creating standards and assessments in the Early Learning Challenge, including appropriate implementation, support for educators and programs in their use, specification of the purposes of the standards and assessments, and inclusion of family engagement as part of the standards work. Given all that we know and believe about how children learn, the variability in their early development, and the number of factors that can influence both their trajectories and their performance on a given task on a given day, assessment must be approached carefully. The draft definition of “Comprehensive Assessment Systems” does a sound job of grasping these sensitivities and complexities.

We recommend that the outlined components and approaches in the Comprehensive Assessment System also be applied to the Kindergarten Readiness Assessments (KRA). In order to best foster children’s learning and development, assessment in kindergarten should follow the requirements of the Comprehensive Assessment System. Specifically, formative assessment should take place multiple times throughout the year, and measures of environmental quality and the quality of adult-child interactions should be incorporated.

FFYF wholly supports the goal of a robust continuum of early learning programs, all demonstrating quality and working on continuous quality improvement, regardless of funding stream. Given the complexity and variation in how services are delivered and programs are structured across the early childhood continuum, we make a handful of recommendations in additional comments about clarifying how the Departments envision QRIS implementation.

The draft criteria rightly highlight the essential role early childhood educators and leaders play in promoting children’s learning and development, and FFYF particularly compliments the draft’s recognition of the full spectrum of partners necessary to developing strong educators. We hope the final application continues to emphasize the role that institutions of higher education need to play in states’ efforts to articulate systemic, integrated reforms and that higher education will be fully incorporated as an essential partner in building state early learning systems.

Our recommendations regarding stronger linkages to K-12 are noted in the “priorities” comments, and we propose an additional approach to the competition found under “award information.”

Finally, for the Early Learning Challenge to achieve its intended impact, the work it launches and inspires must be sustained over time. Sustainability for a quality-based early learning system and services cannot be achieved without ongoing and increased federal investment, including investment in the Child Care and Development Block Grant. There are other critical areas for federal leadership to support this work, integrated across the two departments, such as potentially consolidating federal technical assistance and launching cooperative work to help states develop common reporting terms and measures. We continue to encourage establishing a workgroup of states participating in the Early Learning Challenge, and for the two departments to concretely and practically assist in implementing their plans.

Again, the First Five Years Fund commends the Departments on their vision for the Early Learning Challenge. We thank you for this opportunity to provide input and for your consideration of these recommendations.

The Maryland Association for the Education of Young Children (MDAEYC) is very excited that many years of advocacy work at the state and national level have developed into the Race to the Top - Early Learning Challenge. Clearly the federal government has grown to understand and actively promote the critical role that early childhood education plays in raising a well educated, responsible citizenry. MDAEYC is thankful for the opportunity to comment on, and hopefully improve, the Early Learning Challenge Fund priorities and requirements. We are lucky in Maryland because our state and educational leaders have promoted early childhood education for decades. Along with our partner organizations, we feel confident that Maryland is poised to take full advantage of the Early Learning Challenge. Our hope is that every state can experience the success we do after years of promoting early childhood education. To that end, we offer several suggestions to make the Early Learning Challenge the beginning of a revolution in early childhood education across the nation.
The first of two primary changes we hope to see in the Early Learning Challenge requirements relates to developing workforce knowledge and competencies and to supporting early childhood educators. The primary predictor of children’s academic success in the classroom is the level of training of the teacher. We know from years of experience and mountains of research that the best way to provide high quality education to high-needs children is to put our money and greatest efforts with those in direct service of children and their families. Current requirements would allow, if not encourage states to put most funds toward activities such as creating and improving data collection systems. In order to truly improve early learning programs for high-needs children, there must be money specifically funneled to those are teaching them and working with their families. Taking it a step further, adding language that would create pathways for community based programs to develop high quality pre-kindergarten programs would be a way both to spend money in a cost effective manner and to reach many high-needs children attending those programs through subsidies.
The second piece we would like to see amended regards the required kindergarten assessment. Since 2002, Maryland has implemented the kind of kindergarten assessment system required to receive funds from the Early Learning Challenge. Our system, the Maryland Model for School Readiness (MMSR), an adaptation of Maisel's Work Sampling Survey, was designed in collaboration with all invested parties and it is used to better teaching practices and student learning. Every public Kindergarten child in Maryland is assessed by his or her teacher, trained for that purpose, through observations in 30 areas of development.  These observations are recorded, and summaries are reported to the schools, the local education authorities, and the Maryland State Department of Education, which use them for quantitative assessments of the strengths and weaknesses of Maryland's Kindergarten students overall and in each specific area of development.  
By far the most important use of the assessments is by the teacher, to understand better how to tailor the curriculum and her teaching to meet the educational needs of each student.  Work is underway currently to extend the universal student identification number and the associated observational training to licensed child care programs, so that the benefits of the assessment process can be felt even earlier.  It should be noted that no schools, teachers, or students are penalized as a result of this assessment process. Rather, school authorities target training and other resources to those areas which are most likely to benefit children’s educational outcomes.  Most students are unaware of the observations that are taking place in the normal classroom environment, so they do not develop the test anxiety that has been shown to impede student progress when introduced to young children. Discussions regarding our yearly results revolve around improvements across developmental domains for individual students and early childhood education in general across the state. We strongly urge the Education and Health and Human Services Departments to include language in the Early Learning Challenge requirements that prohibit states from using these assessments in any other manner. Using assessment results for competitive, punitive, or reward measures will only inhibit true high quality education for high-needs children. Instead, it will create stress and pushing for results at all costs rather than for the overall developmental growth of individual children. Please take the lessons we have learned over the years and put them to good use. We use observations of play to learn about children and we plan play so that they learn about the world.
We look forward to helping prepare Maryland to meet the requirements of the Race to the Top - Early Learning Challenge. It is our hope that lessons we have learned inform those requirements so that states are encouraged to create developmentally appropriate, educationally sound programs that last for generations to come.

Sincerely,
Shannon Dungan
Public Policy Chairperson
Maryland Association for Education of Young Children

Thank you for the opportunity to comment on the Obama Administration’s proposed competition criteria for the Race to the Top-Early Learning Challenge (RTT-ELC). The draft executive summary reflects a thoughtful response to the field’s call for the creation of integrated statewide systems for early learning and development.

Jumpstart is a national non-profit organization working toward the day every child in America enters school prepared to succeed. Since 1993, Jumpstart has recruited and trained more than 20,000 college students and community members to serve more than 90,000 preschool children in low-income communities. In 14 states and the District of Columbia, Jumpstart partners with community members, higher education institutions, and various early learning providers to serve children in low-income neighborhoods. During the course of the school year, caring adults deliver a research-driven, results-oriented program that helps cultivate children’s language and literacy skills in preparation for success in kindergarten and beyond.

As a provider of high-quality early learning programming to young children in low-income neighborhoods, Jumpstart supports the focus on children from low-income communities and the different grant award amounts based on a state’s share of the national population of children ages birth to 5 years old from low-income families. In addition, Jumpstart applauds the inclusion of Absolute Priorities to create a common set of standards and tiered Quality Rating and Improvement System (QRIS) to support, measure, drive quality and provide accountability for early learning and development programs.

Jumpstart encourages the U.S. Departments of Education and Health and Human Services to consider the following recommendations and suggested changes:

Recommended Competitive Preference Priority – Encouraging Private Sector Support
The inclusion of the Invitational Priority “Encouraging Private Sector Support” is commendable, though Jumpstart recommends the priority be competitive. As the early childhood education field is represented by programs that are both public and private or some combination, it is vitally important to provide further incentive for states to include all early learning and development providers in the statewide plan.

Recommended Competitive Preference Priority – Innovations for Improving Early Learning and Development Outcomes
Additional points should be awarded to applications that identify and include innovative programming that has demonstrated strong learning and developmental outcomes for young children. The inclusion of this competitive priority would align with other Obama Administration initiatives such as the Investing in Innovation Fund. By highlighting successful programs, including supplemental programs, states would help direct and move the field to invest in innovations that are working in communities.

Selection Criteria B. Promoting Early Learning and Development Outcomes for Children
The draft includes in selection criterion (B)(5) an opportunity for states to describe how families will be engaged and supported. In the definition of program standards, the draft outlines in (d) strategies for family engagement that include social networks and intergenerational activities. This is laudable, and Jumpstart recommends that this criterion also include a description of how community members will be engaged to serve not only families, but young children directly. Community organizations and individuals that best serve young children and their families should be included. This will more closely reflect the various organizations and community members involved in providing high-quality early learning programs and environments for young children.

Selection Criteria C. High-Quality Accountable Programs
The draft selection criteria in (C)(2)(a) outline the types of programs expected to be included in the tiered QRIS. In addition to including incentives for states to include private provider participation, Jumpstart recommends states be required to design tiers in a manner by which non-profit organizations that provide supplemental programming to young children could be evaluated and held accountable. Many supplemental programs have a limited focus and would not be able to map onto all QRIS measured standards; however, having a method by which these programs could map onto a state system with defined and widely-accepted standards would reinforce a baseline of quality.

In addition, Jumpstart recommends that states describe in their applications a way in which direct service programs can access data related to the children they served to better understand their role in producing child outcomes. Access to this data will help all programs better monitor and ultimately improve their performance.

Selection Criteria D. A Great Early Childhood Education Workforce
Jumpstart is pleased that the draft summary pays great attention to the development of the early childhood education workforce. To be a first-class and professionalized workforce, however, Jumpstart recommends that this criterion’s wording change from “great” to “world-class.” In addition, Jumpstart suggests that the final announcement include a requirement that states define methods and the extent to which they will encourage and enlist new educators and leaders in the field. Providing a plan for supporting a pipeline of new educators and leaders is crucial to the future of the field.

Specific wording recommendations include (italics indicate suggested new language):

(D)(2): “The extent to which the State has a High-Quality Plan to improve the effectiveness, recruitment, induction, and retention of Early Childhood Educators…”

(D)(2)(b): “Policies and incentives… that promote entry into the profession, establishment of high quality pre-service induction programs, professional development and career advancement…”

(D)(2)(c)(ii): “Increasing the number and percentage of Early Childhood Educators entering the profession and moving up through the progression of credentials.”

Additionally, to develop a strong and prepared pipeline of early childhood educators and leaders, Jumpstart recommends placing emphasis on field-based, in-classroom learning opportunities. With programs at over 60 colleges and universities, Jumpstart has a long history of partnerships with postsecondary institutions. Providing thousands of college students with applied learning experiences each year, Jumpstart understands the value of training adults in the classroom and engaging them in practical learning opportunities.

The draft executive summary is an excellent next step in what is a monumental moment for early learning and development. Thank you to the staff at the U.S. Departments of Education and Health and Human Services and in the field of early childhood learning and development who have dedicated so many years to young children so that we can be poised to better serve them.

Sincerely,
Kim Davenport
Chief Program Officer
Jumpstart

ASSESS WITH CAUTION: DEVELOPMENTAL OUTCOMES AND ASSESSMENTS FOR YOUNG CHILDREN

The end goal and desired outcome of traditional education is academic success for all children. Goals and desired outcomes for young children, understandably, are quite different from those of older students. As we well know, young children simply cannot sit, control their attention, and perform on demand for anything but the shortest length of time. Measuring academic success in young children with the tools and techniques developed for older children will lead to frustration and inaccurate data results (Flagler 1996, Meisels 2005). To accurately measure outcomes for young children, tools must respect age-appropriate expectations at each stage of early childhood development and also accept assessment techniques and reported results that look quite different from those employed with older students. RTT-ELC and the early childhood community must advocate to stop the current trend of pushing academic expectations into early childhood programs (Goldstein 2007, Katz 2007, Marcon 2002), we must have an array of assessment tools and resources available that clearly incorporate “best practices” and “developmentally appropriate practices.”

Early childhood educators agree with the ultimate goal of traditional education to achieve academic success, however, given the nature of young children, success should be measured quite differently (Meisels 2005). The question is not why measure, but rather, can we do so without negative consequences? For decades research has shown that programs with high-quality learning opportunities have a positive impact on desired developmental outcomes (Bredekamp 1987, LoCasale-Crouch 2007, Zill 2003). With regard to young children, the ultimate goal of assessing developmental outcomes must be to ensure that high-quality learning opportunities are available for all children (Bredekamp 1992, 1995), regardless of the child’s ability, culture, socioeconomic status, risk-factors, and any larger psychometric assessment push or political agenda. The process of assessing cannot in any way negatively impact this goal. To do otherwise would violate the ethical code all educators are encouraged to follow: “Never harm children” (NAEYC, 2004).

Care must be taken to evaluate if an assessment tool or technique has appropriate purpose and benefits, and at the same time does not put the daily high-quality learning opportunities for young children at risk. Skills, child outcomes and behaviors assessed must not be part of any academic, political, or commercial product agenda and must include the developmental age or functional level of children from birth to age five to assure continuity between all programs that may serve a child. Measuring outcomes is important and the direct benefits of collecting developmental assessment data are many.

- Parents can better understand their child’s performance, growth and progress.

-Teachers can use this understanding to plan daily curriculum and intentional learning goals.

-Program directors can monitor specific program quality and effectiveness.

-Specialists can identify possible disabilities or developmental delays, perform developmental screenings, and ensure children receive any needed early interventions.

-Policymakers and academics can document the effects best practices have on desirable outcomes, and monitor the applications of those practices that achieve high-quality learning opportunities for all children and ultimately lead to future academic success.

-Politicians can document effectiveness of public funds spent on programs.

Developmental assessment that is an integral part of an early childhood program has multiple benefits to the individual child, the group of learners, and the adults responsible for the program, at the same time it provides meaningful accountability information to meet larger assessment agendas.

The current focus on measuring academic achievement levels in public education has created unintentional consequences in the educational community and inadvertently affected the basic developmental expectations of early childhood programs (Blaustein 2005, Shepard 1988, National Center for Early Development and Learning 1998). Just as there are many clear benefits to assessing outcomes, there are also inappropriate purposes and multiple risks. Great caution must be taken to ensure that every assessment tool or technique used for young children has appropriate purpose, performance expectations, and does not focus solely on isolated academic “skills” and thus put the daily high-quality learning opportunities for young children at risk. Without such caution, an unintentional vicious psychometric cycle can easily begin.

An example of such a negative cycle might be one in which inappropriate academic performance expectations gather inaccurate data due to a political, commercial, or assessment agenda. Such agendas perpetuate misunderstandings about appropriate expectations and desirable results for young children. Teachers and parents will misunderstand a child’s expected performance, growth and progress. Teachers will then be pressured to employ educational practices based on inappropriate expectations, and to plan daily curriculum to create desirable outcomes for immediate “academic” success. Program directors will be forced to employ expensive quantitative monitoring techniques for specific program accountability and effectiveness. Specialists will be required to employ developmental screening tools that inaccurately identify disability and delay, potentially missing developmental issues and inaccurately identifying “academic” ones. Funding for policymakers and academics will be limited to research aimed at achieving outcomes which are actually inappropriate. Politicians will question the effectiveness of public funds spent on programs, lobby for tighter control through mandates, and perpetuate the cycle further. When assessment techniques and tools do not specifically support high-quality learning opportunities for young children, they will produce inappropriate developmental expectations, misleading data, lead to inaccurate or false conclusions, ultimately violate the ethical code of education and “harm the child.”

Policymakers and politicians need not be at odds with early childhood educators and best practices. If developmental outcomes assessment techniques honor the goal “to ensure high-quality learning opportunities that support a child’s understanding, are available for all children,” accurate results with minimal negative impact can be achieved. Such assessment results will be appropriate and relevant to share with parents, caregivers, educators, academics, politicians and policymakers. These results will be meaningful because they were gathered by adults during authentic interactions in meaningful everyday high-quality early childhood programs that foster understanding and learning in all domains of development. This learning will produce the desired outcomes in early childhood programs and support the ultimate goal of traditional education, “academic success for all children.”

As a practicing neonatologist, it's great to see children's health issues included in the statement. Thanks!

On behalf of the American Association of Christian Schools, I am writing to express grave concern over the proposed requirements in the Race to the Top - Early Learning Challenge. The AACS is a national organization and most of our member schools across the country offer pre-school opportunities for those parents who choose to send their children to school before the kindergarten age. Our schools serve families from all levels of income, and provide quality programs with seamless instruction between grade levels. A key component to the success of these schools is the autonomy which they enjoy because they do not receive public funds. This autonomy gives the schools the freedom to employ the highly qualified teachers that best align with the school’s mission and vision, and to utilize the curricular and teaching methods that will best educate the children under their care. These schools are accountable to the parents of the children, and are therefore strong supporters of the family unit. Without question, quality parenting is the best predictor of a child’s future success and development emotionally, socially, physically, and intellectually. The recognition of parental authority and autonomy of the school are the key components to the success of the education offered at the non-public early learning programs.

We have grave concerns that the proposed requirements for the RTT-ELC fail to recognize the excellent work of existing non-public early education programs, and the vital role and responsibility that parents have for their young children. In so doing, the RTT-ELC will cause the federal government and the state governments to overreach into the private sector and greatly hinder the positive education that is already taking place in the private sector (which is the majority of existing preschools).

The proposed requirements for the RTT-ELC state that in order for states to be eligible they will have to have a plan to bring all early learning programs (including private and non-regulated) under their improvement system and licensing program. Specifically, the requirements explain that a goal of the state should be that all licensed or state-regulated programs will participate in the improvement plan, and that states should have a “licensing and inspection system that covers all programs that are not otherwise regulated by the State and that regularly care for two or more unrelated children for a fee in a provider setting.” This will inevitably bring the private and faith-based early learning centers and preschools under governmental control, even though they do not operate with public funds and already have a strong accountability system in place to ensure the quality of their programs. This increased regulation will only provide unnecessary burdens for these schools and programs, and will undoubtedly hinder the great work that they are already doing with young children and for their families. In addition, the assessment requirements stated in the proposal again will require states to assess programs that are not funded by either the state or federal government, again causing increased and unnecessary governmental regulation for the non-public early learning centers.

This proposal will inevitably lead to greater regulation, more federal control, and ballooning costs to states, communities, and the federal government. Rather than increasing educational opportunities for young children and their families, this government program will only decrease the educational choices that parents will have for their children by hindering the excellent early educational programs already offered by private and faith-based centers and schools.

In order to ensure that the existing privately-run and faith-based programs remain successful and able to operate, we strongly recommend that these proposed requirements undergo extreme revision to ensure that they do not require states to infringe on the freedoms that are allowing excellent education to take place across the country in the privately-run and faith-based centers. A program designed to better the education in America should not do so at the sacrifice of the existing, successful educational programs in our nation.

The National Congress of American Indians (NCAI) is the oldest and largest American Indian organization in the United States. As the most representative national Indian organization, we serve the broad interests of tribal governments across the nation. NCAI was founded in 1944 in response to termination and assimilation policies. Since then, we have fought to preserve the treaty rights and sovereign status of Indian tribes and to ensure that Indian people may fully participate in the political system.

NCAI is encouraged by the opportunity provided by the Department of Education (DoED) to respond to the Race to the Top – Early Learning Challenge (RTT-ELC) draft selection criteria and priorities. The recommendations detailed in this letter are particularly important because Indian children, and the school systems that serve them, have been largely ignored in the previous iterations of the RTT grants. States that have Indian lands within their geographic boundaries have not been required, or encouraged, to collaborate with tribes to reach our children. The Bureau of Indian Education, which is responsible for educating some of the nation’s most needy students, has been completely excluded from the application process. We are pleased to see that the DoED is taking steps to correct this by including tribal children, parents, citizens, and governments in the definition of “High Need Children” and “Early Learning Intermediary Organizations.”

Currently, there are nearly 200 tribal head start programs in 27 different states funded by more than 150 grants serving less than 20 percent of eligible American Indian and Alaska Native children. These Indian head start and child care programs, and tribal education departments, have decades of experience providing educational opportunities for American Indian and Alaska Native children. Furthermore, 93 percent of American Indian and Alaska Native students attend state public schools; of these students, many likely begin elementary school with fewer opportunities to attain the appropriate level of readiness due to economic and geographic barriers. Moving forward with the recommendations listed below will help provide greater access, build successful education foundations, and foster a better educated tribal workforce and citizenry – contributing to the overall welfare of states.

NCAI recommends the following changes to the RTT-ELC Program Application:

1) Tribes within states should be considered stakeholders in the development and implementation of RTT-ELC.
DoED includes Indian children living on “Indian Lands” (as defined by Section 8013 (6) of the Elementary and Secondary Act, of 1965) in its definition of “High-Need Children.” In order to properly meet Absolute Priority 2 of the suggested application
priorities, DoED should require states to consult with federal recognized tribes within their geographic boundaries. States must include tribal leaders and our early education experts in the development and implementation of tiered quality rating and improvement systems to ensure the learning needs of American Indian and Alaska Native students are properly addressed to achieve school readiness.

2) Require states to submit letters of support from federally recognized tribes within their geographic boundaries with RTT-ELC applications.
The requirement that “Early Learning and Development Standards” “must be developmentally, linguistically, and culturally appropriate” suggests that local tribal support and involvement is imperative to certify that a states’ plan is culturally sensitive for tribal citizens within their early education system. Support from tribes will also demonstrate that tribal leaders, tribal child care and head start programs, and tribal education departments understand their role in implementing the state’s plan under the challenge – effectively assuring that each state is successful in meeting the needs for one category of “High-Need Children.”

3) Give preference to states with “Indian Lands” that submit a plan to consult with tribes as part of any “High-Quality Plan.”
Those states that will develop plans to meet selection criteria under the challenge have an opportunity to build systems that account for all the gaps that currently exist in early education systems. If states with “Indian Lands” consult with tribes in the adoption or implementation of a “High-Quality Plan” its progress holds significant promise to effectively address the needs of American Indian and Alaska Native children. Giving them preference would assure the most successful, comprehensive plans are implemented. Conversely, states that do not consult with tribes within their geographic boundaries, or include them as stakeholders within their plans, should not be eligible for funding.

4) Give preference to states who submit plans to partner with Tribal Colleges and Universities to develop effective Early Childhood Educators.
States that plan to partner with Tribal Colleges and Universities (TCUs) should be given preference when reviewing RTT-ELC applications because many tribal citizens and other reservation residents choose to attend these local, affordable institutions of higher education. Supporting students that attend TCUs would result in a stronger, more culturally aware workforce in state early education systems.
NCAI looks forward to working in partnership with DoED in the future. Should you have any questions, please contact Ahniwake Rose at arose@ncai.org or (202) 466-7767.

Sincerely,

Jefferson Keel
President

The Connecticut Early Childhood Education Cabinet (CT's ECAC)asks that the following be considered:

Please clarify how non-center based activities, such as home visitation and IDEA part C services, fit in with tiered rating systems (competitive QRIS).

Please consider scoring ALL priorities including those that are invitational. This would allow states to receive credit for innovations beyond those that apply to absolute and competitive priorities. These invitational priorities encourage states to “think outside of the box” in order to implement effective policies and services for High-Need Children.

We are pleased that engaging and supporting families is included in the selection criteria. Please consider adding language regarding family-school partnerships. These rich, deep family-school partnerships are key to effective early learning systems. Additionally, we suggest explicit mention of family literacy and intergenerational programs that support families with young children.

I would like to submit comments on the Race to the Top grant that will benefit early education and give power and influence to the parents where it belongs. Many grants offered have often left the most important element of parent input out of the picture. If we are racing to the top, we need to hear from the child's first and most important educator. We are also seeing more kids being raised and influenced by other family, friends and neighbors. We need to hear and respect their wisdom. One of the more important factors of children learning well is their readiness emotionally and socially for any type of school experience. The five protective factors that form the basis for the Strengthening Families framework are the best for building up families for success. If we want to compete on a global level, we need to even the playing field for ALL children and provide the needed support and encouragement for families. We can do this by ensuring that grants such as these highly consider the role of parents and other family members play in supporting programs for they and their children. Look at what has been successful and continue to fund those opportunities; look for innovation and grass root efforts by smaller organizations that show promise and make sure that the protective factors are the backbone of all that is submitted and funded.Thanks for the opportunity to comment.

On behalf of the National Association of Child Care Resource and Referral Agencies (NACCRRA), I am writing to express strong support for the Race to the Top – Early Learning Challenge (RTT-ELC) grant proposed requirements. We commend the Administration’s commitment to early learning through a vision that integrates a cross-departmental, cross-program, whole-child approach. In brief, without such an integrated approach, there is no early learning system. We strongly support the emphasis on increasing the number of high need children in high quality programs. Currently, far too many of these children are in low quality, unlicensed child care settings that do little to promote school readiness.

Child Care Licensing and Quality:
Giving a competitive preference priority to states that show a commitment through licensing and inspections will send strong and appropriate messages to states to include all children cared for in non-relative, out-of-home settings in their early learning systems. Child care plays a critical role in the health, safety, and development of children but in too many states, child care is set apart from early learning initiatives because it is viewed as too hard to tackle. NACCRRA applauds you for including full-day/year-round child care programs (both center-based and family child care) and for recognizing that child care is an early learning setting and should be a part of state early learning systems.

Yesterday, the Bureau of Labor Statistics released the most recent unemployment data showing a rise in unemployment to 9.2 percent. It is clear that the weak economy continues to present challenges to states and the federal government as policymakers look to reduce budget deficits. It is critical that states make a commitment to preserve current investments in early learning as part of their RTT-ELC applications. We recommend the Administration to consider priority consideration, extra priority points, or disallow grant applications unless states commit to:

• Maintaining current investments in core licensing and monitoring functions
• Ensuring that RTT-ELC funds are used to supplement, not supplant ALL current state early learning investments
• Maintaining current income eligibility for families who need child care assistance
• Maintaining provider reimbursement rates for licensed care.

Parent Engagement:
We wholeheartedly support the Administration’s focus on engaging and supporting families as a selection criterion. Studies have shown that parent involvement is crucial in the development of children and that parent-provider communication is linked to the quality of care provided. Nothing is more important to a child’s progress than parents who are engaged and knowledgeable about their child’s needs in order to support their early learning and development. We also support your recognition that parents, as consumers, need information and support so that they are partners in any state school readiness initiative. Asking states to communicate program ratings to parents will help them make informed decisions. We recommend that you go further by asking states to describe in their plan HOW parents will be educated about quality ratings and what high quality programs look like.

Health and Safety Linkages:
One of the strengths of the Head Start Program is the comprehensive manner in which the health, behavioral, and developmental needs of high-need children are identified and addressed. The lessons of Head Start need to be applied to all early learning programs and we strongly support the inclusion of health and behavioral screenings in the RTT-ELC State plans. Early intervention can prevent school failure, reduce the need for special education services, and boost a child’s confidence (that in itself is a marker for future achievement). The promotion of children’s social, emotional, physical, and cognitive development is crucial to a child’s future and early childhood educators must be trained to support and help meet these needs. In addition, we applaud the promotion of healthy eating habits, expanded physical activity, and improved nutrition. For that reason, we recommend that the State representative for the Child and Adult Care Food Program be included in the list of required Participating State Agencies.

Child Assessment:
While there have been many comments posted about the Administration’s call for assessments, we share your goal that child assessments be used to inform efforts to close the school readiness gap at kindergarten entry and informing instruction and services. We strongly recommend that States be given extra points for using kindergarten entry assessment to support early learning programs in neighborhoods where children are coming to kindergarten unprepared. This model has been highly effective in the State of Maryland.

In summary, we greatly appreciate the work of the administration on this proposal. We appreciate the inclusion of child care programs and the recognition that child care is an early learning setting. We strongly believe the Administration’s proposal will help strengthen early learning programs for millions of young children. It is time that we not just recognize that early learning settings set the stage for school readiness but that we implement early learning systems to achieve this goal.

Linda K. Smith
Executive Director
National Association of Child Care
Resource and Referral Agencies (NACCRRA)

Improving the learning opportunities for young children is certainly a valuable endeavor worthy of national attention. Assessment of children’s overall development is one important component of any improvement effort. However, if it is not done well, the consequences are likely to be more harmful than helpful. The history of No Child Left Behind and of high-stakes testing in general bears this out, as concluded by the National Research Council in its recent report, “Incentives and Test-Based Accountability in Education.” An over-emphasis on testing, using narrowly constructed tests controlled through state-centralized examination systems, and attaching punitive sanctions to them, have combined to create many damaging consequences. These include narrowing the curriculum, teaching to the test in the measured subjects, pushing children out of school, retaining students in grade even though retention has repeatedly been shown to be educationally counterproductive, and increasing both student and teacher alienation.

The critical questions, then, are whether the results will be beneficial or harmful once implemented by states and districts; and whether the proposed guidelines will effectively prohibit misguided and harmful uses of tests and assessments while promoting the beneficial uses of high-quality assessment.

Based on the consequences of NLCB and related state programs, and evidence of a shift from developmentally appropriate schooling to test-focused instruction for young children, this program is all too likely to result in an expansion of narrowly construed “assessments” (really, standardized tests) causing a narrowing of learning opportunities and distorting curriculum and instruction in order to boost test scores.

I note that some commenters to these “requirements” have issued warnings that appropriate programs are already greatly at risk due to the current overemphasis on testing. The Department must heed these warnings. I concur also with the NAEYC’s cautions against the misuse of tests.

The Department, then, must take unambiguous steps to ensure that states do not reduce assessment to paper and pencil or other narrowly constructed tests, likely with an overemphasis on formal academics linked to the new national reading and math standards. Doing so will significantly damage early childhood programs and the children they serve.

The language generally found in these “requirements,” using phrases like “high quality” or referring to “developmentally, linguistically, and culturally appropriate” standards, is not sufficient to ensure that state programs really are those things.
States that do not make completely clear that they will implement truly comprehensive assessments (rather than limited tests), to be conducted in developmentally appropriate ways by teachers, should not receive awards - and this point should be clearly stated in the application information.

States should be barred from using any of this RTTT-funded child assessment information for high-stakes accountability purposes for children, program staff, or programs except as a minor and not numerically fixed component of a comprehensive evaluation of a program. The appropriate use is for program improvement, including better serving the children and guiding professional development. This will be particularly relevant when programs are evaluated, as I will discuss later.

Some states have moved toward developmentally appropriate, comprehensive assessments. Secretary Duncan has praised Maryland’s assessment, for example. That assessment is an adaptation of the appropriately well-regarded Work Sampling System (WSS). It would be a positive step if states used WSS or a reasonable adaptation, provided proper professional development to ensure it is used well, and did not attach high stakes to it or any component of it.

The WSS and comparable assessments are not one-time tests. Rather, they are sophisticated means for gathering a variety of kinds of evidence over time across relevant domains of learning and development. Such assessments can provide rich information for teachers to better work with children and for a program, school or system to improve itself.

States unwilling or unable to establish assessments of at least as high quality as the WSS should not be granted funds under this RTTT program. Independent panels should evaluate available assessments to determine that they are comprehensive, balanced, and developmentally appropriate. This could be done early to enable states to select from (and modify if appropriate) such assessments. If a state chooses to design its own, or to allow programs or localities to design or adopt/adapt their own, then such assessments also must pass through a careful review. States should not be allowed to use commercial or self-made assessments that fail to meet the criterion of comparability with WSS. While this will take resources and could slow the process, it is far better to do so than to allow inadequate, flawed, inaccurate or downright bad assessments to corrupt programs, misinform policymakers and the program, and likely damage children.

Without a strong policy from the Department, followed by adequate monitoring, it is all too likely that some states will choose to use one of many completely flawed ‘readiness’ tests that are commercially available. Dr. Samuel Meisels has critiqued such tests as inaccurate and often developmentally inappropriate. (He did so before he created the WSS, which is now owned by Pearson.) Other standardized instruments, especially one-time tests, are similarly flawed and should not be allowed.

I will further elaborate on these points in response to other components, and address additional issues.

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

Well-stated, Monty. States must be careful to use commercial or self-made assessments that fail to meet the criterion of comparability with WSS. An over-emphasis on testing has already caused students to lose time in class that could be used for additional learning experiences. Valuable field trips (the one aspect of the 13 years in school that students always remember) have been lost because of slashed budgets, as the states have reduced state aid to schools in order to pay for the expensive assessments. The elephant in the room is how much damage has been done to school climates and those who work in the classrooms, reducing time to develop colleagial conversations (thank you, Margaret Wheatley) and inducing fear. The trickle-down effect on the students must be harmful, to say the least. And why is it that the assessments are driving the curriculum, rather than the other way around, as acknowledged by PARCC only a few days ago at their meeting: http://www.parcconline.org/sites/parcc/files/PARCCGoverningBoardMeetingF...

The RTT-ELC is a strong positive step in the right direction in providing policy, support, and leadership for improving the achievement levels of children across the nation. Being researched based, early learning has served as a strong indicator of achievement success throughout the primary and secondary years. The RTT-ELC program and policy provide opportunity for a large sector of the population to gain fundamental learning skill, social skills, and a healthy attitude and perspective toward education that is commonly found in middle and upper income communities.

Learn By Doing. We remember 90% of what we DO as compared to 10% of what we read.
A school site can give the curriculum a place be experienced. Except for physical sciences, schools lack physical experience with the subject matter. Our school sites are distilled environments that are stripped of all personallity of their surrounding community. I can't figure out if the chainlink fences are to keep kids in or out. Children on the whole cannot explore the outside environments any more without being accosted by neighbors, store owners and police. Exploring their community is large part of their social development.

What if a school was a park for learning enriched with nature for exploration and understanding? Dangerous you say? How about fully educated, I say. We have all the tools and research we need for educating people now we just need to change the mindset of what a complete school is. How about the Childrens Outdoor Bill of Rights? Why can't a school provide the experiences? Most of whom I speak with say, NO because of maintenance costs. My reply, education comes first the children are here to LEARN

United Way Worldwide (UWW) and the UCLA Center for Healthier Children, Families and Communities supports the Administration’s rigorous criteria for the Race to the Top – Early Learning Challenge (RTT-ELC) competition and we appreciate the opportunity to provide public comment on the proposed competition criteria.

Strong Framework for Success: We support the overall framework the Administration is advancing for this initiative, recognizing that states and local communities must address several inter-related elements to advance the learning of their most at-risk children. To that end, we commend you for asking states to work on standards and assessments; quality rating and improvement systems (QRIS); professional development and preparation; and systems alignment. These objectives are critical to the development of high quality early learning and development programs. We know the Administration recognizes the additional importance of focusing on early childhood outcomes, and in case this is not already planned for the final guidance:

We recommend the inclusion of an explicit overarching goal to improve school readiness, beginning at birth, to ensure the longer term developmental and academic achievement of children (e.g., 3rd and 4th grade literacy, numeracy and other developmental skills).

Approach to Assessment: We write specifically on assessment and how it is addressed in the proposal. The proposal calls for the introduction of kindergarten entry assessments as well as the introduction of a Comprehensive Assessment System.

1. We recommend the word “entry” be deleted throughout the guidance as relates to kindergarten assessment.
If the Absolute Priority 1 requirement for kindergarten “entry” assessments is to be interpreted literally, this is too restrictive, and will limit the ability of states and schools to use tools that allow young children several months of acclimation to kindergarten to ensure the assessment is a valid reflection of readiness to learn (rather than adjustment to a new environment). There is a large body of research showing that particularly in communities where many children have not attended Early Learning and Development Programs, measures of school readiness have much greater validity (i.e. would identify developmental challenges that are persistent and more predictive of future academic success) when used several months into the school year, rather than at entry.

2. We urge you to specify that a population-based kindergarten assessment approach is encouraged or at least permitted.
While this may be implicit in your proposal we believe that it should be made explicit in the final guidance. Population-based assessments have the potential to reflect the cumulative effects of a broad array of social and environmental factors that influence school readiness. Additionally, these assessments effectively demonstrate shifts in the developmental status of entire populations of young children.

In order to establish a population measurement for school readiness, an assessment tool must meet several key criteria, including that it be holistic, logistically feasible to implement at the population level, valid and reliable and supported through tools and technical assistance to ensure quality measurement and effective use of the data.

Few tools have been created specifically for this purpose. One tool that does is the Early Development Instrument (EDI), a valid and reliable population-based measure of school readiness that includes the Essential Domains of School Readiness. The EDI is currently being implemented in 38 school districts in 18 communities across 10 states with an additional 14 sites planned for next school year. Rich community level data, such as that provided by the EDI, can inform decisions about resource expenditures, guide the way schools plan for early elementary programs, and how child-serving organizations and whole communities approach early childhood system improvement.

The EDI is easy to administer (15 minutes per child), and is a cost effective and efficient way for states, school districts, communities and neighborhoods to identify the percentage of kindergarten students vulnerable (<10%ile) or very ready (>75%ile) on each domain of development. EDI data are geo-mapped and can be reported alongside other population level data that influence child learning and development, such as poverty, residential mobility, birth data, child care enrollment, other health and human services resources, and child welfare reports in order to establish a comprehensive understanding of the factors driving observed outcomes for children. Data collected with the EDI can be linked to state longitudinal data systems.

3. We urge you to include kindergarten in the Comprehensive Assessment System.
We recommend that the focus of the Comprehensive Assessment System be expanded beyond early learning and development programs to include kindergarten classrooms, i.e. including formative assessment, accompanied by necessary screening, teacher-child interaction and quality environments as part of this work.

The RTT-ELC competition provides a catalyst for states and local communities to work together in developing and implementing innovative strategies and approaches that address the long-term health and developmental needs of young children. Again, we thank you for putting together a strong framework and a rigorous competition.

It would be an honor as a parent to partner with
Race to the Top- Early Learning Challenge Grant
It is exciting times to see our nation shift to and apply support to our children in their most optimal years of brain development. Research continues to support that Zero to Three is what makes me and Three to Five is what keeps me Alive! As a parent of three children 5, 3, and 1 I see this power come alive in my everyday life. One of the world changing choices I made as a parent was to receive Protective Factors training. It has helped me to have courage (resiliency) and stay on the flight plan even with turbulence; it has allowed me to learn my educational freedoms in child/parent development based on my values and customs; it has relieved me as a parent that it will take more than myself to provide healthy assets/connections for our family; it has placed organization into the supports we need for our health and well being (concrete support in times of need); and ultimately it has created a home that supports social and emotional growth for my children in all the new environments they will learn in that we discuss at home.
The Strengthening Families approach is an evidenced based system to support professionals in their own families and the families they work with. It provides strategies for families and parents to better assess quality care and empowers them to support their child’s learning in both academic and social/emotional growth. It allows systems to facilitate screening and referrals for health, mental health, disability and FAMILY SUPPORT. Strengthening Families looks at parents as leaders and is willing to drop the fear and build the trust needed to facilitate conversations about decisions for their children, facilities, and services. The accountability of the professionals increases as they learn to articulate, apply, and support the family as a whole. How programs interact with families has a huge impact on what influence Race to the Top will have on our nation. I would love to see Strengthening Families and the Protective Factors influence Race to the Top and would encourage the common language to continue and bridge the gaps between our programs for teens, higher education teachers, and public schools. This allows for common language and goals for our communities and their well being. Parents are their children’s first teachers…yes we have all heard that! Let’s keep in mind they are their FOREVER TEACHERS. If Protective Factors became a birth right to all Americans it would help influencers of children, professionals, practitioners, families, current parents and next generation families! In order for quality programs to help parents make informed decisions about care for their children they must have strength based training in how to partner with parents.
What parent engagement, involvement, parent leadership, and/or partnership looks like today needs to shift from what has been offered to past generations. With today’s current economic status, divorce rates, teen parent rates, work out of home, and grandparents raising our kids we have to shift from a top down approach to partnerships with parents to a more grassroots approach to supporting parents with the Protective Factors and a evidence based Strengthening Families Approach to making this shift. With a growing number of child care provider turnover rates reaching over 48% the best effort is to trust in our families and make the shift to including parents into the conversations. I know it can be discouraging when programs offer several parent nights that have two parents attend but this is a reflection of a program that does not have Strengthening Families and Protective Factor building with their families. We have to shift from this top down approach to supporting families, break down the fears, build trust and partner with families. I know that in this fast paced life that I live with three kids under five, working, personal life, family/friend connection building that in order for me to partner with the different locations that my children learn the communication will have to shift from the more transitional forms to ideas like a Community Café’, different social media, go-to-meetings, meet-ups, webinars, texting or events that support my family as a whole (provide child care, stipends, loss of wages to attend, parent partnership training, transportation, computer access). The circles we move in influence the circles others move in. It would be an honor to partner with Race to the Top as a parent to continue to support the optimal brain development of young children but also support the research that parents are influential leaders in their children’s life. Small shifts making big differences for families! Thank you for allowing me to share my story.

Well stated parent perspectives for this generation of families. Joining a parent group or infant massage class to build relationships to support family development should be as easy as putting your baby in a stroller and walking to the neighborhood library or park.

Well said, with excellent parent and family perspectives noted. I support federal support to state programs that are responsive to local community services directly supporting parenting as it begins prenatally. I see first hand how parent to parent connections fostered through local parent centers with responsive programs and local parent formed groups like meet-up and MOPS provide much needed support for this generation of families. Joining an infant massage or newborn care class for fun is a grand incentive for parent participation in learning to understand their new baby and begin to build their relationship. Reliable and easily accessible parent resource centers throughout communities connecting parents prenatally to parenting knowledge, skills and support would provide stability at the very beginning of family life. It should be as easy as putting your baby in a stroller and walking to the neighborhood library. Early childhood professionals with relationship based knowledge, skills and experience provide parents with comfortable and engaging partnerships.

Comments from Samuel J. Meisels, President, Erikson Institute.

I am pleased to present comments and recommendations for the draft RTT-ELC criteria. I will restrict my comments to issues concerning assessment. (Please note that my remarks are personal and do not reflect the opinions or policies of Erikson Institute.)

The draft criteria deal with assessment in two principal ways. First, in terms of a “Comprehensive Assessment System” and second, with regard to a “Kindergarten Entry Measure.”

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. The first two elements of the CAS, screening and formative assessment, relate to how children are developing and what they are learning. The other two elements listed in the definition are environmental and adult-child interaction measures. These concern program evaluation and, although they relate to child development, they are not the same as child development.

For the sake of clarity I recommend that screening and formative assessment be retained in the CAS (though I would rename this “Child Assessment Measures”) and the environmental and dyadic assessments be included as part of the QRIS and be called “Classroom Evaluation Measures.”

In addition, I recommend that it be made clear that these measures apply to all children aged 0 - 5. The criteria are silent about this at present. Further, the measures must apply to all children. On p. 13 of the draft criteria – section (B)(4)(i) – the document says “Screen all High-Need Children using screening measures” . . . that conform to EPSDT guidelines. However, in order to know which children are “High-Need” it is essential to first perform a universal screening, lest children who are “High-Need” be overlooked.

Section (B)(2) describes the professional development required by staff in order to implement the CAS. These steps are essential for both Child Assessment and Classroom Evaluation measures. They also are a key component of the Kindergarten Entry Measure. Without adequate and ongoing professional development the potential of these measures will not be realized.

There is significant potential for confusion and misunderstanding regarding the Kindergarten Entry Measure (KEM). Given the accountability culture engendered by NCLB, it is likely that many states will be tempted to rely on the high-stakes testing model used with older children, although the goal of the KEM differs from the accountability goals of NCLB.

The purpose of the KEM—to “inform instruction”—is stated clearly in Priority 1 and section (B)(3). However, no definition of KEM is offered in the document. I recommend the following:

Definition: A Kindergarten Entry Measure is a criterion-referenced assessment that is based on a teacher observing, recording, and evaluating child performance in a natural classroom environment in relationship to standards.

Criterion-referenced assessments tell us about the proportion of a specific domain or subject area that a child has mastered. Unlike norm-referenced tests that are used almost exclusively to rank children numerically and compare them to a set of external standards, criterion-referenced data are uniquely valuable for making instructional decisions. These performance-based assessments focus on children’s actual work and achievements, rather than their responses to formalized, decontextualized test items. They consist of actual examples of classroom-based activities, rather than highly inferential estimates of learning. Such an approach to assessment has the potential to enhance learning and improve teaching.

Section (B)(3) provides direction for the states about such a measure. However, some criteria are missing or are insufficiently highlighted. In addition to the draft criteria already provided, I recommend the following:

1. State explicitly that precautions must be taken to prohibit the use of KEM data for high-stakes purposes.
2. Clarify that teachers will be expected to serve as assessors and states must provide ongoing professional development for teachers.
3. Note that the assessment process adopted for KEM should support transition between Kindergarten and the early elementary grades.

I want to emphasize that it is extremely important that the criteria for KEM be very clear concerning accountability and high-stakes. The reauthorization of Head Start in the 110th Congress made it unlawful for the Federal government to promulgate any rules that call for high-stakes testing in Head Start. Specifically, a Special Rule was included in the reauthorization that states:

The use of assessment items and data on any assessment authorized under this subchapter by an agent or agents of the Federal Government to provide rewards or sanctions for individual children or teachers is prohibited.

Further, the clause says:

The Secretary shall not use the results of a single assessment as the sole or primary method for assessing program effectiveness or making grantee funding determinations at the national, regional, or local level.

In short, the purpose of the KEM—instructional improvement—is appropriate, but high-stakes is not. This applies both to decisions regarding individual children and judgments about program effectiveness.

The other points noted above are self-explanatory. States that have used performance assessment as part of their kindergarten entry procedure—e.g., MD, PA, MN, SC—have shown excellent results and increased school readiness of their children by instituting professional development and training teachers to use the data obtained from these types of assessments. In addition, by aligning KEM to Grade 1 standards, the probability is increased that these data will be widely used, thus justifying the ex;pense and effort involved in implementing this assessment.

One final issue concerning performance measures (see (A)(1)) should be mentioned. The draft criteria note that states are to establish “baseline numbers, annual targets, and final goals” for improving performance of “High-Need” children on the KEM. However, before such targets can be set, definitions of “High-Need” must be formulated and baselines determined. In other words, for realistic performance goals to be set, states will need to engage in a two-stage procedure of obtaining baseline data and then creating short- and long-term goals based on these data.

Thank you for thoughtfully, completely and concisely addressing some of my concerns as I read the document. We much embrace with opportunity with best practice as understood in the field of child development and early education.

Illinois Action for Children supports the direction of the draft RTT-ELC for improving and aligning systems to achieve better learning outcomes for High Need Children. However, we believe that the requirements could be strengthened in two areas so that the highest need children and families become a planning priority. First, we are concerned that there is no incentive for states to serve very-high-need children and families that, because of poverty, are not now participating in, and have difficulty accessing, any early childhood program. We propose the following additions: (1) On page 9 under Performance Measures, add a new second dot point “Increasing the number and percentage of Very-High-Need Children (a subset of High-Need Children) participating in quality Early Learning and Development Programs. (2) Define Very-High-Need Children as children with family incomes below the poverty line.
Our second area of concern is that the goal of Priority 3, to include all programs in the QRIS system, will be undermined by the requirement to extend licensing and inspection to most non-relative Friend and Neighbor child care providers. These are often the only providers available to families working low-wage jobs with changing shifts or unusual schedules. In Illinois, for example, 67% of low-income single working mothers have non-traditional work schedules. In our experience, a licensing and inspection requirement would drive many small, informal home-based providers underground, whereas an incentive-based QRIS system draws them into quality improvement activities. We recommend re-framing paragraphs (a) and (b) under Priority 3 to require a coordinated system of licensing and QRIS tiers, supported by a coordinated program of monitoring and inspection. Each state could explain how its particular system advances Priority 3.

While this comment will seem anti agreement, it is meant to be a rationale and way to improve what is here for its solid success.

As usual, the initiatives are great for the sound-byte stage, but are light on their beneficial, functional implementation. While we are again going in a progressive, bold fashion, the supports necessary for much to improve on a sustainable level are not there, without improving the method of financing for public education, including early education and child-rearing programs, as well as the supporting services agencies that a child's life and family functional.

People should be cautious of the entire movement going on at the Federal and State levels to make education run as businesses, to make them all employment-at-will agencies, and to denigrate those professionals who really have made a difference in education. It's not that schools should not run more like businesses; it's the fact that the mechanisms behind many of these changes are in fact the same large mechanisms that have brought public education to such a crossroads. Should we have public education? If the answer is, yes, then we should all wake up and LOOK at the companies providing the "research-based" materials, and testing for schools. It's mostly garbage, and has been for years! Old academia saying--publish or perish. Why? Money is the way the world revolves.

How many times do we need to purchase new textbook materials at the taxpayers' expense just because it's the way state funding formulas work? Now that the big publishing companies have finally put a bit of money into the technology revolution, that has been here for at least the last 25 years, we see that laws are changing to change textbook purchases to include software, and more technology is coming into schools, with donations from some of the same big players just so they hang onto their monopolistic grip to the minds of our future. It's always the same tune--our program is great, and you need to change because IT will get students to higher academic achievement levels. STOP!! Think for just a moment. If that was all true, then how do we continue to see such declines in the position of the US on a world-wide scale? It's because those same UNION and non-UNION teachers were told to use this or that program because it's going to do wonders! Well now, wasn't that an academic bunch of you know what! It's not the teachers!!! It's the system, and until we improve the system, we will spend more and get less.

Real improvement comes from the uniting of grass-root efforts that demand system changes with the connectors in the middle who can put a squeeze on those at the top to bring about a revolution...not from the top down. Anyone at the grassroots level knows that the problems we are really in come from the continued oppression of those who have to those who have less. So, what to do...

1. Create a system of checks and balances that assure children come to school ready to learn. This means we have to tackle some tough questions about how we implement the entitlements with integrity to getting the results we expect. We can no longer pay out and expect less in return. That is why this Federal piece is so good, we are going to spend less on the 14-21 year old population (which led to an ever-expanding, never ending system) and put some of it into the very young. Again, where it is not good; is that it is not a comprehensive system that also incorporates Departments of Social Services, and Mental Health. It needs teeth to hold adults accountable for their social responsibilities in raising the best children possible.

2. Put the whole gamut of daycare and pre-school into public education as they already have many of the resources needed to do the job, including trained staff, staff development, and better pay. When Daycare costs more than educating a child, pays its staff less than professional teachers, and has students come out of its centers ill-prepared to socialize with others, something is out of whack!

3. Continue to get government out of being employment agencies. Let private enterprise evolve by supporting more mental health facilities (hopefully attached to current hospitals, or healthcare agencies), and connecting some of these units directly to school enterprises. You can have the best program in the world for educating a child, but if they just can't be taught because of the overwhelming problems some have in their heads, in their families, or in their environment, then we are not going to get any better results!

4. Create a system of incentives such that we no longer hold students back to "wait" for their bodies to catch-up with their brains. Allow students to move as quickly or as slowly as needed (demonstrated progress), and create opportunities for entrepreneurial talent to move into incubators where new creations can take hold and re-grow our manufacturing and technological infrastructure. This means continue STEM for teaching professionals so they can go back and forth from business to education, such that we are not in this textbook teaching mess, with so many teachers not able to DO what is necessary out in the "real world", so we have innovation within schools again, and where companies are thriving and chomping at the bit to take kids out of schools before they are "done" with formal education.

5. Continue to encourage public and private partnerships because that will automatically place strong demand on performance systems that yield results. Monitor and grow relationships to PUBLIC education so our country does not become just like some others where only those who can (innately superior) move on to higher prosperity, while others fester and cause a huge headache for society.

6. Make education as high a priority as national defense, so we can envision a world with armor and technical prowess that is not necessarily physical in nature, but just as wonderful, or lethal depending on our need and circumstances. Remember when schools were the place to be for cutting edge materials you couldn't get at home? Think about the turn-around now? Still feel that way about schools? Schools need the support to be that place again, where they can't get what they can at home.

As if all this was not enough...it can and should be done for less than what we currently spend if we reallocate HOW we do what we do, and empower those in the professions to be the HUMANS they are, and not just textbook helpers some have become.

If anyone doubts what is stated, just think about this...we had great intentions and need to go into IRAQ, and we achieved our main mission, but we got a lot more than we bargained for in the process, where we now had to rebuild a country. If we do the same with education, one thing is for certain...those who can will have more, and those who can't will have less. Trouble is...once we break the threshold of balance, the only sure return is through extreme violence because those who can't, won't have anything else to use.

The Race to the Top-Early Learning Challenge will provide needed support to a very important segment of the educational system. As an Early Childhood professional I have witnessed the importance of a strong foundation in learning for both parents and children. I have worked with young children and their families for many years. My focus has been to empower parents to be their child’s first and best teacher and strongest advocate. As the parent of four children ,one with special needs, I have experienced firsthand the importance of being an advocate for my children and a partner with my children’s teachers. Empowering parents with knowledge, information, and support helps them to create a strong foundation for their family which ensures continued growth. Support and funding from grants such as RTT-
ELC will allow community agencies and early childhood programs to continue this type of work.
In Massachusetts our state has adopted the Strengthening Families approach developed by the CSSP to frame many of their programs. This approach embraces the notion that parents are leaders not only in their family but within their communities. I work for a program funded by a state grant which uses this approach. We work in twenty six communities that have very diverse needs. By utilizing the Strengthening Families Approach we are able to develop unique programs tailored for the needs of individual communities. We start by partnering with community agencies that families view as safe and family friendly spaces, such as the local library, and develop programs where parents can create social connections. It is often within these social situations that parents begin to develop supportive friendships that transfer outside the organized programs. Although information pertaining to developmentally appropriate activities and behavioral strategies are provided within the context of these programs parents are able to learn from each other which is very powerful. In addition our agency has knowledge of a variety of support services in the various communities thus serve as a resource when families require concrete support ranging from referral to housing services to the provision of gifts and food for their family during the holiday season. The community agencies that we have built relationships with in turn refer parents to our agency when they see a need. Grants such as RTT-ELC can help provide the needed resources to continue to build these community connections.
As the economy has changed, so have the needs of families of young children. Many families are unable to afford the cost of preschool or day care due to their financial status. Our programs are universal meaning they are open to everyone in the community. This allows informal caregivers such as grandparents and babysitters access to these program and the services provided. Parents who do not meet the income guidelines for HeadStart or other programs with income requirements utilize the programs we provide as a way to ensure their children have access to activities that will enhance their child’s development. One of the key components of our program is an emphasis on the parent as their child’s first and best teacher, this is reinforced by the provision of activities and book lists which encourage the parents to extend the learning at home. Grant such as RTT-ELC can provide the support needed to strengthen these community based programs.
Provides of Early Education and Care play a key role in supporting families. They are often an entry point into the educational system. Early Childhood programs serve as the gateway to the overall educational system. It is here where parents first begin their journey and learn how to become a partner in their child’s education as well as a leader in their community. Many Early Education and Care providers want to have family engagement programs but have limited funds and staff to carry these programs out. Many times programs need funding for the provision of child care during parent meetings, travel stipends, etc. Grants such as RTT-ELC can provide the needed funds to help programs and early childhood providers access the training needed to enhance the quality of their programs.
Lastly it is very important to involve parents in the process of program and policy development. They understand the changing needs of their family far better that policy makers who sit behind a desk and read research. Parents should be viewed as the experts on their situations. They are their child’s first and best teacher and the “CEO” of their family. It is important that their voices be heard when developing programs and plans for their families.
At my children’s school there was a very active parent group. We were encouraged upon entry to become a partner with our child’s teacher as well as the school as a whole. Parents were treated as professionals and afforded respect and support for the role they played in the school. I helped to develop a thriving community service program at the school that continues to grow. This was a great project and helped me develop connections within the community At the time I did not have strong connections in my community and felt isolate because I did not have family member to rely on for support and guidance. The school began to fill that void and help me begin to build a network of support. My three youngest children entered this setting as toddlers. I became comfortable with the role of “expert “ on my child and learned to ask questions and solicit help when needed. I feel that I became a stronger parent because of the encouragement and support I received. I also felt empowered to advocate for my children and make a difference within my community. I hope that because of grants such as RTT-ELC all parents can be empowered to be strong not only for their family but for the community at large.
I appreciate the efforts of the Obama Administration to provide grants such as RTT-ELC that support Early Learning. These programs strengthen families which ultimately strengthen our nation.

COMMENTS ON THE DRAFT PRIORITIES AND CRITERA FOR THE
RACE TO THE TOP EARLY LEARNING CHALLENGE:
By the Pew Home Visiting Campaign

The Pew Home Visiting Campaign, of the Pew Center on the States, promotes the adoption of data-driven state and federal policies that advance smart investments in high-quality, home-based programs for new and expectant families. Our recommendations are informed by research and best practices in the field and we hope they are helpful as you draft final application guidelines. If you have any questions about our research and recommendations, please contact Nicole Barcliff, Senior Associate, Government Relations at (202) 552-2201 or nbarcliff@pewtrusts.org.

PRIORITIES
Priority 1: Absolute Priority – Using Early Learning and Development Standards and Kindergarten Entry Assessments to Promote School Readiness. According to the National Infant & Toddler Child Care Initiative, Early Learning Guidelines (ELG) or standards “describe expectations about what children should know (understand) and do (competencies and skills) across multiple domains of learning during specific age ranges”. The new federal initiative has the unique opportunity to guide (and promote) state innovation by using data to identify indicators of programmatic success and ensure that there is a focus on delivering outcomes. In addition to using early learning and development standards and kindergarten entry assessments to promote school readiness, states should be encouraged and rewarded for establishing a plan that uses infant / toddler guidelines to guide program development and data collection across programs – including appropriate alignment of desired outcomes for the Maternal, Infant, and Early Childhood Home Visiting Program (MIECHV) - in order to deliver appropriate outcomes for early learning and socio-emotional development.

SUGGESTED PRIORITY 5: Competitive Preference Priority – States should be rewarded for developing a strategy that invests in well-designed programs that are supported by research. RTTT-ELC provides an opportune moment for federal leadership in setting criteria to help guide public investments. We encourage DOE and DHHS to model the positive trend that is present in other early childhood development initiatives – using research and evidence to allocate public dollars. The new MIECHV provides a good example of how federal guidance can move states in the direction of establishing data-driven criteria to guide allocation of resources to state programs. The home visiting initiative requires prioritization of public resources for proven programs that meet the highest evidentiary standards, ensure fidelity in implementation, and are proven to yield the highest return on investment. It pushes states to invest in programs supported by research and evidence. To that end, RTTT-ELC should reward states for developing a strategy that invests in well-designed programs that are supported by research.

SELECTION CRITERIA
(A)(3) High Quality, Accountable Programs: States should be rewarded for aligning early childhood development goals across programs and funding streams. There are several early childhood programs – particularly those that forge a unique federal / state partnership (MIECHV, Head Start, Early Head Start, etc.) – that seek to deliver similar outcomes within the same domain. As states fulfill the requirements for these initiatives, they should be encouraged to move toward aligning goals across different early childhood programs, which would facilitate coordination of services, funding, data collection and assessment. Even though some programs will need to have a focus on the fidelity and efficacy to particular models, over time, general infant / toddler and early learning guidelines can serve as an important foundation for such an effort.

(C)(3) High-Quality Accountable Programs – Rating, monitoring, and improving Early Learning and Development Programs: States should be rewarded for developing a plan to measure outcomes in order to drive improvements and offer a return on the public’s investment. States should improve systems for monitoring and continuous improvement activities. RTTT-ELC funds can support articulation of clear, measureable outcomes for the early childhood system, identify indicators that move programs toward desired outcomes, develop rigorous ways to assess progress and collect real-time data, and build states’ capacity to use data to support quality improvements and policy decisions. States should also be encouraged to link their federal and state supported home visiting programs to developmentally appropriate outcomes for infants and toddlers. By developing such systems, states can hold programs accountable, refine service delivery, and spur innovation by identifying problem areas that may require creative solutions.

ELIGIBILITY REQUIREMENTS
Early childhood stakeholders should be required to sign letters of commitment and support for the proposed early learning strategy to ensure that each state is focused on inter-agency collaboration. We applaud DOE and DHHS for including agencies responsible for administering state home visiting programs in the Participating State Agency category, and for requiring a Memorandum of Understanding (MOU) describing the agency’s level of participation in the grant as part of the application. Establishing an integrated system of high quality early learning programs and services requires collaboration among the agencies and entities responsible for various early childhood programs. In order to assure effective coordination and delivery of critical early learning, health, development, child abuse and neglect prevention and family support services, entities with direct involvement, or investment in early childhood development state programs should be consulted and concur with the development of the ELC strategy.

SELECTION CRITERIA
Selection Criteria (A)(3) – Successful State Systems – Organizing and aligning the early learning and development system to achieve success: States should be required to articulate a strategy that includes the lead entity for the Maternal Infant, and Early Childhood Home Visiting Program. We are encouraged that the proposed rules include state agencies administering home visiting services in the Participating State Agency category, and suggest that the state lead for MIECHV be included in the formulation of state RTTT-ELC applications. The MIECHV marks the beginning of a new era for federal investment in well-designed home-based services that have been proven to yield significant positive outcomes for high-risk children and families. States have taken significant steps in developing comprehensive state plans that rely on evidence-based programs, data, and continuous quality improvement to produce desirable outcomes for children and families. The RTTT-ELC provides an opportunity for states to align two federal programs with similar goals.

COMMENTS ON THE DRAFT PRIORITIES AND CRITERA FOR THE
RACE TO THE TOP EARLY LEARNING CHALLENGE:
By Pre-K Now, a campaign of the Pew Center on the States

Pre-K Now, a campaign of the Pew Center on the States, advocates for the adoption of data-driven state and federal policies that advance smart investments in high-quality, voluntary pre-kindergarten. We would like to thank the U.S. Department of Education and the U.S. Department of Health and Human Services for the opportunity to provide input regarding the draft executive summary of the requirements, priorities, selection criteria, and definitions for the Race to the Top – Early Learning Challenge (RTTT-ELC) competition. We look forward to being a resource to you in this process. If you have any questions or require additional information about our research and recommendations, please contact David Beard, Senior Associate at (202) 540-6409 or dbeard@pewtrusts.org.

We were pleased to see many of our recommendations reflected in this draft as you set a high bar for states to receive an RTTT-ELC grant. We applaud the requirements to secure buy-in from all relevant agencies and the collaboration that memoranda of understanding will promote at the state level. We hope that the final application guidelines will continue to reflect your commitment to improving quality of state early learning systems in ambitious and measurable ways across all Early Learning and Development Programs.

We support Priority 1: “Using Early Learning and Development Standards and Kindergarten Entry Assessments to Promote School Readiness” and its designation as an Absolute Priority. This work will spur state initiatives to close school readiness gaps at kindergarten entry and reward states that measure outcomes in developmentally-appropriate ways to drive improvements and demonstrate a return on the public’s investment. To ensure that this priority has the intended impact, it is important for states to embed their kindergarten readiness assessments in robust systems for monitoring and continuous improvement that include clear, measureable outcomes for the early childhood system; valid indicators of these outcomes; training to ensure appropriate administration of assessments, and systematic processes for stakeholders to use assessment data to improve instruction, target professional development activities and inform other quality investments.

Like standards, assessments are critical to informing practice and improving educational outcomes for children. Given what research tells us about the unique issues related to early childhood assessments and their impact on children, many organizations in the early childhood field are concerned about the possibility that standards and assessments would translate to high-stakes testing in the younger years. While we would oppose using assessments that provide or lead to rewards or sanctions for individual children, teachers, early childhood education programs, or schools, we do support the use of valid, reliable, and developmentally-appropriate progress monitoring and assessments for program improvement. Appropriate and high-quality assessments should be a critical piece of reform.

In addition to kindergarten readiness assessments, state leaders and local stakeholders need information about child development and learning at multiple points in time from birth to kindergarten entry to have a better grasp of how young children are progressing before kindergarten and how investments in program access, workforce improvements and other quality efforts influence their development over time. We recommend that the definition of “Essential Data Elements” include “child-level data on development and learning from birth to kindergarten entry.” 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, and developmentally-appropriate and used for formative purposes and not for high-stakes decisions.

Building on this recommendation and on our support for early learning standards and kindergarten entry assessments to promote school readiness, we seek to ensure that the benefits of early learning are maximized and that children’s readiness for kindergarten eventually translates into college and career readiness. To that end, we recommend upgrading Priority 4: “Sustaining Program Effects in the Early Elementary Grades” from Invitational to Competitive priority. States should be required to demonstrate that their early learning system will be part of a comprehensive, systemic effort to improve education and raise student achievement.

The RTTT-ELC should do more to encourage states and school districts to utilize existing education funding streams, such as Title I and professional development funds under ESEA, to create a seamless continuum of learning for High-Need Children. In the current draft, the state’s budget included under the State Plan would show “how resources will be repurposed or reallocated, from other Federal, State, private, and local sources (e.g. CCDF, Title I, IDEA, State preschool, […]) to align those resources with, and support and sustain, the State Plan.” Building strong connections between early childhood and education funding streams should be featured more prominently among the selection criteria. As one example, professional development funds under ESEA may be used to provide joint training for community-based pre-k teachers and early elementary teachers - an activity that should be addressed and encouraged in Priority 4.

Our recommendations are informed by research, best practices in the field and a decade of state-level advocacy for high-quality pre-k, and we hope they are helpful as you finalize application guidelines. We forward to working with you to ensure the successful implementation of Race to the Top – Early Learning Challenge.

The National Professional Development Center on Inclusion (NPDCI) is pleased to have the opportunity to submit comments on the draft criteria and priorities for the Race to the Top – Early Learning Challenge. We strongly support many of the document’s features including:
• The broad definition of the early childhood workforce and the various sectors included in the criteria;
• The emphasis on a high quality, tiered, accountability system whose purpose includes increasing the number of High-Need Children served and the broad participation across all Early Learning and Development Programs; however, it should be noted that for many states there exist multiple accountability systems and this challenge is not explicitly addressed through the current set of priorities.
• The emphasis on partnering with higher education as part of the “great early childhood education workforce” component. Such partnerships will ensure that states have access to information that reflects the most up-to-date research knowledge and the newest innovations in early care and education practices.
• The emphasis on the development of a coordinated Comprehensive Assessment System based on the use of multiple assessments for various purposes, including the recent emphasis on formative assessment to inform instructional and caregiving decisions.
We recommend:
• In section (B) increasing the emphasis on linking assessment with interventions. This is mentioned in Section (B)(2)(c) but could be highlighted to a greater degree. Currently three national organizations, the Division for Early Childhood, the National Association for the Education of Young Children, and the National Head Start Association are developing a joint position statement on Response to Intervention (RTI) for early childhood that will provide guidance on linking formative assessment with instruction and interventions.
• Providing guidance to states in section (D)(1) on the development of Early Childhood Educator competencies so that there is consistency across states and connections with national standards. (This will require work from national leaders with support from federal agencies in integrating different sets of national standards and ensuring that competencies reflect the knowledge and skills needed to support each and every child, including High-Need Children, and emerging research on effective practices.)
• Defining professional development in the criteria so that the emphasis is on both the acquisition and application of knowledge and skills and competencies in section (D)(2), requiring an emphasis on methods that address formal and informal learning opportunities and that provide structured guidance and corrective feedback.
• Asking states to link competencies with specific evidence-based practices that are associated with positive child and family outcomes and making those practices the centerpiece of professional development in section (D). This would entail providing a definition of specific evidence-based practices and placing greater emphasis on early care and education practices throughout the criteria. This suggestion is in keeping with the NCATE 2010 report on teacher education and the need to move to a clinical teaching model that focuses on specific practices rather than general knowledge, is performance-based, and linked to competencies and standards.
• Ensuring that the emphasis on High-Need Children, cross-sector participation, and cross-sector integration, which are present in some criteria areas, are incorporated consistently in all areas of the document including the section on workforce (D).

We appreciate the opportunity to provide feedback on the draft criteria and priorities. There are some resources that have been developed by NPDCI and other national early childhood TA centers (e.g., NCCIC and others) with direct relevance to the criteria. These are available through the Early Childhood Technical Assistance Consortium website: http://www.ectaconsortium.org/

The National Professional Development Center on Inclusion (NPDCI) is funded by the US Department of Education, Office of Special Education Programs, to assist states in building an integrated professional development system that supports high quality inclusion: http://community.fpg.unc.edu/npdci

As an early childhood professional, I confidentally support this comment.

The American Association of School Administrators, representing more than 13,000 school system leaders across the nation, is pleased to submit comments on the draft priorities and criteria for the Race to the Top Early Learning Challenge (RTTT-ELC) program. AASA has long recognized the value of high-quality early education and supports a voluntary role for the nation’s public school districts. AASA’s Governing Board and Executive Committee have reviewed and adopted, several times over, a national policy on this issue that is very clear:
Recognizing the critical role that families and early education plays in getting students ready for school, AASA resolves that every child must be provided with quality, comprehensive early childhood programming so that he/she can enter kindergarten ready to learn with the skills necessary to ensure success in school. A high percentage of a child’s development and learning occurs by age 5. All children should enter school ready to learn, and every adult in the community must assume a measure of responsibility for the education, welfare and safety of each child. Therefore, AASA believes that communities should offer developmentally appropriate early educational programs for all children beginning no later than age 3. The future success of all children requires such an investment.

AASA also has a clearly established preference for proper and continued investment in formula funding programs instead of competitive grants, like Race to the Top. AASA opposes the competitive concept behind Race to the Top in large part because of the unfair disadvantage many schools face in lacking the capacity—though not willingness—to compete. Given the reality of the $500 million that is moving through RTTT-ELC and having reviewed the RTTT-ELC draft criteria, AASA has identified a handful of provisions that have significant implications for public schools. We submit these comments so as to avoid implementing RTTT-ELC in a way that undermines the ability and effectiveness of schools to fulfill their roles as providers of both early and K-12 educational opportunities.

1. Eliminate the requirement for re-directing existing education funds. Draft Performance Measures requires state applications for RTTT-ELC funding to provide a budget that demonstrates how resources will be repurposed from other federal, state, private and local sources, including IDEA and Title I. AASA is concerned that the wording of this section suggests that the redirection of funds is mandatory, and strongly encourages maintaining flexibility for states and LEAs with regard to federal education funds. Further, AASA strongly opposes any mandate to repurpose in order to qualify for the RTT-ELC grant. Both IDEA and Title I are already underfunded, and the continued funding constraints threaten already diminished resources at the state and local level.
2. Include local school districts in the process of both applying for and implementing RTT-ELC grants. While the draft performance measures require state applicants to demonstrate commitment from a broad group of stakeholders and local communities through letters of support, MOUs, etc., local education agencies (LEAs) and education service agencies (ESAs) are not mentioned. Numerous stakeholder categories are identified in the draft (including early childhood advisory councils, early childhood educations, education association leaders, family and community organizations and a broad range of early learning administrators), but both LEAs and ESAs are notably absent and both would make meaningful contributions to the process and implementation of the grant, given the potential and widespread impact on K-12 education.
3. Ensure that assessment requirements are not over-reliant on academic testing of pre-schoolers. AASA is concerned by the seeming over-reliance on the use of academic assessment for early education participants. AASA supports and understands the importance of using assessments to evaluate a program, but does not endorse academic assessments on our youngest students. The focus of early education should be development, not academics. AASA is concerned about testing young children who cannot read, are still learning to listen, may not know the phonemes, and are still developing the gross and fine motor skills necessary to use their hands well enough to reliably mark answers. Another point of concern would be the high-stakes nature of any of these assessments, and the negative impact high-stakes testing has on any activity, including the documented experience with NCLB in K-12 education. There is a sizeable difference between assessing an early education program or activity and assessing children. At this young age, these students are learning through experience, and learning takes place through experiences, touching, feeling and manipulating, none of which can be fairly evaluated through academic assessment. Further, at this age, a sense of fear or insecurity—well-documented in the frequently-assessed K-12 students—is detrimental to optimal learning, and even more so in the youngest students. A hyper-focus on academics and assessment, at the detriment of supporting the social and emotional growth and well-being that is crucial to the early learning experience, undermines the whole purpose of early education. We urge the Department to clarify its expectations and requirements around assessments within RTT-ELC, to clarify expectations between assessing programs/activities and assessing students.

AASA welcomes the opportunity to work further to enhance the collaboration between LEAs and others.

I applaud the Obama Administration for their commitment to early learning and I respectfully ask that they take the next bold step to insure that all families have access to affordable quality childcare regardless of socio economic status, rural or urban, migrant or immigrant, etc. until their children reach school age.

The increasing number of single parent families and the large number of families requiring two incomes due to stagnant or declining wages for some types of work have made child care a necessity for millions

Working parents with low and moderate incomes are hardest hit by the lack of affordable, quality child care. In rural areas, this lack is a serious barrier to families’ financial security and the safety and development of their children. Their children are usually left with neighbors, family, or friends. Unfortunately, the majority of these caregivers/babysitters are not aware of the state licensure and the requirements associated with the licensure. Because of the lack of knowledge, there are no quality control measures built in to protect children or parents, there are no health and safety standards for care, and caregivers more than likely have no training. In addition, the ratio of caregiver-to-children is not enforced, so caregivers may take in as many children as they can.

Recently a young father from a rural community was given the opportunity to provide input to the Department of Early Learning in Washington State regarding what he wanted in a child care center for his children. He was flabbergasted when he found out that there were child care centers and that a license was required in order for someone to provide child care and that there were licensing requirements to ensure that children were in safe, healthy, and nurturing places. A humble man yet proud of his children; he stated that all he wants is for them to have the same education opportunities as other kids. He was very grateful for what he learned, honored that he was invited to the table and excited to share this new knowledge with his community. He left with renewed faith believing that his children would have a real chance at a better life, but will they?

During the summer many parents struggle with what to do with their kids. Most Latino parents cannot afford to send their children to all day child care much less to summer camp. Out of necessity they leave their children home alone to fend for themselves. A young anguished single mother shared that she worried that the neighbors would find out and report her but she had no other alternative. The fact that she is not socially connected, has no family to count on, and has a low paying job limits her options on what to do with her children. At a recent visit to a migrant farmworker housing camp, I saw young children taking care of their siblings because their parents had to work long hours in the fields. Being removed from the community and in a very rural area also makes it more difficult to have access to some form of childcare.

It is imperative that every child has access to quality child care. A place where every child is safe and accepted regardless of their race, religion, special needs, etc., a place where staff is valued, trained, paid a living wage, and sensitive to cultural differences. Furthermore, a place where adoption of the Five Protective Factor framework is fundamental and “a given” in order to ensure that all children develop, learn, and have a positive experience.

Of paramount importance is the parent; a child's first and most influential teacher is the parent. It is crucial that parents be given the opportunity to be at the table in all local, state, and federal policy decision-making and activities. In order for “parent partnerships to improve care for all children” to work, we must insure that parents are given the tools, training and necessary support to fully participate in the decision-making process and co-creation of programs.

The Protective Factors are positive attributes that strengthen all families and which should be a birthright!
• Parental resilience
• Social connections
• Concrete support in times of need
• Knowledge of parenting and child development
• Social and emotional competence of children
All of the factors work together to reinforce each other. I strongly believe that If all child care systems and programs focus on the Protective Factors, which most families themselves want to build, it will undeniably foster and develop positive relationships between parents and providers.

In my work with schools and with many communities I have found that no matter what age, race, ethnicity, culture, etc. we all have the same basic needs and we all want what is best for our children.

Thank you for the opportunity to provide my input.

On behalf of the Washington State Child Care Resource & Referral Network, I am writing to express strong support for the Race to the Top-Early Learning Challenge (RTT-ELC) proposed requirements. This new approach to child care and early learning promises to ensure that children are in quality settings and arrive at school ready to succeed. Thank you for the opportunity to comment.

Threshold/Licensing

I applaud the competitive preference priority of requiring that states must increase the number of children from birth to kindergarten who are participating in programs governed by the state’s licensing system and quality standards. In particular, I support setting the licensing threshold standard for states at two or more unrelated children. While I would prefer to see this threshold set at one unrelated child, as we have here in Washington State, two or more is movement in the right direction. In addition, I believe that any state licensing requirement should include inspections on a quarterly basis. Inspections ensure that children are in safe settings and that the providers are in compliance with state laws and regulations. Here in Washington State, as we implement our QRIS through the WA State CCR&R Network, we are redesigning the roles of licensing and CCR&R to better leverage and compliment the public investment. We are focusing licensing on getting potential new providers licensed and keeping all licensees in compliance. Any quality improvement above licensing will be the role of the CCR&R Network. This might be a good model for maximizing licensing’s accountability across the nation.

Parent Engagement

I support the inclusion of engaging and supporting families as a selection criterion. Studies have shown that parental involvement is crucial in the development of children and that parent-provider communication is linked to the quality of care provided. Nothing is more important to a child’s progress than parents who are engaged and knowledgeable about their child’s needs in order to support their education and development. Parents, child care programs, and state and federal policymakers share responsibility for the safety and well-being of children while they are in child care settings. Early childhood educators should be trained on effective family engagement strategies and parents must have access to the information they need to make informed decisions about their child’s educational and developmental needs.

Health and Safety Linkage

I support the inclusion of identifying and addressing the health, behavioral, and developmental needs of high-need children to support school readiness as a selection criterion. Children cannot grow and learn if they are not in healthy and safe environments. Health and behavioral screenings are important factors in a child’s school readiness and future school success. Early intervention can prevent school failure, reduce the need for special education services, is associated with avoiding violent crime, and becoming an employed adult. The promotion of children’s physical, social, and emotional development is crucial to their future success and early childhood educators must be trained to support and help meet these needs. In addition, I applaud your inclusion of promoting healthy eating habits, expanded physical activity, and improved nutrition. Three times more children are obese today than just 30 years ago. Plus, more and more children are being diagnosed with obesity-related conditions, like type 2 diabetes and high blood pressure. Studies have shown that the promotion of healthier choices, in food and. lifestyle, helps prevent childhood obesity and other related illnesses from the start. I would also suggest encouraging connecting kids with nature as a multi-faceted approach to the fight against childhood obesity and healthy social emotional development. I commend you for taking these necessary steps now to protect children’s health and success in the future.

Full Day, Full Year Care

Working parents need full day, full year care and I strongly support your inclusion for such programs in these proposed requirements.

Assessment

I commend you for the inclusion of effective uses of comprehensive assessment systems as a selection criterion priority. The only way to determine and assess a child’s needs and educational development is through an effective developmentally appropriate comprehensive assessment system. Nothing is also more important to this system than early child educators’ understanding of the purposes and uses of such assessments in a comprehensive system. Training to these early childhood educators to appropriately administer the assessments and interpret assessment data is so vital to the improvement and guidance of instruction, programs, and services.

I am in support of the Obama administration proposal, with the number of children in this country who come to school already behind we must get them much earlier than Kindergarten. It is a must to include parents as much as possible. Screening children for social and emotional problems in critical to any Early Childhood Program. We also must measure children and track them through this period of development. To track and not provide the supportive service is criminal. Having a way to address the children need must be in place and it appears that this would happen based on the criteria. I will say that this model is what is mostly taking place in the old Head Start model but with more funding.

I am are writing to express strong support for the Race to the Top-Early Learning Challenge (RTT-ELC) proposed requirements. It is wonderful to see the Administration take a new approach to child care and early learning to ensure that children are in quality settings and arrive at school ready to learn. With more than 11 million children spending an average of 35 hours per week in some type of child care setting it is vital to ensure that these settings are licensed to provide minimum protections for states and ensure that these programs offer early learning opportunities as well. Thanks for the opportunity to comment

I welcome the competitive priority where states must increase the number of children from birth to kindergarten who are participating in programs governed by the state’s licensing system and quality standards. In particular, I support setting the licensing threshold standard for states at two or more unrelated children. While I would prefer to see this threshold set at one unrelated child, two or more is a laudable improvement for states. In addition, I believe that any state licensing requirement should include inspections on a regular basis. Inspections ensure that children are in safe settings and that the providers are in compliance with state laws and regulations.

I support the inclusion of engaging and supporting families as a selection criterion. We know that parental involvement is crucial in the development of children and that parent-provider communication is linked to the quality of care provided. Nothing is more important to a child’s progress than parents who are engaged and knowledgeable about their child’s needs in order to support their education and development. Parents, child care programs, and state and federal policymakers share responsibility for the safety and well-being of children while they are in child care settings. Early childhood educators should be trained on effective family engagement strategies and parents must have access to the information they need to make informed decisions about their child’s educational and developmental needs.

Finally, I know working parents need full day, full year care and I strongly support your inclusion for such programs in these proposed requirements.

Thank you again for being able to respond to this exciting opportunity.

The Somali Youth and Family Club sees a need for the Strengthening Families approach needs to be applied to this grant because what works for one community may not work for the other but the Protective Factor Framework of the Strengthening Families approach applies to any child’s situation. Additionally, these grants must be used to ensure quality early childhood experiences for all children, and in particular, for children in the child welfare system until they reach school age.

We cannot expect quality care and school readiness from a refugee community members who cannot read or write or have the basic protective factors needed for a child to thrive in their household such as concrete supports in times of need or adequate knowledge of parenting and child development and the capacity to nurture a child’s social and emotional competency. We would like to see a change in the policy that permits the licensing of home daycare businesses that are not contributing positively our children's development. Our children will thrive if they attend quality daycare centers, where there is supervision and more structured programs with adequate evaluation.

The funding must go to programs that can play a role in our children's cognitive development. In our community, most of the parents expressed that they learn about the problems their children are facing after they start school and when it is too late to reverse the effects of such poor quality home daycare. The funding must also be used for programs that offer parental skills at the grass roots level communities, not only for large agencies that can prove their big budget plans. Our community is running a Community Cafe with Kaleidoscope Play and Learn sessions for under five children in the Creston Point Apartments (Seattle WA) for the last six months. And we found that many kids are able to read letters, words, picture stories and count numbers. These children were sitting home and not having this kind of opportunity before. We have received positive feedback from many parents. One of our parents took her four year old to the eye doctor. While at the eye doctor, her four year old was able to read all the letters for the examining doctor. The doctor admitted he was impressed to see Shurkri being proud and able to read all the letters. Her mother was equally proud. This is extremely rewarding to hear. The project is successful and vital and we highly encourage funding for such programs.

Play is the work of children –

“From everything we know about brain development, children can learn skills that lead to reading right from birth, and it’s important especially in the first three years of life.” (Dr. Barry Zuckerman, Rx: Read to Your Baby, New York Times, 4/17/11)

Very young children who are given opportunities for developmentally appropriate play, especially with the guidance of a trusted adult, are most likely to begin their formal schooling “ready to learn”.

Some parents of small children do not know what is developmentally appropriate play and, not realizing its value, are not necessarily looking for the information. Schools have much to gain by promoting school readiness in children from birth to five years old, but lack ready access to those families and the resources to reach them. However, schools could, at very little cost in time or money, invite the physicians who care for very young children to promote school readiness, and could give the doctors guidance in what is appropriate developmental play, and what community resources exist to help parents promote it.

Pediatricians and other doctors who regularly treat small children are almost always held in very high regard by the families they serve, and their advice is not taken lightly.
The framework for such a plan already exists in the national nonprofit Reach Out and Read program, where young patients from six months to five years old are “prescribed” a book at every checkup. (See “Rx: Read to Your Baby”, New York Times, 4/17/11).

An incentive to physicians could be earning CME credits for a few hours in a course on school readiness developed jointly by the school system, community or other college and the early childhood community.

“Many studies indicate that the period that starts at eight months and ends at three years is of unique importance in the development of a human being. To begin to look at a child’s educational development when he or she is two years of age is already much too late, particularly in the area of social skills and attitudes.” (emphasis supplied) (Dr. Burton L. White, The First Three Years of Life, Prentice-Hall Press, 1985, p. 11),

Play with me Read to me Laugh with me Talk to me Sing with me Listen to me!

Jane Andrew
Severna Park, MD
7/7/11

On behalf of the NYS Early Care & Learning Council Board of Directors and staff, thank you for your investment in our youngest children through the Early Learning Challenge Fund. We also thank you for this opportunity to provide input on the fund. In New York, the responsibility of school readiness is shared among an early childhood system that includes families, professionals and the community with an exceptionally strong connection to local communities through a network of Child Care Resource and Referral (CCR&Rs) agencies.

The Early Care & Learning Council is the network hub for New York State’s CCR&Rs. Our CCR&Rs are organized by county or multi-county regions, many of which include a mix of urban and rural communities. The network provides information about early care and education to public officials, the media, civic leaders and the public, perform annual needs assessments, and are active in community collaborations to improve the quality and availability of early care and learning services.

We appreciate the opportunity to provide feedback and make recommendations for the Race to the Top- Early Childhood Challenge grant competition. Please consider the recommendations below.

Establishing a System of Quality of Care

•Child Care Licensing- Quality Rating and Improvement Systems must be linked to the State licensing system.
•Child Care Quality Investments—States must demonstrate that they have a plan to align spending on quality activities through their CCDBG state grant with the activities of all other systems for integrated services. (QRIS, Intensive Technical Assistance, Pre-K, etc)
•Financial incentives and non-monetary supports to programs and providers must be included to meet and sustain higher levels of quality program standards.
•Children’s early experiences create the foundation for all future learning, behavior and health. High-quality early childhood programs, starting at birth, provide the foundation that children need to become ready for success in school and in life. States must demonstrate that they will increase the availability of high quality licensed and regulated early childhood programs.

Support Professional Development

•Scholarship and Compensation Initiative-States should and implement a system of workforce supports such as scholarships to attain a credential or degree, salary/wage supplements and other compensation benefits (such as health care) that is aligned with the elements of the integrated system of high quality early learning programs and services, including the professional development system.
•Attention must be given to retention rates in the field of Early Childhood Education.

Expand Data and Systems

•All data collected on young children (including early learning programs and program quality and the early childhood workforce) should be linked with the data that is collected in the K-12 state education system. Information stored in the Statewide Longitudinal Data System would then be found through unique identifiers assigned to child, teacher or program site. This would improve the quality and use of data.
•The alignment of early learning and K-3 standards is necessary and should encourage states to set research-based expectations for children of all ages in all key areas of child development including cognitive (literacy/communications, mathematics, science, and social studies), social, emotional, and physical development.
•As states improve the use of child assessments to improve teaching and learning and report on the overall status of young children, birth to age 5, there should be a demonstrated collaboration with related state efforts serve children in K-3 classrooms.

Develop Transitions and Supports

•States must examine standards to ensure that all children are healthy and ready to learn, this includes a concentration on all health, behavioral and developmental needs and transition to kindergarten.
•Full Day Kindergarten- States must demonstrate how the integrated system will help expand the availability of high quality full-day early childhood programs in low-income communities (including both rural and urban communities). This will limit the amount of times during the day a child must transition to another site.
•Family Engagement, Outreach, and Consumer Education- Early childhood education programs must be culturally and linguistically accessible, inclusive and respectful of the diversity of families and children. Existing resources should be leveraged to promote family support and engagement.

Unique Circumstances

•Consideration must be given to include States at Different Stages in the development of their Quality Rating and Improvement System.
•The diverse population of a state must be considered so all young child are given the opportunity to learn and grow. In populations where English is not the primary language, support must be given to Dual Language Learners.

Thank you again for this opportunity and we look forward to working with you to ensure that today’s children to become tomorrow’s leaders! Please do not hesitate to call on me anytime at (518) 690-4217 ex 27.

Best Regards,

Marsha Basloe
Executive Director

The National Center for Learning Disabilities (NCLD) welcomes the opportunity to comment on the Race to the Top-Early Learning Challenge (RTTT-ELC) program the competition’s areas of focus. The RTTT-ELC program represents an important step in helping states focus on the most effective strategies and supports to prepare young children, especially high-need children, including those with disabilities or those most at-risk for being identified for special education to enter school ready to learn. To accomplish this, we recommend focuses on encouraging systemic professional development for early educators in identifying learning difficulties and in implementing Multi-Tier System of Supports (MTSS) also known as Response to Intervention (RTI) in the RTTT-ELC program.

A major component of school readiness is a identifying and responding to any learning and behavior difficulties which a child may exhibit at a young age. To accomplish this, early childhood educators and other staff working with young children need professional development and training to spot these challenges. This professional development would allow educators to intervene and respond to the needs of struggling preschool-age children – before a child’s learning and behavior issues hamper their school readiness and future academic achievement.

Also critical to ensuring school readiness is the use of Pre-K MTSS, or RTI as it is also referred to, by schools and early childhood programs and providers. NCLD strongly believes that Pre-K MTSS should be an essential component of state efforts under this program. Pre-K MTSS can respond, in real time, to the occurrence of language, literacy, and academic learning and behavioral difficulties in young children. The Department’s work -- focused on bringing MTSS to the early childhood setting in key states and with key partners -- is promoting and supporting promising results across the country.

The most critical element of Pre-K MTSS is a tiered approach to meeting the learning and behavior needs of children. The tiered approach allows more rigorous evidence-based interventions when a child struggles. In total, key aspects of MTSS in the Pre-K context include:
• High quality classroom instruction
• Universal screening of all children
• Evidence-based tiered instruction and intervention
• Ongoing [formative] assessment and progress monitoring
• Using student data to make student-focused decisions
• Family involvement to support the child’s learning and behavioral needs

To accomplish both of these important priorities, NCLD offers the following recommendations for the RTTT-ELC program and the priorities for its competition:

States which are presently implementing Pre-K MTSS or commit to implementing Pre-K MTSS as a part of the application they submit should receive a priority in receiving a grant. Those states which have already begun to effectively implement MTSS or Pre-K MTSS will be further along in responding to the learning difficulties of students and understanding the professional development needs among personnel. Providing a priority for these states to win grants would reinforce the importance of state-led reform efforts and using proven, research based techniques to ensure children are ready for school. Likewise, a State that commits to rigorously implement Pre-K MTSS should also be given a priority (at a slightly reduced level compared to states which already undergone implementation) in this grant competition.

The RTTT-ELC program should authorize funds to implement Pre-K MTSS programs. Once a state has received RTTT-ELC funds, using these funds in the most effective way should be the priority to ensure strong, demonstrable results. Implementing a Pre-K MTSS program or supporting an existing implementation effort would be an effective use of RTTT-ELC program funds.

States should be permitted to use RTTT-ELC program funds to implement professional development for educators to identify learning difficulties before they impact school readiness. Professional development to provide early identification of children experiencing learning difficulties is sorely needed. Preparing teachers to responding to a child’s learning disability before it impacts their eventual school readiness is critical to RTTT-ELC funds having the greatest possible impact.

These recommendations will add an important focus to the RTTT-ELC program that will ensure that states can maximize the resources they receive to improve the quality and services provided under their early childhood programs. NCLD believes these modest recommendations will significantly advance the ability of educators to ensure struggling preschool-age children are ready to academically achieve when they enter school.

Thank you for the opportunity to comment on the priorities for the RTTT-ELC program and its eventual implementation.

James H. Wendorf
Executive Director, NCLD

Thank you for the opportunity to comment on the RTT-ELC Program draft requirements, priorities and selection criteria as well as the ability to read others' comments to date. I have three areas of comment to provide. My comments are informed by my experiences as an early childhood educator actively involved with our state's professional development system as well as my current position as a school board member for our unit school district.

1. In addressing Priority 1, I caution against relying on test scores in early childhood as a measure of program quality. I recommend a recent interview with Sam Meisels, president of Erikson Institute, where he discusses developmentally appropriate assessments of young children and the unintended consequences of testing in early childhood. The interview with Sam Meisels, which includes a link to his paper "Accountability in Early Childhood: No Easy Answers", can be read at: http://illinoisearlylearning.org/interviews/meisels.htm.

2. To ensure "efforts to close the school readiness gap at kindergarten entry and inform instruction and services in the early elementary school grades" (as stated in Priority 1), I recommend that local school districts are involved in the application and implementation of RTT-ELC. Representation from school board members as well as district administrators and educators are essential to ensure practices align between community based and school based early childhood programs and that best practices are used in all cases to provide for a successful student transition in the K-3 grades.

3. In applying your 4th selection criteria related to "a great early childhood education workforce" I recommend you look for examples where states are addressing serious wage disparities among early childhood teachers with wage supplement-related programs to equalize wages and benefits across sectors. As the report "Who's Caring for the Kids? The Status of the Early Childhood Workforce in Illinois-2008" [find: http://ceep.crc.illinois.edu/pubs/whos-caring/whos_caring_report_2008.pdf] indicates, the wide variation in compensation across early childhood program sectors is drawing teachers with degrees and early childhood certification from community-based programs to public school programs. For children to have access to comparable early learning opportunities, the differential wages and benefits across early childhood program sectors must be addressed.

I am writing from the state of NY. The best educational opportunities tend to cater to the elite. ALL children deserve the best education that the adults he or she depends on can provide ( it takes a village to raise a child). Many states offer charter schools - Montessori (AMI) schools which provide EVERY child with the opportunity to grow and learn in peace and security.
Not only other states but other countries, namely Finland, Sweden, Australia, Japan and now China and many more are adopting AMI Montessori education into their school systems. The United States is by far the leader in AMI Montessori population, teachers, training sites, schools, etc. yet the United States is farthest behind in incorporating what is already here into the public school systems. Milwakee Public schools have upheld AMI Montessori education in their public schools for children preK to 6th grade for more than 20 years.
I feel the solution is right in front of us but bureaocratic stalwarts are holding a failing ground.
The teachers unions in my area practically run the schools leaving little if any area for creativity on the part of the teacher. Our children are our future and most precious resource. They must have the opportunities to grow and flourish in peace and harmony with adults to GUIDE them in a child centered environment, not TEACHERS who force information in an adult centered environment. The 3-6 year olds are the most impressionable and need to be reached and nurtured in a creative, peaceful environment which values academic achievement along side with emotional development and social awareness. These children are our future and deserve nothing less than the best there is regardless of their income, cultural origin, religion, race etc. Our diversity is what makes us great. We need to play that card wisely.
AMI Montessori teacher 33 years...(privately since there are no charter schools in Nassau County)

The National School Boards Association (NSBA), representing over 90,000 local school board members across the nation, is pleased to submit comments on the draft priorities and criteria for the Race to the Top Early Learning Challenge (RTT-ELC) program. NSBA has long recognized the benefits of high quality Pre-K and supports a voluntary role for local school districts. NSBA’s 2011 Delegate Assembly established a national policy on this issue, that urges the federal government to grant flexibility to school districts to establish preschool programs for all three and four year olds through a separate funding stream, that develops, coordinates, and enhances the quality and availability of preschool programs. NSBA also supports pre-kindergarten-16 collaboration among the various sectors of education and with business, industry, and government to enhance teaching and learning opportunities so that all students are prepared to live in and contribute to a vibrant society.

In reviewing the draft criteria for the RTT-ELC grant, NSBA has identified provisions that could dramatically impact local school districts and undermine their effectiveness as providers of Pre-K services and as K-12 educators in those states that receive funds. Therefore, NSBA believes that it is crucial that these concerns be addressed in the final criteria. Key revisions include:

1. Incorporate local school district governance in the process of applying for and implementing RTT-ELC grants. Draft Performance Measures require state applicants to demonstrate commitment from a broad group of stakeholders and local communities through letters of support, MOUs, etc., but local education agencies (LEAs) are not mentioned. Of the many stakeholder categories identified in the draft (including state early childhood advisory councils, early childhood educators, education association leaders, family and community organizations and a broad range of early learning administrators and advocates) school district governance representatives such as school boards are absent. We note that state early childhood advisory councils are required to have an LEA representative as a member. However, it is critical that local school boards have a meaningful role in the application process and implementation of the grant given the potential and widespread impact on K-12 education. See #2 and #3 for further explanation.

2. Assure balanced representation of early childhood and K-12 participation in RTT-ELC grants. Invitational Priority 4 in the draft states that the Department of Education is particularly interested in state applications describing how the state plans to “sustain and build upon early learning outcomes throughout the early elementary years,” including how the state will 1) enhance current K-3 standards for all domains of school readiness, 2) ensure transition planning between early learning and the early grades, including family engagement, and 3) increase the percentage of children who are able to read and do mathematics at the end of third grade.

The potential statewide impact of this priority on local school districts is immense and calls for robust representation of local school boards in the application and implementation process. For states in the process of implementing Common Core State Standards for literacy and math, active involvement by LEAs is even more important to prevent duplicative and possible contradictory efforts.

3. Eliminate the requirement for re-directing existing education funds: Draft Performance Measures require state applications for RTT-ELC funding to provide a budget that demonstrates how resources will be repurposed or reallocated from other Federal, State, private and local sources, including Title I and IDEA. The wording of the section suggests that redirection of funds is mandatory. NSBA recommends maintaining flexibility for states and school districts with regard to federal education funds and opposes a mandate to repurpose or reallocate in order to qualify for the RTT-ELC grant. Programs such as Title I are already underfunded and these hard economic times have jeopardized local school district resources at the local, state and federal level. Repurposing education funds for the RTT-ELC grant could become a long-term, if not permanent obligation of funds to sustain the program when RTT-ELC funding has been spent. LEAs should not be put in the position of sacrificing services and programs for high need children in their districts as a result of a state’s decision to apply for short-term, one-time funds.

The pivotal role of local school districts in children’s achievement in school and in life means that the success of the RTT-ELC will depend on the involvement of K-12 providers and leaders. NSBA would be happy to provide additional suggestions to enhance the collaboration between local school districts and others to assure mutual success. Questions regarding our concerns may be directed to Lucy Gettman, director of federal programs at 703-838-6763; or by e-mail at lgettman@nsba.org.

Sincerely,

Michael Resnick
Associate Director

The National Association for the Education of Young Children (NAEYC) and many other organizations made recommendations for the state applications for the Race to the Top-Early Learning Challenge grant competition, taking a comprehensive approach, “looking at state examples and to the research of child development and learning on what children and families need and how programs can effectively and appropriately help them be successful” in their June 3, 2011 letter to the Secretary of the Department of Health & Human Services, Kathleen Sebelius, and Secretary of Department of Education, Arne Duncan.
It’s clear that accurate assessment in preK is not done with paper and pencil. “The current state of child assessment remains as stated by the NAS in Eager to Learn 'in flux.' While progress has been made in the development of valid and reliable assessments for young children, program evaluation, and teacher-child interaction, the NAS also states in its 2008 report that there is a great need for additional research and development.”
The letter also states that “substantial caution is needed when assessments are used for accountability purposes in programs with young children. Cautions must include using change scores so that assessments reflect children’s progress and program input, and do not penalize programs that serve the highest risk children (whose assessment scores at any one point in time will reflect their risk status).”
And “Most importantly, reviews of the research on assessments for young children make clear that assessments conducted for purposes of accountability should be used to strengthen programs.”
See the details on assessment of young children in the Appendix – Child Assessment pgs 9-11 http://www.naeyc.org/files/naeyc/file/policy/federal/RTT-ELC_Letter_and_...

The warnings of NAEYC must be heeded. The critical question on assessment will be how to ensure that states do not reduce to paper and pencil or other narrowly constructed assessments, perhaps with an overemphasis on formal academics linked to the new national reading and math standards. Doing so will significantly damage early childhood programs. States that are not very clear that they will implement comprehensive assessments, to be conducted in developmentally appropriate ways by teachers, should not receive awards - and this point should be clear in the application information. States should be barred from using any of this RTTT information for high-stakes accountability purposes, but rather used for program improvement.