Race to the Top District Competition Draft

Public Comment Section for Race to the Top District Executive Summary Now Closed

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 Race to the Top District (RTT-D) competition.

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

Please check our RTT-D Program page for updates.

Thank you


Thank you for your interest in the Race to the Top – District (RTT-D) Program. Like the Race to the Top State program, the Race to the Top – District Program is designed to encourage unprecedented innovation and bold comprehensive reform in elementary and secondary education.

In order to run a rigorous competition and obligate funds to grantees before the December 31, 2012 statutory deadline, the Department of Education (Department) will waive rulemaking for this new program, pursuant to its authority in the General Education Provisions Act.

However, because the Department is very interested in your input, we are posting this draft executive summary of the draft requirements, priorities, selection criteria, and definitions for the Race to the Top District competition on this Web site. We encourage all interested parties to submit opinions, ideas, suggestions, and comments pertaining to the Race to the Top District program. This document will be posted for public input until 5:00 PM EDT on Friday, June 8, 2012, 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. Though the Department will not respond to comments, the Department will read and consider all comments in finalizing the Race to the Top District competition design. Later this summer we will publish a notice of final requirements, priorities, selection criteria, and definitions in the Federal Register along with a notice inviting applications.

The Race to the Top District competition will build on the lessons learned from the State-level competitions and support bold, locally directed improvements in teaching and learning that will directly improve student achievement and teacher effectiveness. More specifically, Race to the Top District will reward those LEAs that have the leadership and vision to implement the strategies, structures and systems of support to move beyond one-size–fits-all models of schooling, which have struggled to produce excellence and equity for all children, to personalized, student-focused approaches to teaching and learning that will use collaborative, data-based strategies and 21st century tools to deliver instruction and supports tailored to the needs and goals of each student, with the goal of enabling all students to graduate college- and career-ready.

Successful LEAs will provide the information, tools, and supports that enable teachers to truly differentiate instruction and meet the needs of each child. These LEAs will have the policy and systems infrastructure, capacity, and culture to enable teachers, teacher teams and school leaders to continuously focus on improving individual student achievement. They will organize around the goal of each child demonstrating content and skills mastery and credentialing required for college and career and will allow students significantly more freedom to study and advance at their own pace - both in and out of school. As importantly, they will create opportunities for students to identify and pursue areas of personal passion-- all of this occurring in the context of ensuring that each student demonstrates mastery in critical areas identified in college- and career ready standards. LEAs successfully implementing this approach to teaching and learning will lay the modern blueprint for raising student achievement, decreasing the achievement gap across student groups, and increasing the rates at which students graduate from high school prepared for college and careers

The Department is posting this document on a moderated site, which means that all posts will be reviewed before they are posted. We intend to post all responsive submission on a timely basis. The Department reserves the right to withhold comments that are: unrelated to this request, inconsistent with the Department's Web site policies, advertisements or endorsements and/or otherwise inappropriate. 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 Race to the Top District competition and program, and should be as specific as possible. We ask that you limit your post to 2,000 words. All opinions, ideas, suggestions, and comments are considered informal input and, again, the Department 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 your post may or may not be reflected in the final Race to the Top District requirements, priorities, selection criteria, or definitions or other policies that are announced in the Race to the Top District notice inviting applications.

Comments

The Lawyers' Committee for Civil Rights Under Law, a non-partisan, non-profit organization formed in 1963 at the request of President John F. Kennedy to involve the private bar in providing legal services to address racial discrimination would like to submit these comments in response to the draft executive summary of the draft requirements, priorities, selection criteria, and definitions for the Race to the Top District Competition. As part of the Lawyers' Committee's mission to ensure equal opportunity, particularly for African Americans and other communities of color, we firmly believe that every child must have equal access to a rich, comprehensive, and diverse educational experience. Race to the Top presents a unique opportunity to provide incentives to state and local leaders to work together on ambitious reforms and develop comprehensive plans that enhance local policies, modernize school practices, and improve educational outcomes for students. We are fully in support of the National Coalition on School Diversity's request that diversity be prioritized in the Race to the Top District Competition criteria. The importance of promoting integration and avoiding racial isolation has been reaffirmed as a compelling government interest by five Justices of the U.S. Supreme Court in Parents Involved in Community Schools v. Seattle School District #11, and by the Department itself in its December 2011 Guidance on the Voluntary Use of Race to Achieve Diversity and Avoid Racial Isolation in Elementary and Secondary Schools2 report issued jointly with the U.S. Department of Justice. We recognize the challenges in creating and maintaining racial and economic diversity. However, we believe that it is inappropriate to use federal funds to perpetuate racial and economic isolation in our public schools. At the very least, new federal funds should incentivize local efforts and to promote diversity.

In addition to our support for the promotion of diverse and integrated learning environments, we are also in support of prioritizing parental engagement as a vital mechanism for improving school diversity. While we recognize and commend the Department's inclusion of criteria involving stakeholder engagement and support, we are concerned that the Race to the Top District competition proposal, the most important new source of federal funding for schools, lacks a clear commitment to parental engagement.

Parental engagement is an essential component of school success.3 Parental involvement has been closely linked to effective school turnaround strategies, greater student achievement, and improved school attendance.3 Parental engagement also contributes to greater school readiness, improved student social skills, and higher graduation rates.3 The Department has previously identified parental engagement as a core component of school reform.4 In the blueprint for revising the Elementary and Secondary Education Act (ESEA), the Department stressed the importance of strengthening and supporting comprehensive planning that promoted systematic inclusion of parents and communities as partners; enhancing district capacity around family engagement; providing additional resources, expanding grant opportunities, and providing other financial incentives to create programs that promote family and community engagement; and identifying and supporting best practices that focus on engagement strategies that increase student achievement.5 Yet, this acknowledged interest in family engagement is mostly absent from the draft criteria of the Race to the Top District Competition.

Effective parent engagement strategies must be part of any comprehensive education plan and not simply voluntary or encouraged. Parents should be fully informed, not only of their right to ensure that their child is receiving a high-quality education, but also of their responsibilities in creating an enriched learning environment outside the classroom. We urge the Department to adopt measures that prioritize and encourage parental engagement in all schools, and provide the proper resources, incentives and guidance for schools. Any new federal funds should incentivize local efforts to promote and prioritize innovative educational approaches that merge educational reform and the compelling need for parental engagement. LEAs and regional groups of LEAs are in an optimal position to effectively promote parental engagement. They can institute school, district, and inter-district policies that foster meaningful parental involvement, monitor levels of parental engagement at the school-level and the classroom-level, and proactively address unique issues that arise when striving to include parents in the school decision-making process.

In accordance with these general comments, there are several provisions which we believe the Department of Education should include in the final competition design. They are as follows:

  • As an Absolute Priority, panels that are responsible for reviewing LEA applications during the peer review process must include a critical mass of parents and members of the local community.
  • As an Absolute Priority 1: Personalized Learning Environment, the Department should add that an LEA's application must coherently or comprehensively address how it will implement strategies that:
    1. (1) Provide parents with meaningful opportunities to be engaged in their child's education, including involvement in school decision-making processes, and meaningful communication with school staff.
    2. (2) Monitor and track district and school efforts to enhance parental and community involvement.
  • As a Competitive Preference Priority, in addition to the points allocated for providing family and student supports, the Department should also consider:
    1. Whether the applicant has formed a coherent and sustainable partnership with all types of parents, as well as public and private organizations, such as local PTA's or other parent groups to support the plan described in Absolute Priority 1.
  • Under Selection Criteria: District Capacity and Success Factors - Reform Conditions, the third articulated goal of "meaningful stakeholder engagement and support" should be modified to explicitly say "meaningful parent, community, and stakeholder engagement and support." Additionally, the Department should include:
    1. A clear definition of what constitutes "meaningful parent, community, and stakeholder engagement and support."
    2. A detailed description of how LEA's can demonstrate ways in which families, teachers, principals, and community members have been engaged in the development of the proposal and, as appropriate, how the proposal has been revised based on their engagement and feedback; including:
      1. Making letters of support from key stakeholders, parents, parent organization, and local and civic community organizations mandatory,
      2. Mandating that parental and community feedback be included in the LEA's application, and
      3. If an LEA fails to provide letters of support, or evidence of parental and community feedback, LEA's must provide a detailed description of why letters of support orfeedback were not provided.

Thank you for the opportunity to present these comments. The RTT-D competition presents a unique opportunity to creatively address challenges within our public education system. We urge the Department to include changes to the RTT-D competition criteria that reflect a commitment to parental engagement. This necessitates clearly defined standards and guidelines, and not simply encouragement from the federal government.

Please contact us if you have any remaining questions or need additional information. We would welcome the opportunity to work with the Department on the issues addressed in this letter.

Sincerely,
Tanya Clay House
Director of Public Policy
______________________
1 551 U.S. 701 (2007).
2 http://www2.ed.gov/about/offices/list/ocr/docs/guidance-ese-201111.pdf.
3 The Condition of Education, 2012, National Center for Education Statistics: Institute of Educational Sciences,
May 24, 2012, http://nces.ed.gov/programs/coe/indicator_pfi.asp
4 Jeynes, W. H., The Relationship Between Parental Involvement and Urban Secondary School Student Academic
Achievement: A meta-analysis. Urban Education, Vol. 42 (2007), 82-110.
5 U.S. Department of Education, ESEA Reauthorization: A Blueprint for Reform, (March 13, 2010,
http://www2.ed.gov/policy/elsec/leg/blueprint/index.html).

Comments of the Council of the Great City Schools on District Race To The Top Requirements and Grant Selection Criteria

The Council of the Great City Schools, the nation's primary coalition of large urban school districts, supports the Department of Education's emphasis in the proposed District Race to the Top (D-RTTT) requirements on teaching and learning. Implementation of the rigorous Common Core Standards and their related assessments is the most critical challenge currently facing our urban schools along with ensuring that disadvantaged and minority students are learning this accelerated content at rates that will overcome persistent achievement gaps.

The four areas of reform in the RTTT authorization stress the importance of raising content standards; creating assessment and data systems necessary to track, adapt, and evaluate performance; enhancing the effective teaching of academic content -- often the weakest link in education reform initiatives -- and ensuring that the lowest performing schools and students do not continue to struggle.

The District RTTT Program provides an important opportunity for additional investment in local systemic reform activities not otherwise available in the current environment of declining state and local resources and shortchanged in ESEA and IDEA funding levels.

Additional Areas of Support in D-RTTT Requirements
In this national competitive education-reform initiative, the Council also supports a number of the quality, scope, and impact requirements in the proposed D-RTTT package, including:

  • awarding only high-quality local applications without a specific quota or additional competitive points being awarded to any of the four funding slates (p. 2 in Absolute Priority 2-5);
  • allowing applications from a consortium of LEAs (p. 1)
  • allowing participation in only one D-RTTT application (p. 1);
  • demonstrating a four-year track record of improving student outcomes, closing achievement gaps, and having a student data system to support instructional decision-making (p. 2 in Eligibility Criteria 4, and p. 5 in Selection Criteria B.1)
  • allowing applicants to focus reform activities on a particular segment of the school district given the limitations in funding (p. 1 in Eligibility Criteria 1.a, and p. 6 in Selection Criteria B.4.a);
  • setting a minimum service population of at least 2,500 students (p. 2 in Eligibility Criteria 2);
  • setting a minimum low-income level of at least 40 percent on the free and reduced price lunch metric (p. 2 in Eligibility Criteria 3)
    [The Council would prefer a 50 percent FRPL requirement, since 40 percent FRPL is less than the current national average and the FRPL metric serves as a proxy for the full range of disadvantaged and minority school children who are projected to soon become a majority of the nation's student population.]

The following comments from the Council of the Great City Schools emphasize one overriding concern in the proposed application requirements, and provide a number of additional suggestions to strengthen the operation and impact of the D-RTTT initiative.

Diversion of Effort from the Four RTTT Reform Areas Into Tangential New Priorities

School districts should be allow to maximize this new funding opportunity by addressing the RTTT reform areas in the context of their own local systemic improvement and academic reform efforts without being channeled into new or tangential directions by D-RTTT application requirements and review criteria. In our opinion, the absolute and competitive priorities on personalized learning plans and wrap-around services are entirely new directions (not reflected in the original RTTT authorization), which could result in school district attention, resources, and efforts being diverted away from higher academic standards, expanded data and assessment systems, curriculum upgrades, revised instructional approaches, and new accountability measures now actively underway in reform-minded school districts.

Addressing both the absolute and competitive priority criteria in a D-RTTT project will be a practical necessity -- not a choice -- in order to receive a grant under the proposed rules. Districts will likely have to set up elaborate systems and procedures to meet the absolute requirement of an "individual learning plan" for each student, as well as to identify, integrate, and case-manage a variety of non-academic services for a student and a student's family. Some districts may want to apply for these particular personalized approaches and should be allowed to do so. But other districts that are committed to other approaches for increasing academic rigor, training teachers and principals, tracking performance, and revising instructional delivery systems should be able to propose their best thinking in the four RTTT reform areas without narrowing their reforms to fit prescriptive parameters of the proposed personalized learning and integrated services priorities. Moreover, there is limited research on the effectiveness of these practices to warrant these particular two priorities being implemented on a national scale.

High-quality differentiated instruction can be delivered effectively, and appropriate student interventions can be provided without mandating the "personalized learning" in the proposed D-RTTT requirements. For example, a large segment of special educators acknowledge that the No Child Left Behind subgroup performance and accountability system produced more significant academic progress for students with disabilities over the past decade than three decades of individualized education plans (IEPs) and prescriptive IDEA procedural requirements. A new study to be issued this summer by the Council of the Great City Schools and the American Institutes for Research shows that improvements in teaching and student achievement will not automatically result when timely student-performance information on interim assessments are available unless practitioners pay particular attention to specific instructional strategies and teaching skills that are informed by the data. The Council is concerned that the proposed D-RTTT personalized learning systems and individual student learning plans may add formalities and procedures to the instructional process without directly affecting the quality of teaching or student outcomes.

With only 20 grants being awarded, the D-RTTT initiative should support a wider variety of approaches to local systemic reform without narrowing district options under the proposed absolute and competitive priorities.

Recommendation: Delete the absolute priority on personalized learning and the competitive priority on integrated community services, in favor of more flexible approaches to the four reform areas of RTTT. Also, delete each of the selection criteria and subcriteria associated with the current absolute and competitive priorities.

Union Support as Part of Stakeholder Engagement and Support, Not as a Condition of Eligibility

A number of Council districts have expressed concern over union reticence to fully support and participate in a RTTT project. Similar issues arose in a number of districts during the State RTTT application process. The proposed D-RTTT requirements include the signature of the local union along with the signatures of the district superintendent and school board as a condition of eligibility. The superintendent and school board are legal representatives of the school district as a unit of local government -- the union is not. The Council finds it inappropriate for any non-government official to be delegated any aspect of control over the eligibility or ineligibility of a school district in the application for a federal grant. The Council suggests that the selection criteria for Meaningful Stakeholder Engagement and Support be weighted to reflect the importance of this criterion -- possibly with additional points for union support. The Council also finds that a 70 percent support level among teachers in LEAs without collective bargaining is unnecessarily high, and suggests majority support.

Recommendation: Strike paragraph 5 in the Eligibility Criteria on page 2, and appropriately weigh the Stakeholder Engagement and Support criterion in paragraph 3 under Reform Conditions in Selection Criteria B.3 on page 5. Also, on page 5 in Selection Criteria B.3.a.ii, strike "at least 70 percent" and insert "a majority".

Delete Mayor, County Executive, and Township Administrator Comment and Response, and Revise State Comment Documentation Requirement

Many school districts serve multiple local communities headed by a variety of mayors or township administrators, as well as county executives. Securing formal comments from each of these officials is burdensome and of questionable benefit. The stakeholder engagement and support requirements in Selection Criteria B.3.b should suffice in ensuring the involvement of appropriate local elected officials. At the state level, a school district should not be required to document that the State "declined" to comment – it should be sufficient to provide evidence that the State was provided with the opportunity to comment for at least five business days.

Recommendation: On page 2 under State Comment Period, paragraph 1, subparagraph a., strike "evidence that the State declined to comment" and insert "evidence that the State was given five business days in which to comment." And, on page 2, paragraph 2, strike the Mayor, City or Town Administrator Comment Period entirely.

Increase Emphasis on Districtwide Systemic Impact

Given the limited amount of funding available for each D-RTTT project, the Council supports allowing a district to focus RTTT funding on particular segments or portions of the school system. RTTT, however, is a systemic reform initiative. D-RTTT should demonstrate how the funded activities contribute to districtwide reform. The Council suggests consolidating the various subcriteria addressing districtwide systemic reform into the Vision Selection Criteria A, in order to fully explain the overall impact of the project's activities.

Recommendation: Relocate Selection Criteria B.4.d regarding districtwide change on page 6 as a new paragraph 3 under Vision Selection Criteria A on page 4.

Consolidate Selection Criteria and Subcriteria for Easier Application Development and Peer Review

The proposed D-RTTT requirements set out an extensive range of selection criteria, which will result in review points being diffused among far too many provisions. The Council suggests consolidating and streamlining many of the criteria and subcriteria and allow the peer reviewers to focus on the most critical reform issues and activities. The Council's recommendation to remove the multiple requirements and related criteria/subcriteria on personalized learning (see above) also will substantially streamline the application package.

Recommendation: The Council suggests wherever possible to use assurances instead of specific requirements in the selection criteria (e.g., the salary and expenditure information under Selection Criteria B.2 on page 5). Consolidate Selection Criteria D on Transition Plan and Continuous Improvement on page 10, and the accessibility and credit earning options in Selection Criteria C.3.a on page 11 into the "high quality plan" criteria under Selection Criteria B.4 on page 5-6.

Revise Funding Ranges to Better Reflect the Varying Sizes of School Districts, and Increase the Number of Available Grants

The funding structure of the proposed D-RTTT grants is flawed. A district or consortia serving 2,500 students could receive up to $20 million, while a district serving hundreds of thousands of students is limited to receiving $25 million. In effect, a district of 100,000 students -- which is 40 times larger than a district serving 2,500 students -- could receive only $5 million in additional funding. Any funding structure will have some weaknesses, but the proposed structure is not equitable. The lower end of the funding structure should be lowered; the middle range should be adjusted; and the upper end should be increased. By lowering the lower range of grants, more grants can be awarded with available D-RTTT funding.

Recommendation: $2.5 to $10 million for 2,500 – 5,000 students. $10 to $20 million for 5,000 to 20,000 students. $20 to $30 million for 20,000 or more students.

Superintendent Evaluation and School Board Evaluation Requirements May Be Superfluous

The impact and appropriateness of an evaluation of a School Board, which is the legal authority of most school districts as units of local government, seems questionable – particularly for elected school boards. Additionally, most urban school boards already establish evaluative criteria for their superintendents.

Clarification Needed on Requirement for an Over-Representation Remedial Plan

School districts will be uncertain about whether they must meet the program requirement regarding over-representation on page 13. The final D-RTTT requirements should clarify the precise basis for a district being required to undergo an assessment and develop a plan regarding over-representation (see Program Requirements in paragraph 4 on page 13). If there is no official notice or criteria provided for school districts, then this requirement should be made into an assurance. The district would assure that if over-representation is determined during the D-RTTT grant period, an assessment and remedial plan would be developed and implemented.

Jeff Simering, Council of the Great City Schools

The National Education Association appreciates the opportunity to provide comments on the Race to the Top District Competition Draft dated May 21, 2012. While NEA remains concerned about the use of competitive funding programs to advance education goals, we support the broad concept of allowing districts to apply for Race to the Top (RTTT) funds for the first time in this competition.

We also strongly support the requirement that key stakeholders, such as educators and their representatives, must support districts’ plans. The involvement of those who work in our schools in the development and implementation of this program will bring experience and expertise to its design and greatly increase capacity for success.

We are sympathetic to the broad concept of advancing personalized learning through this competition, as long as it is promoted without unnecessary requirements, and with sustained fiscal support, a clear chance of success, and local stakeholder support. With so many schools struggling financially around the country, and meeting so many demands for change – such as stronger standards and assessments and the requirements of the state waiver programs – great attention should be paid to make sure that any new proposal has a clear focus and does not impose unnecessary burdens that might tilt the scales against applicants that have the fewest resources and serve the poorest students. In this regard, we would urge the Department of Education to consider whether its heavy emphasis on its existing RTTT reform proposals in the competition might be reduced in favor of prioritizing personalized learning and innovation.

NEA’s comments on the specifics of the proposal follow:

ELIGIBILITY CRITERIA AND APPLICATION REQUIREMENTS

• We believe that the minimum of 2,500 participating students in a district will exclude individual districts that could succeed in advancing personalized learning from applying, requiring them to at best seek out a consortium in spite of their own unique problems, strengths, and goals. Moreover, the coordination of an ambitious RTTT-D program among a number of small and often geographically isolated LEAs that could comprise such a consortium may require human and time resources that are not readily available in smaller systems, especially when coupled with the proposal’s complex data infrastructure requirements.

• We recommend deletion of the eligibility and application requirement of a “clear track record of commitment to the core educational assurance areas,” including designing and implementing a teacher evaluation system as defined by the department. This criterion will tilt the scales against non-RTTT states, dilute the focus on personalized learning, and make it difficult for schools with the fewest resources and the greatest challenges to apply.

• We applaud the requirement of a local union/association president signature on the application and urge that it be required even in the absence of collective bargaining to ensure the support of key stakeholders during the critical implementation process, and bolstering the district’s capacity for success. We also applaud the requirement of signatures from all union/association presidents on Memoranda of Understanding (MOUs) with consortium participants. We believe this provision could be strengthened through the inclusion of a requirement that unions/associations be involved in the development of MOUs.

• To the extent charter school LEAs are considered for grants, we have several concerns. Charter sector accountability and transparency remain weak and inadequate in at least some important respects in most states. The Southern Regional Education Board’s recently issued report, Charter Schools in SREB States: Critical Questions and Next Steps, offers recommendations for how states can do more to ensure academic quality and adequate oversight. Among those we believe merit consideration are policies that:
o require charter contracts to include meaningful measures of academic performance and also specify the types of measures that most accurately gauge the academic growth of charter school students. In addition, state policy-makers should continually review how well these measures gauge academic growth and attempt to improve them.
o ensure that all authorizers establish clear and rigorous guidelines and procedures for charter school application reviews and ongoing charter school oversight. Authorizers must establish specific, rigorous criteria for the continuation and renewal or revocation of charter school contracts and must aggressively hold charter schools to those criteria. States and authorizers must also close poorly performing charter schools that fail to improve over time.
o ensure that charter school authorizers have the capacity to support a rigorous, high quality application review process, and to provide rigorous oversight while respecting charter schools’ autonomy. If states maintain small authorizers with limited capacities, policy-makers should consider ways to aid small authorizers by extending the expertise and abilities of larger authorizers to the oversight.

o ensure that authorizers rigorously review every charter school at regular intervals (as determined by each state). This is important to ensure that poorly performing schools either make improvements or are closed within a reasonable period of time.

The federal government can incentivize states to adopt these and other accountability and transparency-enhancing policies by requiring that charter LEAs eligible for this RTTT funding be located in states adopting specified policies such as these.

• We support giving stakeholders in states and towns opportunities to comment, but recommend that attention be given to how to make that practical when a district includes a significant number of townships and boroughs.

• To the extent teacher evaluation is required in this proposal, evaluations should be comprehensive – based on multiple indicators to provide teachers with clear and actionable feedback to enhance their practice – and should include all three of the following components: (i) Indicators of Teacher Practice demonstrating a teacher’s subject matter knowledge, skill in planning and delivering instruction that engages students, ability to address issues of equity and diversity, and ability to monitor and assess student learning and adjust instruction accordingly; (ii) Indicators of Teacher Contribution and Growth demonstrating a teacher’s professional growth and contribution to a school’s and/or district’s success; and (iii) Indicators of Contribution to Student Learning and Growth demonstrating a teacher’s impact on student learning and growth. Such indicators must be authentic, reflect that there are multiple factors that impact a student’s learning beyond a teacher’s control, and be agreed to by the local union/association. Unless tests are shown to be developmentally appropriate, scientifically valid, and reliable for the purpose of measuring both student learning and a teacher’s performance, such tests should not be used to support any employment action against a teacher and may be used only to provide non-evaluative formative feedback.

• In the definition of student growth on page 18, we recommend adding “multiple” before “measures” in numbered paragraph one, and “multiple” before “alternative measures” in numbered paragraph two. In the definition of teacher evaluation, we applaud the inclusion of the phrase “multiple valid measures.”

• With regard to student growth, we encourage the Department to support maximum flexibility in how student growth measures are included in such systems when providing guidance to potential grantees, when approving grant applications, and when providing post-award guidance and technical assistance to grantees because in some jurisdictions student growth measures are bargained or agreed upon by all parties. Another major concern is that many of the teacher evaluation systems currently are being implemented without being piloted, field-tested, or validated and we encourage the Department to focus on those grantees that build in such rich feedback systems in early implementation phases. Furthermore, we urge the Department to stress the importance of evaluation systems being implemented with fidelity and without gimmicks such as some teachers’ evaluations being based on the student growth of other teachers.

ABSOLUTE PRIORITIES

• NEA believes that promoting innovation around personalized learning is an important education goal. One key component in personalized learning is the support of educators who provide the personalized learning, which we hope will receive support through this competition, including use of funds to recall or hire much-needed teachers, education support professionals, and specialized instructional support personnel to advance personalized instruction.

• NEA also applauds the goal of Priorities 2-5 of ensuring a diverse group of RTTT and non-RTTT applications, as well as rural and non-rural applications.

SELECTION CRITERIA

Vision

• The requirement that applicants set forth a “comprehensive and coherent reform vision that builds on its work in the four core educational assurance areas” takes away from the focus on personalized learning and puts the focus on long-standing RTTT reforms. This ignores the reality that sustained personalized learning as described in the proposal will in and of itself be a heavy lift for districts and staff. It also heavily disadvantages non-RTTT state applicants.

• The inclusion of teacher attendance as a “vision” factor seems anomalous, and the definition of teacher attendance could discourage protected collective bargaining activity.

District Capacity

• Requiring districts to demonstrate a “clear record of success in advancing excellence,” means that districts with the greatest need could find it difficult to receive grant funds. The result will be that RTTT-D funds flow to the districts that already have relatively high capacity rather than to those with greatest need.

• We would urge the Department to emphasize that the proposed competition allows a lower-capacity district to partner with a higher-capacity district to build functionality and capacity. Some districts have significant capacity to personalize learning opportunities for all students; encouraging these districts to work with a struggling district and use RTTT-D funds to collaborate may be an effective way to improve the education of students in struggling schools and provide valuable lessons for all involved districts about student learning.

• The proposed rules evaluate applicants, in part, on their ability to implement one of the four school intervention models in low-performing schools; however, some districts have no reason or requirement to implement one of the four school intervention models. Furthermore, the RTTT-D proposed rules do not ask applicants to implement an intervention model. Therefore, the requirement that a district demonstrate their ability to implement one of the four models does not seem strongly related to the goal of this proposed competition.

• We encourage the Department to clarify for privacy reasons that the required data transparency around salaries will be adjusted so that personally identifiable financial information will not be available publicly.

• We strongly support the encouragement of meaningful engagement and support of stakeholders in the proposed rules, including support from educators and their representatives in LEAs with collective bargaining, and 70 percent support of educators in participating schools in LEAs without collective bargaining (not just the teachers, but all affected educators). The involvement of local stakeholders will bring expertise and experience to proposed personalized learning plans, and help promote solutions tailored to the unique circumstances of individual schools and students.

Preparing Students for College and Careers

• The proposal includes a number of proposed new local decision-making structures, including “professional teams or communities” that e.g. “improve educators’ practice by using feedback provided by the LEA’s teacher and principal evaluation system,” and also “school leadership teams” that have “sufficient flexibility and autonomy over such factors as school schedules and calendars, school staffing models, roles and responsibilities for educators and non-educators, and school-level budgets.” These decision-making structures raise important issues with regard to school autonomy, existing decision-making structures, and collective bargaining. Their inclusion in this proposal, along with the significant changes envisioned in teacher responsibilities (e.g. creation of digital learning content and personalized learning plans) highlight the need for union/association and educator support that appear in other parts of the Department’s proposal.

• We also encourage the inclusion of a Savings Clause for rights under federal, state and local law as well as collective bargaining, similar to the one included in the Department’s waiver principles.

Policy and Infrastructure

• The proposal promotes “the opportunity for students to progress and earn credit based on demonstrated mastery, not the amount of time spent on a topic.” This concept should be further studied by the Department in light of core content standards assigned to each grade level and state tests which measure specific skills at each grade level.

• The proposal calls upon LEAs and schools to support personalized learning through, among other things, “Ensuring that all participating students, parents, educators and other stakeholders (as appropriate and relevant to students’ teaching and learning) have equitable and sustainable access, regardless of income, to content, tools, and other learning resources both in-school and out-of-school.” Ensuring equitable access for parents is an important ideal but a complicated task for schools, and provides further evidence that other RTTT reform requirement’s unrelated to personalized learning should be pared back to allow for important efforts like helping parents.

• We would urge the Department to further spell out and address the privacy implications of creating data systems that “provide the capability for parents and students to export their information in an open data format.” What data will be exportable, and how will it be protected from a FERPA standpoint?

• An important infrastructure improvement that should be advanced by this proposal is small class size, which promotes personalized attention and instruction. Efforts to decrease class size should be explicitly encouraged and supported by this competition.

Budget and Sustainability

We urge modification of the requirement that “the applicant has a high-quality plan for sustainability of the project’s goals after the term of the grant, including a 3-year post-grant budget (including budget assumptions, potential sources, and uses of funds).” There are in many districts no additional funds for this post-grant period. Districts that are already looking at major cuts will need to shift money away from other priorities to maintain the goal of a program that was federally funded for one year.

Optional Budget Supplement

NEA supports the optional budget supplement that allows for greater flexibility. Initiatives in the area of early learning, full day kindergarten, dropout prevention, community schools, and other important areas should be encouraged in this proposal.

COMPETITIVE PREFERENCE PRIORITY—RESULTS, RESOURCE ALIGNMENT, AND INTEGRATED SERVICES

We support the effort to promote sustainable partnerships with a wide range of outside groups to augment school resources and provide “additional student and family supports, such as addressing the social-emotional, behavioral and other needs of the participating in students.”

CONCLUSION

The NEA respectfully submits these comments.

Donna M. Harris-Aikens
Director, NEA Education Policy and Practice

Dear Secretary Duncan:

ZERO TO THREE appreciates the opportunity to comment on the Race to the Top District Competition proposed guidelines. ZERO TO THREE’s mission is to promote the healthy and positive development of infants and toddlers, particular those in the most vulnerable families. The path to later success in school and in life begins in the early years as the foundations are laid for all later learning. We believe school officials have a large stake in community efforts to ensure that the most at-risk young children receive early developmental support to help minimize the gaps that emerge even before they reach prekindergarten. Therefore, we are pleased that the eligibility criteria for the District Competition make clear that the early childhood period could be covered in a local grant application.

We offer a few suggestions for ensuring that any applicant choosing to include services for younger children incorporates this age group appropriately. First, it should be clear that when the early childhood age group is included, community-based organizations can be partners in the grant application, not simply providing assurances that they have been consulted. While Local Education Agencies (LEAs) in a few instances fund services for very young children, they very rarely are providers of services to the infant-toddler age group. Services, including Head Start, for children in the Prekindergarten age group also are most frequently provided by community-based organizations. In addition, as described below, early childhood activities in which LEAs or schools might engage to enhance opportunities for the young children feeding into their schools could include initiatives other than direct services, which also would call for community partners.

We also urge that the application clearly delineate the differences between early childhood, including the early elementary grades, and services for older children in the areas of developmentally appropriate curricula and teaching practices as well as evaluation and assessment. The various domains of development—including physical, language, social, and emotional—are inextricably related in young children. Nurturing relationships in the early years support the emotional health and social competence that provides the foundation for emerging cognitive abilities—the “bricks and mortar” for development. Therefore, we strongly recommend that applicants be required to assure that they will use a comprehensive curriculum for children in third grade and younger that addresses all domains of development. An understanding of how learning in very young children is facilitated, not instructed, should be infused into professional development opportunities for teachers working with the infant-toddler age group.

The types of measurements used to determine progress for school-age children above third grade as well as success for the schools they attend are not appropriate for the early childhood period. We strongly urge that the application require assurances that assessments of children in third grade and younger will conform with the recommendations of the National Academies of Sciences reports on child assessment and that such assessments will be used to improve teaching practices and support the development of individual children, not to make decisions about program funding. We also note that, as discussed above, some activities related to early care and learning undertaken through these grants could be more systems-focused and therefore metrics should make room for other ways of assessing their effectiveness.

We are pleased with the inclusion of the Competitive Preference Priority for integrating public and private resources, which has the potential to create strong partnerships between districts/schools and community-based early childhood providers. Such partnerships could be used as the umbrella under which activities to enhance early childhood services could occur. These activities could include initiatives other than direct services such as community early childhood needs assessments, facilitating the provision and follow-up on screening for early developmental delays and disabilities, or joint professional development. We believe this potential for early childhood partnerships could be heightened by requiring a description of how the resources provided through the partnership will be shared and will enhance the goals and activities described for the partnership. In addition, the submitting LEA should be required to obtain the signatures of all non-school partners on the application.

Once again, we thank you for including early learning as an option in this new effort to spur education reform within communities. We look forward to working with you to expand opportunities for supporting the development of our youngest children.

Sincerely,
Matthew E. Melmed
Executive Director

Below is an overview of suggested revisions:

1. Refocus from personalized learning to accelerating achievement for all levels of students and cultivating academic interests.

- Focus should be on accelerating the performance of all students, including high needs students. That does not necessarily mean that the tasks are personalized or different in all situations, but could instead mean that rich, high quality common tasks are used with personalized scaffolding for all students.

- The existing focus on adapting to students’ “personal interests” could be misleading; an improvement is to say “academic interests,” or “academic interests and academic perseverance.” Solely adapting to what kids personally enjoy doing is not likely to make a significant impact on learning outcomes.

- Overall the emphasis should be on tools producing substantial results in shorter time periods (acceleration) rather than on a particular method as the outcome. The focus should be on promoting a competition with defined requirements that encourages innovation to achieve results.

- Specifically, in literacy ensure that personalized learning does not exclude all students from having the opportunity to confront complex texts. In math, it should not prevent all students from engaging in the careful, sustained study of common, well-chosen problems (as high performing countries do).

2. Hone the metrics for “effective and highly effective” teachers by requiring districts to report them separately. Change the measure from teachers to whom students have daily access to “teacher or teachers of record”, where a teacher of record is defined by the district’s teacher evaluation system.

3. Explicitly identify technology as a force that can expand the reach of highly effective teachers, and explicitly identify class size limits as a barrier that needs to be removed.

4. Create a race by engaging an evaluation partner to refine common yardsticks and by issuing an annual report card on the progress that every district is making toward its goals. It would be best if the partner could embed data analysts in a representative number of districts. Require districts to invest in their side of providing data. Note that while the core measures will not change, the specific metrics may be refined to render them cheaper to execute, more comparable, and more reliable.

5. Help create pressure on districts to do good things on the way to application and provide a clearer guide to judges by awarding points for policies that:

- Identify highly effective teachers (even if a more fully developed teacher evaluation system is not yet in place)

- Allow highly effective teachers to have large class sizes or take on roles requiring greater responsibilities

- Allow highly effective teachers to earn higher pay than the regular salary schedule for reaching more students

- Practices that encourage collective work of teachers working in teams using data to improve and refine their work.

- Make blended learning viable

6. Add a section on demonstrating flexibility in budgeting processes to support innovation including the ability to:

- Flexibly invest in personnel and other resources to allow for hybrid learning environments

- Spend on diverse instructional resources, including technology, and not just textbooks

- Increase the class sizes and/or responsibilities of highly effective teachers and compensate them for their additional labor and contribution

- Shift resources in response to performance outcomes

7. Strengthening and expanding the reporting period for winners beyond the grant period

- Data system requirements should be that districts not only track a teacher-student match, but that they provide back data to teachers and their supervisors on student achievement gains.

- Metrics should be tracked by the DOE for five years, rather than three.

- In districts from RTTT-winning states, use SEA’s to calculate growth percentiles on the state tests and report those data.

- Districts should calculate the growth percentiles for each possible baseline score in the starting year of the grant. As long as the state did not change the tests, the reporting partner could use those same percentiles for measuring whether or not growth is "rising". In other words, the first year would ensure that the median student is achieving a growth percentile of 50. However, in subsequent years, that number could rise, if achievement is accelerating.

-----------------

Below are suggested revisions for individual sections in the executive summary:

BACKGROUND

Include the following paragraph at the end of the section

It is worth noting four key principles that drive this effort:

1. Accelerating achievement towards college readiness for different levels and types of students. The approaches taken should substantially accelerate all students’ learning by providing tools and supports that allow them to do excellent collective and individual work.

2. A focus on substantial rather than incremental results. Winning LEAs will pursue policies that promote significant, non-incremental increases in students’ performance.

3. Supporting model efforts of breakthrough performance based on policies and programs that can scale. Winning applications will clearly illustrate how efforts focused throughout districts or specific schools can be scaled to additional districts or additional schools within a district.

4. A focus on expanding student access to the highest performing teachers.

ELIGIBILITY CRITERIA

- Under subsection 4.b, include the following as a minimum requirement:"The ability to provide data back to teachers and their supervisors on student achievement gains"

APPLICATION REQUIREMENTS

- Under subsection 2, include the following as a minimum requirement: "The ability to provide data back to teachers and their supervisors on student achievement gains"

ABSOLUTE PRIORITIES

- Absolute Priority 1: Redefine as "Student Centered Learning Environments"

- Ensure that that Absolute Priority 1 includes a focus on accelerating the full variety of students through collective and individual work and interests.

SELECTION CRITERIA

- Sub-section A.1: Include that student and educator support should be "grounded in common tasks as well as individual academic interests."

- Sub-section A.2: Include the following as an area for focus: "Number and diversity of students who are taught by effective and highly effective teachers"

- Following Sub-section B.3: Include the following criteria related to budgeting:

4) Demonstrated flexibility in budgeting processes to support innovation including the ability to:

a) Flexibly invest in personnel and other resources to allow for hybrid learning environments

b) Spend on diverse instructional resources, including technology, and not just textbooks

c) Increase the class sizes of highly effective teachers and compensate them for their additional labor

d) Shift resources in response to performance outcomes.

- Sub-section C.4: Performance Measurement

- Ensure that the competition also funds an independent performance measurement partner that will support districts in providing comparable data around for these core measures.

- C.4.a should measure: The number and percentage of participating students, by subgroup (as defined by this document), whose teacher or teachers of record (as defined by the district’s teacher evaluation system) are effective and highly effective (as defined in Race to the Top and with access to effective and highly effective educators reported separately)

- C.4.c should measure: The number and percentage of participating students, by subgroup, whose academic performance substantially accelerates by such measures as who were not on-track at the beginning of the school year but who have caught up by the end of the school year based on the LEA on-track indicator (as defined in this document) and mean student achievement growth (i.e. mean student percentile growth or SPG using expected growth by prior score from the SEA) by grade and subject.

- C.4.d should be removed

- An a metric should be added to measure: The percentage of high school graduates enrolling in college (based on longitudinal matches done by the non-profit organization, National Student Clearinghouse)

Subsection D. Transition Plan and Continuous Improvement

D.2. should assess: Plan for increasing the number of students who receive instruction from effective and highly effective teachers and principals—including in hard-to-staff schools, subjects, and specialty areas, such as mathematics, science, and special education—through the meaningful use of technology to expand the reach of highly effective teachers and address the barriers created by class size limits

Subsection E. Budget and Sustainability

E.2. should instead measure the extent to which: The applicant has a high quality plan to pursue non-incremental improvements to student performance throughout the grant period. The Department will identify a performance measurement partner to refine common yardsticks, and will issue an annual report card on the progress every district is making toward its goals. That report card will consist of a small set of measures, based on student-level data made available to the reporting partner, and will be compiled for at least two additional years following the grant period.

E.2. The Department should use a common reporting partner to save districts the cost of finding an evaluator and to allow for more direct comparisons.

DEFINITIONS

Personalized learning plan should be defined as: A formal document, available in digital and other formats both in and out of school to students, parents, and teachers, that, at a minimum: establishes student learning goals based on academic and career objectives and academic interests; sequences content and skill development to achieve those learning goals and ensure that a student can graduate on-time college- and career-ready; and is updated based on information about student performance on a variety of activities and assessments that indicate progress towards goals.

Comments from: Susan Pimentel, Jason Zimba, David Coleman, Karen Hawley Miles

Hon. Arne Duncan
Secretary
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202
Submitted via internet comment at:
http://www.ed.gov/comment/reply/12250#comment-form

June 8, 2012

RE: Race to the Top District Draft Guidelines

Dear Secretary Duncan,

The NAACP Legal Defense and Educational Fund, Inc. (LDF) is pleased to submit the following comments in response to the Department of Education’s (ED) Executive Summary of Race to the Top – District competition (RTT-D).

All children, especially those from low-income homes, with disabilities, or with high needs, must have the opportunity to attend schools with peers from different backgrounds, feel safe and supported when in school, and have equal access to teachers who are fully-prepared and effective. We know that ED is committed to these goals, and we offer the following comments to strengthen RTT-D to support the challenging and necessary work to make these goals a reality.

The following comments focus on improving RTT-D by:

1. Promoting Diversity
2. Reducing Discipline Rates and Disparities
3. Ensuring Equity
4. Properly Training and Evaluating Teachers
5. Engaging Parents and Communities

1. Promoting Diversity

Through RTT-D, ED has a prime opportunity to promote diversity and reduce racial isolation in schools. The Supreme Court, in Parents Involved in Community Schools v. Seattle School District #1, and the Departments of Justice and Education, in their joint Guidance on the Voluntary Use of Race to Achieve Diversity and Avoid Racial Isolation in Elementary and Secondary Schools, continue to stand by the core teaching of Brown v. Board of Education that diversity provides deep and important civic and educational benefits to students. Indeed, ED highlighted diversity as one of its Supplemental Priorities for Discretionary Grant Programs announced by ED in December 2010. And, as you noted upon the release of joint guidance by the Departments of Education and Justice on promoting voluntary integration and diversity efforts, “[r]acial isolation remains far too common in America’s classrooms today and it is increasing . . . . This denies our children the experiences they need to succeed in a global economy, where employers, co-workers, and customers will be increasingly diverse. It also breeds educational inequity, which is inconsistent with America's core values.”

Yet, despite this overwhelming support for school diversity, there has been no mention of reducing racial isolation or promoting diversity through RTT or ED’s “flexibility” package. Notably, in RTT-D, students “who attend high-minority schools” are considered “high-needs students,” but there is no emphasis within the RTT-D guidelines to address the racial isolation that imperils students’ education.

ED should call on LEAs to diversify schools and support this work through RTT-D’s priorities, either as an absolute or competitive preference, as it suggested in its December 2010 Federal Register notice. Furthermore, we suggest that ED assess applications based, in part, on how applicants propose to reduce racial isolation and increase diversity in schools within RTT-D recipient districts. ED should also monitor the progress of RTT-D recipient districts in reducing racial isolation and increasing diversity in schools affected by RTT-D. Lastly, for schools that need intervention, the magnet school model offers an effective method of addressing the twin goals of increasing student academic performance and promoting diversity. Such models should be included in the options supported through RTT-D for turning around struggling schools.

In addition to these recommendations, please note that we also endorse the comments on Race to the Top-District submitted by the National Coalition on School Diversity.

2. Reducing Discipline Rates and Disparities

In the RTT-D Executive Summary, ED requires grantee districts with racial or disability-related disciplinary disparities to undergo an assessment and develop a plan to address the root causes of these disparities. We applaud and strongly support this requirement. Our nation’s disciplinary rates are double what they were in the 1970s despite overwhelming research on the academic, social, and fiscal harms of over-relying on exclusionary discipline. And as suspension and expulsion rates rise, racial disparities in discipline only continue to widen. We see these elements of a “School-to-Prison Pipeline” as incredibly damaging to our nation’s youth and deeply intertwined with the same issues of access and fairness at play in Brown. We commend ED for addressing racial and disability-related disciplinary disparities in RTT-D.

To extend this benefit to more students, we join our colleagues in the Dignity in Schools Campaign in urging ED to require not just grantees, but all applying districts, to undertake a needs assessment and develop a plan to address disciplinary disparities. The state-level Race to the Top competition required some states to make significant changes in law and policy in order to apply for grant funds. To the extent that ED is committed to using competitive grant programs as a key lever for change on matters affecting school pushout, such a catalyst should be used to aid students in districts that do not receive funding as well. Furthermore, we urge ED to require applying districts to set annual, measurable benchmarks for reductions in disparities and to require grantee districts with continued disparities to set aside fifteen percent of their remaining grant funds for implementation of evidence-based approaches to school discipline—a requirement similar to the Early Intervening Services provision of the Individuals with Disabilities Education Act (20 USC §1418(d)(2)). Research shows that implementing best practices that focus on inclusion rather than exclusion from school as a method of discipline can result in improved academic performance, student attendance, and perceptions of school safety.

Please note that we fully endorse the comments submitted by the Dignity in Schools Campaign on Race to the Top-District as well.

3. Ensuring Equity

Eligibility Criteria
We support ED’s focus on students from low-income homes and those with high needs. However, the requirement that 40% of participating students be from low-income households is simply too low. We fear that this low threshold will fail to properly direct RTT-D resources to the many students and schools that desperately need the additional support. We urge ED to raise the minimum percentage of students from low-income homes to be served by these funds.

Reform Conditions
Funding disparities, documented extensively in ED’s recent report on comparability, can hobble efforts to improve struggling schools. We applaud ED’s assessment of LEA transparency described on page five of the Executive Summary. Documenting funding disparities is a crucial first step to addressing one of the persistent divides in public education. Reporting, however, is not enough. RTT-D recipients must be required to address these disparities by instituting policy changes that close the funding gaps, and move the districts toward comparable funding for all schools within their purview.

Competitive Grants
Though we fully support the proposed focus on students living in poverty and high-needs students, we must note our fundamental disagreement with the method for distributing funds through RTT-D. Competitive funding, by definition, creates winners and losers. Though it may be useful for spurring innovation, competition is not a way to provide equitable educational opportunity to all children. If we truly hope to achieve equity in our education system, funding proposed for competitions such as RTT-D should be distributed more equitably as conditional incentives to LEAs and schools that commit to accomplish the measures noted in this letter.

4. Properly Training and Evaluating Teachers

Equitable Distribution of Fully Prepared and Effective Teachers
At the heart of any improvement of student performance is a teacher that is able to support student learning. To perform this critical work, beginning teachers must be fully-prepared (that is, teachers must have completed their training program prior to becoming a teacher-of-record) to work effectively with students beginning on their first day in the classroom. Unfortunately, our most vulnerable students typically have less access to such teachers. Despite a clear prohibition in Title I of the No Child Left Behind Act of 2001, minority students and students from low-income homes are disproportionately taught by teachers who have not yet completed their training. And, despite abundant research that indicates that teachers become better with experience, the latest Civil Rights Data Collection indicates that “Schools serving mostly African-American students are twice as likely to have teachers with one or two years of experience than are schools within the same district that serve mostly White students.”

Equitable provision of fully-prepared and effective teachers is essential to providing every student an effective, personalized learning environment. Data regarding the improved provision of both fully-prepared and effective teachers to all students, especially those from low-income homes and with high-needs, should be an indicator that LEAs must monitor and report. Improvement in these areas, toward the goal of providing all students with equal access to the best and most prepared teachers, should be required of all applicants. LEAs that propose plans to increase the retention and development of these same teachers should receive additional points on their applications.

Teacher Evaluation
Any discussion of teachers should also include evaluation. We have serious concerns with the descriptions of the evaluations that RTT-D recipients will have to implement. Though we agree with the concept of evaluating staff at every level of the LEA hierarchy and using this information to inform professional development and improved services for students, the description of the evaluations mandated by RTT-D implies that the evaluations will focus on standardized test scores as a “significant factor” in measuring performance of school and LEA staff. Overreliance on these limited measures of student learning and educator performance has already resulted in teaching to the test, low morale in teachers and school leaders, and an alarming trend of students being pushed out of school to artificially inflate school performance data. Indeed, powerful perverse incentives are created when test score data is given too much emphasis in evaluations.

Rather than overemphasizing the data that these assessments provide, test score data should be part of a balanced and multifaceted approach to measuring school and LEA staff performance. Such an approach would entail equal weighting of many of the measures noted in the RTT-D guidelines, including observations, parent and student surveys, and school climate data. Particularly for LEA administrators and school board members, we suggest employing several measures that will provide a comprehensive view of performance, such as school climate, parent and student surveys, and feedback from LEA staff and leadership, in addition to multiple indicators of student academic progress.

And, to the extent that evaluation data is used to inform changes to LEA compensation systems, we remain concerned about the possibility of using test score data for awarding bonuses to staff (so called “pay-for-performance”). Such systems have the potential to induce more teaching-to-the-test, which the President has repeatedly decried, and unscrupulous tactics adopted by educators and district staff to increase scores (e.g., the cheating scandals in Atlanta, Washington D.C., and other cities).

5. Engaging Parents and Communities

True reform requires a team effort – to provide every child an equal opportunity to learn, school, LEA, and SEA staff must be involved and working together toward the same goal. The requirement that SEAs and city/town elected leadership comment on the LEA application is well intended, though the five day comment window is hardly sufficient for an in-depth review of and commentary on an LEA’s application. Given the integral nature of SEA and city/local feedback, the required review and comment period should be longer. Similarly, there should be a separate required review and comment period of equal length for community stakeholders and parents. The comment window for community stakeholders and parents should precede the submission of the application, such that once feedback from the community and parents is incorporated into the application, the SEA and city/local elected leadership may then review the application.

* * *

We thank you for the opportunity to comment.

Sincerely,

NAACP Legal Defense and Educational Fund, Inc.

Thank you for this opportunity to comment on the Race to the Top – District (RTT-D) Program. I encourage the Department to lower the 2,500-student minimum eligibility criteria to 250 (matched by some lowering of the award amount for smaller LEAs) . As it stands now, the competition precludes many if not most rural districts and nearly all public charter schools from participation--unless they form consortium. However laudable, these consortium take significant time to build--if they are authentic and robust--and there is very little time to build meaningful and truly aligned consortium of, for example, 5 or 7 charter schools, or between a district and a charter.

A second, and perhaps more important, reason for lowering the enrollment eligibility requirement is to create the opportunity for more and deeper innovative efforts to personalize learning. The evidence suggests that the charter schools sector has pioneered a disproportionate share of most compelling examples of innovation over the last 20 years. Why should a KIPP (circa 1999) or a Carpe Diem (circa 2011) be rendered ineligible for the Race to the Top - District Program? This program is more likely to yield the lasting proof points it seeks if it does not set arbitrary limits that preclude many of the strongest potential applicants.

A final reason to lower the minimum eligibility: this program aims to personalize learning, to pioneer effective and innovative approaches to provide each individual student with the learning pathway they need. The proposed 2,500 minimum appears to be inconsistent with the spirit of the program aim.

Having seen the early interest in cradle to career work in Greater Houston as we are promoting it via All Kids Alliance, I hope it wil be central to the District Race to the Top specifications.

But more important than the catchphrase are the elements. All sectors must have leadership "skin in the game." Data informed decision systems built on continuous improvement protocols are essential. And shared accountability is key.

Comments from America Achieves on Proposed Race to the Top-District (RTT-D) Competition

America Achieves, a nonprofit organization helping educators and communities build outstanding educational systems to prepare each student for success in college, careers, and citizenship, appreciates the opportunity to submit comments on the draft Race to the Top-District (RTT-D) competition guidelines. To inform these comments, we convened eight leading district and state superintendents and more than a dozen national education experts to discuss how the competition could best drive transformational change.

We are pleased that RTT-D will build on the progress made by this Administration’s support for state and district policy reforms reflected in state Race to the Top, the redesigned Teacher Incentive Fund and other grant programs, as well as NCLB waivers, to enable improvements in teaching and learning. This competition can concentrate new resources on accelerating and deepening learning for individual students so that each student achieves rigorous college and career-ready standards by catalyzing, assessing, and improving new models of teaching and learning that are evidence-based and steered by ongoing analysis of data to determine the curricula, instruction, technology, and other supports that individual students need. Another important opportunity built into this competition includes empowering students to advance, track, and manage their own learning toward rigorous outcomes.

We recommend three sets of changes to help this initiative fulfill its potential, which are further detailed below.

First, we recommend communicating more clearly a required blend of strategies for:

a) Accelerating and deepening individual student learning to achieve high, common expectations through data-driven continuous improvement of learning and instruction; and
b) Personalizing student engagement, the assessments of student progress/needs, and supports to help individual students achieve or exceed high, specific academic expectations.

“Personalization” is an important frame for redesigning learning and teaching, but it is a means to an end. The risk – exacerbated by the early stage of learning technologies, uneven instructional capacity in schools, and the short time frame for completing this application – is that personalization could actually lower expectations and the rigor of instruction, especially for currently low-achieving students. That is clearly not the intent and specific changes would help ensure the competition accomplishes its real aims.

Second, we believe that aspects of the current draft (especially given limited district time and bandwidth to complete applications as well as existing cultures of compliance) risk driving applicants and/or potential vendors towards using checklists to meet application requirements. Instead, the competition should support local design and execution of a strong, specific vision to accelerate, deepen, and personalize learning in participating schools to help students reach and exceed high expectations by requiring that all application components be aligned toward that vision and ambitious outcome goals for students.

Third, the notice could better leverage the system-wide work needed to supplement, sustain, and eventually expand the school- and classroom-level work supported by this initiative. One key recommendation towards this end is to increase the maximum grant level to $50 million.

Detailed Recommendations

1) It is important to mitigate the risk of personalization (if inadequately defined and contextualized) inadvertently lowering expectations – especially for low-achieving students – and better communicate a blend of two primary strategies:

a) Accelerating and deepening individual student learning to achieve high, common expectations through evidence-based continuous improvement of learning and instruction; and
b) Personalizing student engagement, the assessments of student progress/needs, and supports to help individual students achieve or exceed high, specific academic expectations – not just end-of-year-standards, but for each day, week, and instructional unit.

To do so, we recommend:

  • Revising language in the absolute priority and selection criteria to specifically reflect these strategies.
  • Requiring applicants to detail their plans for providing data-driven, evidence-based, continuous improvement of instruction and for equipping educators and students with needed capacity and tools to modify and improve instruction to better accelerate and deepen learning for each individual student.
  • Requiring applicants to describe their comprehensive and coherent reform vision and a specific vision of accelerated, deeper, personalized learning that ensures evidence-based, data-driven, continuous improvement of instruction.

2) To ensure applicants do not take a “checklist” approach to meet application requirements and to better accomplish the competition’s aims to a) support local design and execution of a strong, specific vision to accelerate, deepen, and personalize learning to help students reach and exceed high expectations and b) align all plan components toward that vision, we recommend the application:

  • Focus on dramatic improvements in student outcomes to meet and exceed high expectations aligned to college- and career- ready standards. The application should also clarify the definition and expected implementation of college and career readiness, specifically, that each student master rigorous content knowledge and demonstrate the ability to apply knowledge through goal setting, teamwork, critical thinking, communication, creativity, problem solving, and other higher-order skills. Additionally, the application should clarify that the intent of this competition is to create models of dramatic, not incremental, improvements toward those outcomes.
  • Ensure that, for relevant or illustrative schools, grades, subjects, and programs of study, applicants outline a compelling, specific vision of what accelerated, deepened, personalized learning will look like to help students reach and exceed CCR-aligned high expectations. Applicants should describe how each plan component is indispensable and aligned to this overall vision, including how the organizational and human capacity will be built to design and execute on this vision.
  • Ask applicants to describe current and projected capacity needs and how they will ensure adequate capacity to implement their proposed plan.
  • Ask districts to describe how they will drive and implement a process for school, classroom or instructional design that demonstrates stakeholder buy-in and has a clear plan for: 1) an educational model or instructional program for accelerating, deepening and personalizing learning; 2) a process for change management to that model; and 3) a vision and strategy for creating a culture that supports it. The short application timeframe may provide insufficient time for schools to fully establish thoughtful, comprehensive redesign plans that are imaginative and have ownership and support from teachers and other stakeholders. Please consider:

    -Allowing applicants to create a process (such as a design competition) that provides adequate time, structure, criteria, and support to enable schools to craft or adapt classroom and school designs that address the needs and vision outlined and create a critical mass of schools achieving breakthrough outcomes for each individual student. This likely would lead to new or redesigned schools beginning implementation in the fall of 2014. The design process could also match schools with partners that have expertise in instruction, school design, change management, culture shift, human capital, and technology.

    -Reducing the long list of requirements in C1 and C2 of the draft guidelines and instead focus on evaluating how well applicants describe new or redesigned schools and classrooms or a process to create those and articulate an instructional vision, including an evidence-based approach to continuous improvement, personalization of supports to help students reach high expectations, strategies to ensure excellence and equity for every student, plans for change management and culture shift, and the way in which a redesigned school and classroom (and each plan component) aligns to that vision and goals.

    While the overall vision, goals, and alignment of these components into integrated models would be even more important than individual components of a design, schools should be asked to consider critical components such as: 1) continual assessment of what is working and what is not that is available in a timely manner to inform instruction; 2) leadership with clear vision; 3) the instructional methods, tools, resources, curriculum, and infrastructure provided to help students reach college- and career-ready standards; 4) supports for teachers to provide accelerated, deeper and personalized learning including time for collaboration; 5) wrap-around student support services (either integrated or offered as a personalization approach, not as a separate competitive priority); and 6) rethinking of resources – including educators’ roles and responsibilities, budgets, and time/schedule.

    -Developing a process to judge an applicant’s capacity and vision for leading this type of design competition to achieve the goals and vision as well as assess their plan for sustainability and scalability to reach more students over time.

  • Explicitly linking design components with strategies for developing and supporting teachers and leaders who will make new models and outcomes a reality. Teachers and principals need the knowledge, skills, and other tools (e.g., data, technology, and time for collaboration) that will allow them to deliver on the promise of new instructional, classroom, and school models. The competition should require applicants to articulate how they will ensure that their human capital management system is or will be ready to meet that challenge. A significant number of points should be attributed to this portion of applicants’ plans.
  • Ensuring that required performance metrics reinforce the outcomes and related design principles that are at the competition’s core. Specifically:

    -Remove student and teacher survey metrics.

    -Provide measures grouped by school level to ensure appropriate metrics across a range of grades.

    -For high school measures, include post-secondary persistence and outcome measures.

    -Modify performance measures regarding student access to effective educators to specify only the percentage of students' teachers of record who are highly effective.

    -Remove the personalized learning plan indicator.

3. Adjust the application to better leverage the system-wide work needed to supplement, sustain, and eventually expand the school and classroom level work to be supported by this initiative to advance student outcomes. To accomplish this, the Department could:

  • Ensure that districts describe how local and state policies will enable the success of redesigned classrooms and schools. This should include a description of any current requirements and policies (e.g. seat time, Carnegie units) from which schools will be released to enable innovative design models as well as new policies, practices, or expectations that will be established to accomplish the same.
  • Request that districts describe sustainability and scale plans, showing how new school and classroom models will reach more students over time. Consider allowing a phase-in approach to reach the full target of participating students over the grant cycle instead of serving at least 2,500 students in year one.
  • Adjust size of grant awards to better reflect the needs of the smallest and largest districts/consortia. The variability in proposed award sizes for districts with 2,500 to potentially well over 10,000 participating students is small. The proposed award sizes for small districts may exceed what is necessary and could be difficult for small districts to sustain after the award cycle. The competition should allow for greater variability in award size with awards for smaller districts reduced to $5-10 million and increased to $40-$50 million for larger districts.
  • Although the 40 percent poverty threshold in participating schools may be a reasonable minimum, districts proposing to serve much higher levels of low-income students through this competition should be advantaged or prioritized.
  • Discard or deemphasize provisions that are outside of the district’s control and or not essential to the implementation of the desired outcomes. These include eligibility requirements for a P-20 data system as well as union sign off and 70% teacher support for the district’s plan (these could be included as selection criteria offering more points to those district able to demonstrate higher levels of support).
  • Replace the requirement for personalized learning plans with a description of how systems and schools will track individual student progress and use that information to provide the instruction and support needed to reach or exceed high expectations. Requiring personalized learning plans could lead to bureaucratic paperwork and detract from the transformation of teaching and learning.
  • Replace the proposed competitive priority. The competitive priority on comprehensive student and family supports seems disconnected from broader reforms, although many students require added supports to achieve high academic outcomes. Providing academic and non-academic supports to students and families could be incorporated into a thoughtful school and district design as one approach to personalization. Alternate competitive priorities that reinforce the competition’s intended outcomes should be considered. For example, applicants may receive additional points if their plans will accelerate high quality implementation of college- and career-ready standards across the district.

Recommendations to the Department of Education on Race to the Top District Grants

Prepared by
Pamela Cantor MD, President & CEO, Turnaround for Children
David Osher, Ph.D., Vice President, American Institutes for Research
Joan Kass Stamler, Ph.D., Vice President for Research & Metrics, Turnaround for Children

Turnaround for Children partners with schools and districts serving high-poverty communities to drive improvement in school culture, teacher effectiveness, and student academic achievement.

American Institutes for Research (AIR) is one of the largest behavioral and social science research organizations in the world. AIR’s overriding goal is to use the best science available to bring the most effective ideas and approaches to enhancing everyday life.

On behalf of Turnaround for Children and AIR, we are pleased to offer the following comments to strengthen the RTT-D program. The draft RTT-D notice seeks to support districts in building on state policies to design fundamentally new models of teaching and learning that can achieve dramatic gains for every child in terms of the knowledge and skills necessary for success in college and career. In addition to key drivers of this redesign, such as personalization, growing evidence and experience tell us that many kids in poverty – a core target of the RTT-D program – cannot achieve these gains without express attention to their underlying social and emotional needs, and that with knowable, integrated supports, all students can succeed at high levels. The draft RTT-D notice acknowledges this by establishing a competitive priority around additional student and family supports. But the current priority is not fully defined. In sum, we recommend that (1) the competitive priority be moved into the selection criteria as part of a core redesign strategy that each district should address in its context, and (2) the description of these supports be revised to more fully reflect best practices.

All students need social, emotional, and cognitive competencies to succeed in school. And schools must have foundational conditions for teaching and learning – the experience of safety, connectedness and support, and academic challenge and engagement – in order to promote students’ development of those competencies. For example, academic success depends on students’ executive functioning (e.g., self-regulation), and their ability to attend, concentrate, persevere, and work in groups. Similarly, students learn and achieve more when they are physically and socially safe because the experience of anxiety, for example, compromises working memory. Students who feel emotionally and physically safe are more productive in class, and this correlates with achievement.

Many of the children who are the focus of the RTT-D program come to school without these competencies, face many adversities, and attend schools that are not adequately designed or prepared to support optimal teaching and learning. The challenges of poverty disrupt children’s development and compromise their ability to understand and manage their emotions and relationships in ways that will lead to school and life success. The outward signs of this disruption take varied but predictable forms, from distraction to dysfunction, and disrupted development inevitably interferes with children’s ability to fully do the “work of childhood” and progress in school successfully. While the adversities of poverty are powerful in their own right, they are often exacerbated for students with disabilities and those who are English Language Learners.

The current RTT-D draft begins to address these barriers to learning and development by including a competitive priority that addresses the challenges facing chronically underperforming schools in high-poverty communities. The proposal could be further strengthened by making this competitive priority a core requirement. If the requirement’s status cannot be changed, adding specificity to the nature of social and emotional conditions/supports provided and the metrics that should be collected would be an important step in bringing these kinds of practices to scale.

A successful RTT-D model must directly address poverty’s effects on children’s development and the ways it can compromise their ability to attend to learning and their teacher’s ability to instruct effectively. Hence, the requirements should call for approaches that address social and emotional learning, the quality of supports provided to students, and the competency and motivation of all adults in a school building to address, in their daily practice, the cognitive, social, and emotional needs and development of all children.

As RTT moves into being a District initiative, it is important to establish the expectation that schools intentionally adapt practices and build capacity to meet the challenges that children living with adversity bring with them to school. RTT-D should address the facts that social-emotional learning and student support are absent or inadequate in many schools, that conditions for teaching and learning are poor in many high-poverty schools, and that principals and teachers typically lack the skills to deal effectively with the profound challenges in high-poverty classrooms.

To do this, RTT-D should, in its core requirements, not just as a competitive priority, address all critical elements of school design that can drive student achievement, including:

1) A school-wide culture with high expectations for achievement and behavior;
2) Student proficiencies in self-regulation, social interaction, persistence toward goals, and academics;
3) A broadened definition of teacher competency that includes proficiencies in instructional practice, well-managed classrooms, student engagement, social and emotional learning and development; and
4) An adequate capacity for high-quality academic and non-academic supports and interventions for students in need.

Only by addressing these elements can schools and districts develop effective policies and “an infrastructure, capacity, and culture that enables teachers, teacher teams and school leaders to continuously focus on improving individual student achievement.”

Doing this requires collecting and utilizing data on both how students are doing socially, emotionally, and behaviorally, as well as academically, and using this data for planning, monitoring, continuous improvement, and evaluation. Individual student data should include measures of social-emotional competencies and behavior, including self-regulation, motivation, engagement, personal goal-setting, and the ability to work on the development of these skills or competencies. School-wide data should include measures of how students and staff experience the school and classroom environments, including perceptions of physical and emotional safety, feelings of support, and engagement. Institutionalizing this kind of data within schools and districts will help to shape effective practices for student support and development, track its progress, and reinforce its importance.

Dear Ms. Martin and Mr. Yudin:

There is a continuing, clear and compelling need for high-quality, racially and socioeconomically diverse education for all students. Across the country, advocates continue to struggle against the creation of high-needs schools marked by racial isolation and concentrated poverty. Racially and economically diverse learning environments are proven to provide the best chances of success for all students and were most recently recognized as a compelling interest by the U.S. Supreme Court in Parents Involved in Community Schools v. Seattle School District No. 1, 551 U.S. 701 (2007) and the Department’s December 2012 memoranda, “Guidance on the Voluntary Use of Race to Achieve Diversity and Avoid Racial Isolation in Elementary and Secondary Schools” and “Guidance on the Voluntary Use of Race to Achieve Diversity in Postsecondary Education.” By contrast, high-needs schools are inordinately expensive to maintain and improve, due in part to the difficulty of attracting and retaining effective teachers to such environments. It is thus troubling that the RTT-D guidelines entirely omit incentives that promote racially and socioeconomically integrated schools, a core component of a high-quality education.

The Department’s proposal emphasizes individual-focused education and improving high-needs schools without the necessary parallel of promoting racial and socioeconomic diversity on a school or system-wide level. This limited approach can encourage districts to concentrate students in high-minority, low-achieving schools and programs, then apply quick-fix remedial resources instead of creating the diverse schools and classrooms that produce the best learning environment for all students. The current proposal incentivizes such a segregative approach, as it allows LEAs to apply for “subject area bands,” including lowest performing schools, feeder patterns, and individual subjects and grades.

Rather than undermine RTT-D’s own “core educational assurance areas” – all of which require that a district guard against the harms of racial and socioeconomic isolation – and call into question the Department’s commitment to achieving diversity, the RTT-D guidelines should be aligned with these absolute priorities to incentivize high-quality, racially and socioeconomically diverse education.

A. Eligibility Criteria

The RTT-D Eligibility Criteria should explicitly require an LEA to demonstrate a system-wide commitment to high-quality, racially and socioeconomically diverse education at the district, school, and classroom level. The Department should also eliminate measures that could bar counties serving the neediest students from accessing Race to the Top funding.

1. Desegregation orders and Title VI Complaints

To further discourage racial isolation, the creation of high-needs schools, and the marginalization of at-risk populations, the Department should carefully scrutinize applications from LEAs with an open desegregation order or a Title VI complaint. Though these districts should not be ineligible from participating in Race to the Top, the Department should ensure that the applicants do not allocate resources in a way that further marginalizes at-risk populations by soliciting comment from Title VI complainants and parties in the desegregation litigation. Especially for dual district applicants, the Department should solicit comments from private or government plaintiffs on the district’s record of eliminating the vestiges of segregation and require evidence that the district’s RTT-D proposal will be effective in fulfilling its affirmative duty to desegregate.

2. Effect on small high-poverty, high-minority districts

The requirement that LEAs with less than 2,500 students may apply only through a consortium of districts effectively eliminates low-wealth and high-minority LEAs in North Carolina from receiving RTT-D funding. The consortium process adds a serious administrative barrier for these small LEAs, which contain some of the state’s most at-risk students. In 2010-2011, 22 of the 23 districts in North Carolina serving less than 2,500 students were income-eligible for RTT-D and were among the poorest in the state, including 17 counties with 60% or more FRL-eligible students. Nine of these districts serve majority minority student populations.

The onerous administrative requirement of inter-county coordination to address the unique needs of these small districts could delay or deprive resources from the state’s neediest students. Under the 2010 state-administered Race to the Top model (RttT), these 23 LEAs received a total of $7.4 million. These and other small districts would now face significant barriers to receiving this assistance. The Department should create a lower budget requirement tier or modify the RttT model to allow small districts to apply for funding directly from their state.

B. Selection Criteria and Competitive Preference Priority

Each RTT-D criteria and priority should incentivize diversity-promoting measures to further the core educational assurance areas, aligning this program with the Department’s 2012 Guidelines on the compelling interest in promoting diversity and avoiding racial isolation in K-12 education. Parameters should encourage diverse classrooms and expressly disincentivize concentrating high-needs students into a single school. Areas of specific concern include the following:

• Criteria A: Vision: Analysis of the LEA’s “comprehensive and coherent reform vision” of “advancing excellence and equity through personalized student and educator support” should include the district’s actions to create racially and socioeconomically diverse classrooms (including students and faculty) and train teachers to promote the benefits of such a diverse learning environment.
• Criteria B, “District Capacity and Success Factors,” recognizes the need to close achievement gaps and serve high-needs students, but fails to call for systemic diversity-promoting measures that would prevent concentrating racial minority and low-income students into high-needs schools or programs.
• Criteria C: “Preparing Students for College and Careers,” and its subcategories must require that students’ learning environments prepare them for the increasingly diverse world they face in college and beyond. It is particularly concerning that each subcategory calls for creating effective individual learning environments and peer-driven education and teamwork, but does not require an enriching environment of varied perspectives. Teacher and administrator training in analyzing student performance data must also include guidance on how race and income concentrated schools and classrooms inhibit achievement for all students, especially high-needs or at-risk students.
• Criteria D: “Transition Plan and Continuous Improvement,” requires a plan to increase student access to highly qualified and effective teachers and principals. The proposal specifically notes this need in “hard-to-staff schools,” but fails to direct districts to avoid concentrating low-income, racial and ethnic minority, high-needs students and creating schools that drive away personnel and financial resources. A district’s application must include the goal of preventing racial and income isolation as well as raising student achievement..

The Competitive Preference Priority of integrating public and private resources provides an important incentive for districts to engage community organizations. However, the thematic focus on high-needs schools may again incentivize a district to create (or maintain) concentrations of racial minority and low-income students and rely on federal or private partners to assist them. Instead of this exclusive focus, the Competitive Preference Priority should reward diversity measures such as:
• the extent to which each of the district’s schools reflect district demographics, creating a school population that best prepares students to engage with the increasingly diverse nation.
• the degree to which racial minority and socioeconomically disadvantaged students enroll and succeed in all classes, especially advanced curriculums, creating learning environments of diverse viewpoints.
• the broad implementation of alternate discipline and dispute resolution policies that create a fair discipline process and reduce the disparate impact on racial minorities (consistent with the laudable addition of the discipline assessment Program Requirement).

C. Stakeholder Commentary

The Department must solicit commentary from all stakeholders affected by the district’s RTT-D proposal. While it is helpful that the LEA’s application must include letters of support from key stakeholders, including civil rights organizations, additional input should be required. Community stakeholders must be given an opportunity to comment on the school district’s application packet in order to ensure meaningful public participation in the process. The Department should mandate a comment period for suggestions, cautions, and even criticism from any affected stakeholder concerned with the district’s track record, priorities, and prospects for engaging and serving at-risk populations. Once a district develops FERPA-compliant records, as anticipated by the Program Requirements, they must be open not only to the Department and its research partners but to any interested party through FOIA requests.

The abbreviated comment period for this proposal exemplifies what appears to be the Department’s discounting of meaningful public input. The RTT-D comment period was shortened to two weeks and is limited to online comments only, thereby depriving key stakeholders of adequate notice and opportunity to comment. The Department should have taken every measure to ensure consultation and input from as many affected parties as possible.

These comments are submitted on behalf of education advocates in North Carolina. We hope the Department will give serious consideration to these comments and will open every district’s application and results to full public comment.

Thank you for your consideration, and please feel free to contact us with any further information.

Sincerely,

Mark Dorosin, Managing Attorney
919-843-7896; dorosin@email.unc.edu
Taiyyaba Qureshi, Attorney-Fellow
919-962-0226; tqureshi@email.unc.edu
UNC Center for Civil Rights

Christopher Hill, Director
919-856-2567; chill@ncjustice.org
Matt Ellinwood, Policy Advocate
919-861-1465; matt@ncjustice.org
Law and Education Project, North Carolina Justice Center

Yevonne Brannon, Chair
Great Schools in Wake
919-851-2805; YBrannon@Gmail.com

Calla Wright, Chair
Concerned Citizens for African American Students
919-231-9057; ccacc_aacca@yahoo.com

The International Society for Technology in Education (ISTE) appreciates the opportunity to provide comments on the proposed U.S. Department of Education’s Race to the Top District program (RTT-D). ISTE is the premier membership association for educators and education leaders engaged in advancing excellence in learning and learning through the innovative and effective use of technology in PK-12 and teacher education. Home to ISTE’s annual conference and exposition and the widely-adopted NETS, ISTE represents more than 100,000 professionals worldwide.
ISTE strongly supports the RTT-D absolute priority for Personalized Learning Environments (PLEs). We believe grants should be awarded to districts that embrace personalized learning as a robust educational experience leveraging digital tools that includes many opportunities for interacting with others orally and in writing; engaging in rigorous, challenging thinking; project-based learning, and opportunities to leverage creativity in assessment artifacts. Adaptive learning has its place within personalized learning; however, that is just one component of personalized learning. We are concerned that the RTT-D program as currently written, too narrowly defines personalized learning, and thus limits the potential for students to truly experience a personalized learning environment.

Absolute Priority 1, Personalized Learning Environment(s)
Add the following language in CAPS …”in Race to the Top to create student centered learning environments(s) that INCLUDE A WIDE RANGE OF DIGITAL LEARNING AND TECHNOLOGY INTEGRATION OPTIONS TO PERSONALIZE LEARNING that are designed to:”

Section C. Preparing Students for College and Careers
Learning:
The language under the Learning section must be more student-centered, empowering students to be active learners rather than to solely focus on tracking scores and data. Scores and data provide necessary feedback to the teachers and students regarding learning; however, this is not sufficient. Students should be architects of their learning experiences and engage in multiple modalities of learning. The learning section should include references to project-based/inquiry-based learning and student-created content. Additionally, personalized learning should be implemented as part of a larger strategy that promotes both individual and group learning.

Teaching:
Applicants should be required to include the amount of time allotted for teacher professional development.

Program Requirements – Budget
The grant size should be reduced, as replication and sustainability will be difficult with the proposed grant amounts, and the proposed range is inconsistent in per student allocations across the budget ranges. Additionally, reducing the amount of the awards would enable more than 15-20 districts to receive grants, enabling more students to receive the benefits of personalized learning.

Competitive Preference Priority
ISTE recommends that proposals that include a wide range of digital learning and technology integration options to personalize learning should receive a competitive Preference Priority.

Definitions

Digital Learning Content
Add the term “student-created content”, to the sentence, “Digital learning content includes open, commercial and STUDENT CREATED CONTENT.”

Personalized Learning Plan
Make the proposed changes below in CAPS:
A formal document, available in digital and other formats both in and out of school to students, parents, teachers, AND ADMINISTRATORS, that, at a minimum: establishes student learning goals based on academic and career objectives and personal interests; ALLOWS AND ENCOURAGES THE STUDENT TO PROCEED AT HIS/HER OWN PACE; sequences content and skill development to achieve those learning goals and ensure that a student can graduate on-time college-and career-ready; and is updated MONITORED based on information about student performance on a variety of activities and assessments that indicate progress towards goals.

Principal evaluation system
Make the proposed changes in CAPS: (2) meaningfully differentiates performance using at least three performance levels, INCLUDING THE ESTABLISHEMENT OF A SCHOOL-WIDE DIGITAL LEARNING CULTURE.

School Leadership Team
Include a “TECHNOLOGY INTEGRATION LEADER” as a required member of the school leadership team.

Teacher evaluation system
Make the proposed changes in CAPS (2) meaningfully differentiates performance using at least three performance levels, INCLUDING A TEACHER’S ABILITY TO USE DIGITAL TOOLS TO PERSONALIZE LEARNING.

Technology
Add a new definition for technology, The term ‘technology’ means modern information, computer and communication technology products, services, or tools including, but not limited to, technology equipment for classroom usage, Internet and other communications networks, computing devices and other computing and communications hardware, and software applications, data systems and other digital content, and data storage.

In kind donations
In kind donations should be allowable under the RTT-D grant applicants.
The following new language should be added: Under Selection Criteria B, District Capacity and Success Factors, add: “3) c) Documents pledging meaningful in-kind support, which may include tools, technology, digital content, and professional development, from businesses, foundations and/or non-profits with experience serving the k12 community.

The following changes in CAPS should be made Under Selection Criteria E, Budget and Sustainability, insert in-kind donations (as shown) into the following statement: “The extent to which – 1) The application’s budget, which includes all funds that will support the project (e.g., Race to the Top grant; external foundation support; local, State, and other Federal funds; IN-KIND DONATIONS OF TOOLS, TECHNOLOGY, DIGITAL CONTENT, AND PROFESSIONAL DEVELOPMENT, FROM BUSINESSES, FOUNDATIONS AND/OR NON-PROFITS WITH EXPERIENCE SERVING THE K-12 COMMUNITY; or other support.

Sincerely,

Don Knezek
Chief Executive Officer
International Society for Technology in Education

Secretary Duncan:

We have applauded the Administration for repeatedly highlighting the importance of maintaining positive levels of student safety, health, engagement and support in order to foster a constructive learning environment. As the longest-standing coalition of national organizations committed to positive youth development, the National Collaboration for Youth shares your appreciation of this comprehensive support for our nation's students.

Language in the proposed RTT-D executive summary, however, does not reflect this sentiment; in fact, the present RTT-D proposal neglects an opportunity to reinforce the importance of ensuring that students are safe, healthy, engaged, and supported. Proven programs and initiatives that support such goals include, but are not limited to the following:

• Fostering student safety from bullying and other violence
• Encouraging positive physical and mental health
• Developing strong social and emotional skills
• Refraining from substance abuse, including alcohol, tobacco and other drugs
• Maintaining school engagement without high truancy and drop out rates
• Cultivating strong relationships with caring and supportive adult mentors within a student’s family, school and community

To underscore the importance of the points made above, it is absolutely crucial that all RTT-D applicants possess the capability to measure and assess student conditions for learning. When these efforts are truly made a priority, teaching and learning environments can be continually enriched, ensuring improved school success and student achievement.

In closing, we strongly encourage the modification of the RTT-D summary to support the utilization of evidence-based programs and mandatory assessments of student learning conditions for all RTT applicants in order to further enhance the overall learning environment. Thank for you the opportunity to engage with you on this important proposal-- we look forward to continuing the conversation.

Sincerely,
Hayling Price
Policy Director
National Collaboration for Youth

I agree with the comment on"Dignity in Schools."

Healthy schools have diverse populations. School districts should be rewarded (with grants) if the School Board puts a cap on each school so it is not overwhelmed with too many low achievement kids , for example no more than 50% below grade level at each school. So our teachers are not overburdened. So all our schools can strive to be balanced, diverse and we can give each child the attention and resources he/she needs. Every child deserves a good school.

What makes a good school?

Good teachers make excellent schools. In a perfect world the best teachers would teach in the lowest performing schools. Unfortunately, the best teachers don’t want to teach in the high poverty schools. There are more issues to deal with. Kids who can’t afford to pay for a school lunch ($2 for grades K-5, $2.25 for grades 6-12) probably can’t afford a home computer.

They may not have a quiet place to do their homework, or someone to help them do their homework, or maybe didn’t have dinner the night before, or have parents who are struggling to work two jobs to make ends meet. In the higher income schools more parents have time to volunteer in the schools and raise lots of money (selling wrapping paper, golf tournaments, etc) for supplies, computers, special teacher appreciation lunches, etc.

Wake County, NC schools have had an excellent reputation for the past 30 years because they had a diversity policy (they have recently repealed that policy unfortunately). Please make diversity in the schools a priority by making that a requirement for the Race To the Top grants.

The Foundation for Community Education would like to register its support for the Race to the Top program. Many of the provisions contained in the program description have the potential to make some positive changes in the way we approach teaching and learning. There is one issue we would like to address. In the description of how this program will be implemented at the LEA level you can find many references to engaging parents and the community. Community Educators are strong advocates for engagement and have been for many years. These references to involving parents and community have been showing up in the proposal guidelines for program sponsored by the Department of Education for many of those years. The problem often encountered in implementation is that there is often no one in a school or district who has the training and major assignment in facilitating the engagement of parents and community. It is often a matter described by school leaders as, “Well this is everyone’s job in our schools.” Unfortunately, everyone’s job turns into no one’s job.
The number one suggestion is to make sure parent and community engagement is not just a window dressing element in the program, but that LEAs are held accountable for the successful engagement of their parents and key members of the community. We know that there is research that has established a correlation between parent engagement and student success. But, time and time again this activity gets set aside for “coffee and cookies” meetings that do not result in the active involvement in their children’s learning. There are also many members of community who care about education and have resources that have great potential for having a positive impact on teaching and learning.
Second, we would like to recommend that LEAs participating in the Race to the Top program employ a member of the leadership team who has expertise in working with parents and community members to provide a variety of useful activities that will bring greater success to the educational progress of students.
Our last suggestion is to require that an effective assessment be made of the engagement of parents and community.
Thank you for providing us with this forum for sharing our thoughts on this program.
Stephen R. Parson, President, The Community Education Foundation.

Several organizations who are members of the National Coalition on School Diversity submitted this letter today to Secretary Duncan, urging a priority for Race to the Top district proposals that promote school diversity and reduction of racial isolation as part of an educational reform strategy:

Dear Secretary Duncan,

On behalf of the undersigned organizations and individuals supporting quality, racially and economically integrated education, we submit these comments in response to the draft executive summary of the draft requirements, priorities, selection criteria, and definitions for the Race to the Top District competition for the Department of Education’s Race to the Top District Competition. Our primary concern is that the proposed standards overlook the continuing importance of avoiding racial and economic segregation in public schools, and promoting voluntary school integration. We recognize that the notice and comment website is set up to solicit “informal” comments, but we believe that the omission of school diversity criteria from the new notice merits a more formal response.

The importance of promoting integration and avoiding racial isolation has been reaffirmed as a compelling government interest by five Justices of the U.S. Supreme Court in Parents Involved in Community Schools v. Seattle School District #1, and by the Department itself in its December 2011 Guidance on the Voluntary Use of Race to Achieve Diversity and Avoid Racial Isolation in Elementary and Secondary Schools, issued jointly with the U.S. Department of Justice. Yet this acknowledged federal interest in diversity and reduction of racial isolation is altogether absent from the draft standards for the Race to the Top District Competition. We recognize the challenges in creating and maintaining racial and economic diversity. However, we believe that it is inappropriate to use federal money to perpetuate racial and economic isolation in our public schools. At the very least, new federal funds should incentivize local efforts to promote diversity.

We made this same point in 2009 in response to the “Notice of Proposed Priorities, Requirements, Definitions, and Selection Criteria,” for the Department of Education’s original Race to the Top Fund, asking for diversity to be included as a priority. It did not appear in the final rule, nor has it appeared in any of the Race to the Top funding phases since then. However, the need for diversity in our schools has only grown more salient. In his 2010 speech at the Edmund Pettus Bridge in Selma, Alabama, Secretary Duncan discussed the importance of diversity in education both broadly and as it had benefited him, stating that “policies which stunt healthy diversity are bad for children and at odds with the American Dream,” and committing that the Department would embark on a revitalized mission to increase the fairness and equity in education.

The December 2011 Guidance on the Voluntary Use of Race to Achieve Diversity and Avoid Racial Isolation in Elementary and Secondary Schools further emphasizes this priority, stating that racially diverse schools provide “incalculable civic and educational benefits” to students, and that schools lacking in racial diversity “may fail to provide the full panoply of benefits that K-12 schools can offer.” The Guidance clarifies that schools and districts can lawfully promote school diversity, and gives examples of methods that can be used to achieve diversity. The Department, in this new competitive funding round, should be soliciting innovative educational approaches that achieve this goal. There is no reason for the Department to divorce the concept of educational reform from the compelling need for school diversity – in fact, the two can and should go hand in hand.

Furthermore, the Department’s Supplemental Priorities for Discretionary Grant Programs, published in December 2010, affirmatively permit the Department to provide a funding preference for “projects designed to promote student diversity, including racial and ethnic diversity, or avoid racial isolation,” in order to “promote cross-racial understanding, break down racial stereotypes, and prepare students for an increasingly diverse workforce and society.” Given this explicit approval of diversity as a source of preference for federal grant money, the Department should in its NOFA utilize a priority for student diversity to encourage voluntary integration consistent with the terms of the guidance. Such a priority would not be unprecedented; promoting student diversity and avoiding racial isolation are currently competitive preference priorities (albeit very weak) for federally funded charter school programs.

Under the new Race to the Top funding round, LEAs and regional groups of LEAs are in an optimal position to effectively promote integration. They can institute school, district, and inter-district policies that foster a diverse student body, can monitor levels of diversity at the school-level and the classroom-level, and can act dynamically to address the unique issues that arise in balancing the importance of diversity with the difficulty of satisfactorily achieving it. As recognized in the December 2011 Guidance, LEAs are often in the best role to build a diverse student population in American schools from the bottom up.

Given the unique opportunity for the RTT-D Competition to target the compelling goal of diversity at the ground level, we urge that the final notice reflect the goal of supporting racial and economic integration in public schools. We suggest that the statement of purpose and each section of the NOFA reflect this commitment, and that a priority is placed on applications whose proposals similarly reflect this commitment. Otherwise, the importance of reducing racial and economic isolation of disadvantaged students of color as part of an overall school reform strategy is likely to be overlooked both by applicants and by US DOE proposal reviewers.

In accordance with these general comments, we recommend the following additions to the Notice:

¶ As an Absolute Priority, a Competitive Preference Priority, or a Proposed Invitational Priority, the Department should add “Innovative Approaches to Voluntary School Integration” and “Intra-/Inter-district School Transfers to Promote Integration.” This could include, for example, large LEAs encouraging intra-district transfer and magnet programs to promote integration, and small LEAs applying as interdistrict consortia (or demonstrating evidence of interdistrict cooperation) encouraging inter-district transfer programs to promote integration (building on the experience of successful programs in metro areas across the country, including Boston, St. Louis, Hartford, and Minneapolis).

¶ Core Educational Assurance Areas should include as a fifth area the goal of creating a racially and socioeconomically diverse learning environment for students.

¶ Under Eligibility Criteria, we suggest the addition of the following two criteria. These are already likely obvious to many DOE grantees. In practice, however, these principles are often disregarded:

6. The proposal by the LEA or consortium of LEAs will attempt to ameliorate, and not increase, school based poverty concentration and racial isolation in the schools affected by the proposal.

7. The LEA or consortium of LEAs may not use these federal funds to create new racially concentrated or high poverty schools.

¶ Program Requirements should include language supporting voluntary school integration efforts. The Department should require each applicant to include in its application an analysis of how its proposal will utilize both the federal funds and its local resources (including ground-level knowledge of ongoing circumstances) to increase or decrease racial and economic isolation and segregation of students in the jurisdiction applying for funds.

¶ Selection Criteria (B)(4): “A high quality plan…” should include a description of how the district has demonstrated evidence of a plan to successfully address the racial and economic isolation of students in the jurisdiction applying for funds. Priority should be given to proposals with demonstrated evidence that the district has the will and capacity to encourage voluntary racial and socioeconomic integration within the school and classroom. In particular, weight should be given to applicants who have demonstrated how their plan will capitalize on district-level resources and knowledge to increase student diversity through school transfer programs, diversity-conscious attendance zones, or other innovative methods.

¶ Selection Criteria (C)(4): “Performance Measurement” should include as a measure “The extent to which the applicant has established annual ambitious yet achievable annual targets for decreasing the racial and economic isolation of low-income students.” One measure of how well the applicant has so established might be the quality of its intra-/inter-district school transfer program plan.

¶ Selection Criteria (D): “Transition Plan and Continuous Improvement” should include “The extent to which the applicant has a plan for increasing the racial and socioeconomic diversity within schools and classrooms, and for decreasing the racial and socioeconomic isolation of students in the schools, grades, or subgroups receiving RTT-D funds.” In particular, plans should provide for how the LEAs will implement their school transfer programs to balance the efficacy of the diversity goal with the potential for balkanization.

¶ Require that each LEA implement data collection and a plan to reduce conditions of racial isolation for low-income students. Data collection should include longitudinal data pertaining to individual student performance for ethnic majority and minority students, transfer and neighborhood students, and students of high-, middle-, and low-income families.

Thank you for the opportunity to present these comments. Please let us know if you need additional information; we would be happy to consult with the Department further on the issues addressed in this letter.

Sincerely,

Philip Tegeler
Poverty & Race Research Action Council
Washington, DC

Damon T. Hewitt
Leticia Smith-Evans
Eric Rafael González
NAACP Legal Defense and Educational Fund, Inc.
New York, NY

Tanya Clay House
Lawyers' Committee for Civil Rights
Washington, DC

Laura W. Murphy
Deborah J. Vagins
Washington Legislative Office
American Civil Liberties Union
Washington, DC

Khin Mai Aung
Asian American Legal Defense and Education Fund
New York, NY

Gary Orfield & Patricia Gandara
Civil Rights Project/Proyecto Derechos Civiles
University of California, Los Angeles
Los Angeles, CA

Susan Eaton
Charles Hamilton Houston Institute for Race and Justice
Harvard Law School
Cambridge, MA

john powell
Haas Diversity Research Center
Berkeley School of Law
Berkeley, CA

Sharon Davies
Kirwan Institute for the Study of Race & Ethnicity
The Ohio State University
Columbus, OH

Kevin Welner
University of Colorado
Boulder, CO
(University listed for identification purposes only)

Derek Black
Howard University School of Law
Washington, DC
(University listed for identification purposes only)

[Word Count: 1661]

June 8, 2012

The Honorable Arne Duncan
Secretary
United States Department of Education
400 Maryland Avenue, SW
Washington, DC 20202

Re: Comments on the Draft Race to the Top - District Program

Dear Secretary Duncan:

In response to the May 22, 2012, ed.gov blog post, the Mexican American Legal Defense and Educational Fund (MALDEF) submits the following comments to the proposed priorities, selection criteria, and definitions that the United States Department of Education (the Department) outlines to carry out the newly announced Race to the Top- District (RTT-D) program.

Founded in 1968, MALDEF is the nation’s leading Latino legal civil rights organization. Often described as the “law firm of the Latino community,” MALDEF promotes social change through legislative and regulatory advocacy, community education, and high impact litigation in the areas of employment, immigrant rights, political access, and education. MALDEF’s intent here is to encourage the Department to develop final RTT-D requirements that help districts innovate and raise the rates of Latino students graduating career- and college-ready, including those that are English language learners (ELL), migrant students, and immigrant students.

MALDEF sees promise in the district-focus of this federal competitive program given that substantial numbers of students – particularly Latino students – failed to benefit from earlier state-focused Race to the Top (RTT) efforts. For example, of the twelve states that won Phase 1 and 2 awards, only two have Latino student populations that meet or exceed the national proportion of Latino students in United States schools. See Education Trust, Student Demographics in RTTT- Winning States (Aug. 26, 2010). Consequently, while the twelve states overall represent 28 percent of the nation’s students, they only serve 19 percent of the nation’s Latino students. Of the five states with the highest density ELL enrollment – Arizona, California, New Mexico, Nevada, and Texas – only Arizona succeeded in winning RTT during Phase 3, a comparatively smaller award. See Migration Policy Institute, States and Districts With the Highest Number and Share of English Language Learners (2010). Moreover, of the five states with the largest migrant student populations – California, Texas, Florida, Washington, and Oregon – only Florida won RTT funds.

On balance, RTT-D appears to be a positive evolution of the RTT efforts that the Department has championed. MALDEF encourages the Department, however, to use the district-focus here to proactively reach willing districts found within non-RTT states, particularly those serving sizable subgroup populations including racial and ethnic minorities, ELLs, and migrant students. To this end, MALDEF offers the following suggestions to strengthen the proposed RTT-D priorities and selection criteria:

• Absolute Priority 1, Personalized Learning Environment Selection Criteria: MALDEF believes the Department can and should do more to ensure RTT-D equitably reaches Latino students across the recipient school districts. While the proposed reach of RTT-D will likely reach new districts that the previous RTT efforts did not, the selection criteria for RTT-D is less detailed than RTT or even the No Child Left Behind (NCLB) flexibility (waiver) applications currently underway. This lesser prescriptive approach appears to be tied to encouraging the development of innovative, personalized teaching and learning models to promote college- and career-ready outcomes. A personalized teaching and learning environment is one every child deserves and we applaud that goal. The concern for MALDEF, however, remains that with greater local autonomy many RTT-D recipients may find themselves serving some students – and not all students or even those students with the greatest need – given local political pressures or comparatively greater engagement by certain parent sectors over others.

o Recommendation: While RTT-D applicant districts may apply for all or a portion of their schools, for specific grades, or for specific subject/grade bands, they must assure, in part, that: (1) at least 2,500 students are served and (2) at least 40 percent of participating students are from low-income families. MALDEF recommends that districts ensure that an additional percentage of the 2,500 or more students served be ELL, special education, and migrant students. The Department’s commitment to ELL and special education students was evident within the waiver application process; it appears, however, to not be present here in the RTTT-D context. Moreover, the oversight regarding ELLs and students with disabilities should be corrected and expanded to also factor in migrant students. The future lessons to be learned from the RTT-D experience should proactively account for how personalized teaching and learning models can and should reach students with unique learning needs like ELL, special education, and migrant students. Now is the time to require that RTT-D districts select schools, grades, and subject/grade bands that reach all student subgroups, not just some.

• Absolute Priorities 3 and 5: Rural LEAs in RTT States and non-RTT States: MALDEF commends the Department for prioritizing rural LEAs. From 1999-2009, rural Latino enrollment increased by 150 percent nationally, and in some of the nation’s most rural states, enrollment has increased four and five fold. See The Rural School and Community Trust, Why Rural Matters: 2011-2012 (Jan. 2012). Much of this Latino growth in rural areas includes ELL and migrant students and for many of these rural districts this is the first time they have encountered Latino families and students. The measure of RTT-D innovation in rural districts should be right-sized to account for newcomer populations present in those communities.

o Recommendation: The Department should require rural districts applying for RTT-D funds to demonstrate how they will improve student performance for ELLs and migrant students.

• Selection Criteria: MALDEF’s review of the RTT-D Selection Criteria Section does not disclose any affirmative check for whether an applicant district is in compliance with current civil rights laws or that they are affirmatively engaging parents and other stakeholders representing all student subgroup interests. Caution here is warranted. Whereas the waiver applicant states had an affirmative obligation to engage community based organizations and civil rights stakeholders, many of them failed to carry and/or persuade the larger public that they did so. The Department nevertheless approved many waiver applicants regardless of these deficits. Now is the time to avoid a similar negative result with RTT-D.

o Recommendation: MALDEF encourages the Department to add a similar consultation requirement and hold applicant districts to carry this burden with demonstrable evidence of such stakeholder engagement. For example, under (B)(3)(b) of the Selection Criteria Section, “Letters of support from such key stakeholders,” the Department should add the following:

“(b) Letters of support from such key stakeholders as parents and parent organizations, early learning programs, the business community, civil rights organizations, advocacy groups that represent English language learners, special education students, and migratory students, local civic and community-based organizations, and/or institutions of higher education (IHEs).”

Moreover, MALDEF requests that the Department add a more explicit assurance requirement that an applicant district is not engaged in impermissible discrimination. One place to capture such a civil rights compliance assurance might be Selection Criteria Section (C)(3)(b)(i), “The extent to which the LEA and school infrastructure supports personalized learning,” which could be amended to read:

“(i) Ensuring that all participating students, parents educators and other stakeholders (as appropriate and relevant to students’ teaching and learning) have equitable and sustainable access, regardless of income, race, ethnicity, gender, disability, English language learner status, migratory status, or other protected categories, to content, tools, and other learning resources both in-school and out-of-of school.

• Competitive Preference Priority – Results, Resource Alignment, and Integrated Services: Latino and African American students are vastly overrepresented in the nation’s worst performing schools. Students show that 39 percent of Latinos and nearly half of African American attend high schools where graduation is not the norm. See UCLA Civil Rights Project, Historic Reversals, Accelerating Resegregation, and the Need for New Integration Strategies (Aug. 2007). Not surprisingly, high-minority schools are five times more likely to have weak promotion power, which correlates with high dropout rates. See id.

o Recommendation: We join the June 8, 2012, recommendations of the Alliance for Educational Excellence concerning dropout recovery and early warning indicator and intervention systems. MALDEF too encourages the Department to add a second competitive preference priority, which focuses on districts that present persuasive plans to (1) create and factor in early warning indicators of weak promotion power at the middle school level and dropout issues at the high school level, and (2) personalize interventions to put those students at risk of dropping out back on track. The premise of RTT-D is to foster innovation. To proceed without fostering innovation around persistent dropout patterns seems shortsighted and stagnant.

• Definitions: The Definitions Section defines all use of student subgroups in the RTT-D program under the narrowest definition of subgroups – Section 111(b)(2)(C)(v)(II) (“economically disadvantaged students;” “students from major racial and ethnic groups;” “students with disabilities;” and “students with limited English proficiency”) – under NCLB. Yet an RTT-D applicant district’s vision, capacity, success, preparation for college and careers, results, resource alignment, and integrated services cannot and should not be measured without affirmatively factoring in gender equity and the needs of migratory students, the two major student subgroups excluded under Section 1111(b)(2)(C)(v)(II) but factored in under other portions of NCLB, including Section 1111(h)(1)(C)(i) and elsewhere.

o Recommendation: MALDEF encourages the Department to apply the broader subgroup definitions, inclusive of gender and migratory status, wherever possible in the RTT-D program requirements, priorities, selection criteria, and definitions.

• Selection Teams and Transparency: MALDEF commends the Department for factoring in peer reviewers for waiver applications who are knowledgeable on the needs of ELLs and students with disabilities. We encourage the Department to tap its resources to similarly ensure that the selection table for the RTT-D awards has seats for those with expertise in ELL education, special education, and migrant student education. Also, in keeping with the Department’s commitment to transparency with waiver applications, MALDEF also encourages the Department to take steps to inject transparency into how RTT-D districts are selected.

Thank you for your time and attention to these matters. Please do not hesitate to reach MALDEF’s DC office if you have any additional questions or needs.

Respectfully,
Mexican American Legal Defense and Educational Fund (MALDEF) Washington, DC

Regarding the the lack of any priority for proposals that would increase diversity and avoid racial isolation in schools. We see "education reform" and encouragement of diversity in schools as efforts that can and should go hand-in-hand:

I am the First Vice President of the Minsters Conference of Winston Salem (NC) and Vinicity and we as a body of ministers have been working on the issue of the changing demographics from more diverse school setting to more segregated setting. It is amazing to us that over 50 years ago the Supreme Court found that "separate but equal education" to not be the most effective means of the educating all children. So now we find research case after case revealing that separating children by race still yields poor rests when it come to educational profficiency. In a most recent study, it has been confirmed that teachers impact the performance of the student by their atitudes and behaviors in the classroom and the combination of segregated schools and poor teacher influence make for to disasterous results for any school system.

Conclusion: Local School Systems should not be left to their own decisions alone but should have mandated and enforced goals from the U.S. Department of Education for diversity and academic performance for all schools! Current school systems do not and can not produce an effective education plan for a "safe and equitible education" for all of our nations children. We have failed at education because education has been left to state and local decision making processes that do not have all children's interest at heart!

Honorable Secretary Duncan,
 
We commend the U.S. Department of Education and the Administration for this new round of District level competition. Unfortunately, in the previous State Race to the Top competition many worthy organizations were not able to compete because their States did not want to participate in this competition. The biggest disservice was not only to community-based organizations and school districts, but most importantly, to the children and communities in these states that lost out on the opportunity to improve their educational systems.
 
We are fortunate to be headquartered in the City of San Antonio where we have a progressive Mayor who has made education a priority for this City but we would also like to see the many other cities and states we serve to benefit from this program. We are looking forward to this new round of District-level competition as there are many organizations like AVANCE National that for years have been serving children and communities who are most in need. We ask that in this round of competition you also give strong consideration to programs and organizations that work with children and parents in the early years from 0 to 3. As we all know, these are critical developmental years for children.
 
Therefore, it is important that quality, holistic programs that address the cognitive development needs of children 0 to 3 as well as work with parents to enhance their parenting, nurturing and nutritional education also have the opportunity to participate and compete for these grants. Our philosophy and motto "Parents the First Teacher. Home the First Classroom," recognizes that the child does not learn solely in the classroom but that, particularly our most at-risk communities, require parents to also prepare their children to succeed in order to break generational cycles of poverty.

It is programs like AVANCE's Parent-Child Education Program and others in the early childhood learning arena that help ensure that children enter the school system ready to learn and succeed and that their parents are equipped with the life skills and know how to provide nurturing environments at home.
 
Once again, we commend you for this round of competition and ask you that you strongly consider expanding this grant to include early childhood learning programs.
 
Sincerely,
 
Glendelia M. Zavala, Ed. D.
AVANCE, Inc.
San Antonio, Texas
 

The following are joint comments on the draft criteria for Race to the Top – District Competition from Tom Torlakson, California State Superintendent of Public Instruction and Sue Burr, Executive Director of the California State Board of Education and Senior Education Policy Advisor to Governor Edmund G. Brown Jr.

Thank you for the opportunity to comment.

1. The purpose of the 5-day state comment period (Application Requirement 1) is not clear. If the purpose of the comment period is for the state to thoroughly review the application and provide feedback to the district, 5 days is not enough time to do so. If the purpose is to provide the application to the state as a courtesy, then the 5-day period is not needed and can be eliminated.
2. The final criteria and application should state more explicitly that the state has no role in approving the application and no obligations in implementing the district’s proposed plan. This is particularly important given that there is no state-level review of the lawfulness of the proposed plan or its potential fiscal impact. The final application should make clear that any implementation problems or delays will be considered the sole responsibility of the district grantee and all solutions to such problems will be negotiated directly between the district and the U.S. Department of Education.
3. The application should require that districts provide an opportunity for public comment on their application, consistent with the open meeting laws of their state, to ensure that there is sufficient time for review at the local level. This will help identify potential conflicts with existing local policies and agreements and avoid problems with implementation.
4. It is imperative that the application and grant ensure that district applications will not obligate the state to a monitoring or compliance role in any way and that any requirement for the grant will be met by the LEA or consortia of LEA’s and will not be contingent on changes to state law or regulations or additional state revenue or resources.

I support comments posted by NSBA yesterday.

I support comments posted by NSBA yesterday.

June 8, 2012

The Honorable Arne Duncan
Secretary
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202

RE: Race to the Top – District Level Competition

Dear Secretary Duncan:

As a bipartisan advocacy organization dedicated to making children and families a priority in federal policy and budget decisions, the First Focus Campaign for Children presses for policy changes to improve the well-being and protect the rights of the next generation of America’s leaders. In all of our work, we seek to raise awareness regarding public policies impacting children, youth and families and to ensure that related programs have the resources necessary to help children grow up in a nurturing environment.
Chief among our organization’s priorities for K-12 education policy is the encouragement of bold comprehensive reform in elementary and secondary education. Because we believe that the Department of Education’s Race to the Top-District (RTTT-D) competition provides an opportunity for elementary schools to engage partners in the early childhood education and place a greater emphasis on indicators related to conditions for learning (student safety, health, engagement and support), we respectfully ask that the Department give serious consideration to the following two issues as the RTTT-D initiative continues to be developed:

1. School districts that apply for Race to the Top District funds should be further encouraged to align early learning programs with elementary schools as a school turnaround strategy.

Decades of research has shown that high-quality early learning is foundational to success in school and in life. Children from low-income families enter kindergarten with half the vocabulary of their middle-class peers. By the time these students are learning to read, they are already far behind, and are less likely to succeed in school. There is a key opportunity with the RTT- District competition to encourage greater coordination and collaboration between early childhood programs and elementary schools in need of improvement. By incentivizing elementary schools to work with early childhood programs (such as Head Start) to create stronger collaborations and better transition policies and practices, we embolden elementary schools to review their policies and practices to be “ready schools” so all children have the quality teaching, supportive services, and family engagement that makes the school conducive to every child’s learning success.

A competitive preference priority should be offered to applicants proposing to include their local early learning programs in enhancing the continuity of learning and development that sets a strong foundation throughout the K-12 school years and beyond.

2. School districts that apply for Race to the Top District funds should be encouraged to effectively assess and measure conditions for learning and implement proven strategies to continuously improve the teaching and learning environment.

For purposes of eliminating barriers to learning and ensuring that students are safe, healthy and engaged, it is critical for schools to strengthen and expand proven programs that increase the number of students:

Who are safe and not victims of bullying or other violence
Who are mentally and physically healthy
Who are engaged in school, avoid chronic absenteeism and dropping out
Who have strong social and emotional skills

Effective instruction is at the heart of student achievement. In order for students to reach high standards, we must also address the needs our children bring with them into the classroom. As you know, a study by the Educational Testing Service outlined 16 factors that correlate with student achievement--over half of these factors occur outside of the school building. Such factors include forced mobility, environmental hazards, hunger (nutrition), and health care, which puts students so far behind by the ninth grade that their prospect for on-time graduation is dim. We must create safe and healthy learning conditions that help diminish barriers to learning and promote environments that are more conducive to closing the achievement gap.

A competitive preference priority should be offered to applicants proposing to accomplish one of the following for improving the conditions for learning:

a) Prevent bullying, harassment, and violence in schools. Five percent of all students, and one-third of LGBT students, skip school because they feel unsafe. Under the RTT-district competition, districts should be encouraged to establish policies to prohibit and prevent bullying and harassment of all students, regardless of their race, color, national origin, sex, disability, sexual orientation, gender identity, or religion. Schools should be further incentivized to gather data that they can use to identify strengths and weaknesses, and to address them through comprehensive, evidence-based programs.

b) Provide a supportive environment that promotes mental health, and models positive social and emotional skills. School counselors, school social workers, school psychologists, and other support staff play a vital role in supporting learning by fostering a positive school climate and providing mental health, counseling, and early intervention services. The RTT-District competition should further encourage school districts to support these essential staff, and to link with local mental and behavioral health systems to ensure continuity and coordination of services.

We honor the Race to the Top - District initiative by the Department of Education to help improve the current situation of public schools in America. As this new competition unfolds, we look forward to working with you to ensure that our most disadvantaged students and communities are given the resources and assistance needed to provide an equitable education.

Sincerely,

Bruce Lesley
President
First Focus Campaign for Children

The New York City Department of Education (NYC DOE) would like to commend the US Department of Education for its continued commitment to improving the outcomes for all students through Race to the Top. This federal investment has already enabled the NYC DOE to initiate, continue and enhance many reforms that are directly leading to increased student achievement. The NYC DOE would also like to applaud the US DOE’s focus on district-level innovation, and its emphasis on creating personalized learning environments through Absolute Priority 1. The NYC DOE is deeply committed to supporting schools as they seek to better meet the needs, strengths and motivations of each and every student, including ELLs and students with disabilities, and believes this transition is critical to preparing students for success in K-12, college and beyond.

The NYC DOE strongly urges that an exception be created for districts that have mayoral control to exempt them from the eligibility criteria requiring evaluation protocols for the Superintendent and Board of Education. This eligibility criterion presents potential challenges for mayoral control districts, which have different governance structures. Rather than focus on the performance of a set of individual administrators, these districts should be able to identify mechanisms by which they are measuring and holding themselves accountable for district-wide student achievement gains (e.g., increases in graduation rates, college-going rates, etc).

In addition, because the RTTT-D Absolute Priorities include decreasing the achievement gap across student groups, the USDOE is strongly encouraged to provide flexibility and motivation for LEAs to utilize RTTT-D to fund interventions prior to the Kindergarten year, when 50% of the achievement gap is already present. This could include investing in partnerships and systems that (1) facilitate a child’s transition from early childhood settings into K-12, (2) build horizontal alignment, increased early childhood opportunities in high needs areas, and quality standards across diverse early childhood settings in the LEA, and (3) develop a key rigorous, relevant, and actionable measure of the percentage of children who are school-ready when entering Kindergarten. LEAs are in a unique position to leverage federal, state, and local funding to increase the amount of quality early childhood education programming to high need families prior to Kindergarten.

David Weiner
Deputy Chancellor
NYC DOE

Generations United is the national membership organization focused solely on improving the lives of children, youth, and older people through intergenerational strategies, programs, and public policies. We promote education policies that expand access to quality pre-k and early childhood education programs, facilitate the transition of more schools into intergenerational shared sites, assist and include grandfamilies, support multigenerational and civic engagement opportunities, and promote partnerships with older adult organizations to promote intergenerational programs.

We appreciate that the U.S. Department of Education (ED) included intergenerational activities within the Race to the Top Early Learning Challenge. This inclusion leverages experience and scarce resources to ensure positive outcomes for children and provides benefits for older adults as well. Research shows that intergenerational shared sites provide substantial benefits for children as well as significant benefits for older adults who regularly volunteer with children. Studies have also shown that youth who are involved in intergenerational mentoring programs demonstrate improved grades, significant decreases in school absences, and decreased suspensions from school.

Generations United commends ED for including family involvement throughout the Race to the Top District (RTT-D) proposal, with specific focus on family and community assets and outcomes in the Competitive Preference Priority. Within RTT-D, we urge ED to ensure that older adults are explicitly included as an important resource to the educational community, and recognized for the role they play in students’ lives.

The Consortium for School Networking (CoSN) appreciates the opportunity to provide input on the draft application documents for the Race to the Top District (RTTD) competition. CoSN is the premier professional association for school system technology leaders. The mission of CoSN is to empower educational leaders to leverage technology to realize engaging learning environments.

CoSN strongly supports this competition’s focus on personalized learning. Further, we believe that technology can and must undergird much of what the Department hopes to see in forthcoming RTT District applications – including personalized learning plans for all students, the ability to track and monitor individual and collective academic results, and the delivery of more engaging and empowering learning. Our view on the importance of technology to personalized learning is well reflected in the conclusion of a 2010 report issued by the ASCD, the Council of Chief State School Officers and the Software & Information Industry Association: “Personalized learning requires not only a shift in the design of schooling, but also a leveraging of modern technologies. Personalization cannot take place at scale without technology. Personalized learning is enabled by smart e-learning systems, which help dynamically track and manage the learning needs of all students, and provide a platform to access myriad engaging learning content, resources and learning opportunities needed to meet each students needs everywhere at anytime, but which are not all available within the four walls of the traditional classroom.”

In our review of the RTTD draft application documents, we noted that they did not contain as a clear a link between technology and personalized learning, something we believe is warranted and necessary. While the term “digital learning content” appears in selection criteria C (“Preparing Students for Colleges and Careers”) and receives a definition, the term “technology” only appears a few times and merits no definition. Thus, it is unclear whether the very devices and equipment that are supposed to deliver digital content are eligible for support in this competition. While we understand the Department’s interest in allowing applicant’s to use a variety of tools, both technology and non-technology oriented, we are concerned that the lack of explicit references to technology and the absence of a definition of technology within the final application may lead applicants to conclude that the Department does not support or, perhaps, disfavors technology as a component of their applications.

Therefore, CoSN recommends the following changes to the application, which we believe will demonstrate to applicants technology’s relevance and importance to personalized learning as well as its eligibility for support under this grant:

1) In every place that the term “tools” appears, add the term “technology.” Specifically, we have identified the following places where the term “technology” should be inserted:

1. Background – “21st Century tools and technology”;

2. Absolute Priority 1 – “the personalization of strategies, tools, technologies and supports for teachers and students…”

3. Selection Criteria C (preparing Students for College and Careers), Learning – (b) With the support of parents, teachers and other educational support specialists and personnel, students are provided the strategies and tools, including technology…”

4. Selection Criteria C (preparing Students for College and Careers), Learning – (c) “Mechanisms are in place to provide training and support to students to ensure that they understand how to use the tools, technologies and resources provided in order to track and manage their learning.”

5. Selection Criteria C (preparing Students for College and Careers), Teaching (a) (v) “Use data, including technology, and tools for personalized learning to develop plans for each student and to manage how groups of students accelerate their progress toward meeting college and career ready graduation requirements...”

6. Selection Criteria C (preparing Students for College and Careers), Teaching (b) “All participating educators have access to and know how to use tools, technology, data, and resources to accelerate student progress toward meeting college- and career-ready graduation requirements.”

7. Selection Criteria C (preparing Students for College and Careers), Teaching (c) “All participating school leaders and school leadership teams (as defined in this document) have policies, tools, data, technology and resources to structure schools as effective learning environments that meet individual student academic needs and accelerate student progress toward meeting college- and career-ready graduation requirements.”

8. Selection Criteria C, Policy and Infrastructure (b) (i) “Ensuring that all participating students, parents educators and other stakeholders (as appropriate and relevant to students’ teaching and learning) have equitable and sustainable access, regardless of income, to content, tools, technology and other learning resources both in-school and out-of-school.”

2) Insert the following definition of technology within the draft’s “Definitions” section: “TECHNOLOGY.—The term ‘technology’ means modern information, computer and communication technology products, services, or tools including, but not limited to, technology equipment for classroom usage, Internet and other communications networks, computing devices and other computing and communications hardware, and software applications, data systems and other digital content, and data storage.”

Additionally, CoSN notes that this draft application lacks language and requirements supporting in-kind donations. Many other USDE competitions encourage in-kind donations as a way of demonstrating broad community support for applications and leveraging money awarded. We believe that adding language into the application that fosters in-kind support is beneficial to individual applicants and the overall program and urge the Department to consider the following changes:

1) Under Selection Criteria B, District Capacity and Success Factors, add: “3) c) Documents pledging meaningful in-kind support, which may include tools, technology, digital content, and professional development, from businesses, foundations and/or non-profits with experience serving the k12 community.”

2) Under Selection Criteria E, Budget and Sustainability, insert in-kind donations (as shown) into the following statement: “The extent to which – 1) The application’s budget, which includes all funds that will support the project (e.g., Race to the Top grant; external foundation support; local, State, and other Federal funds; in-kind donations of tools, technology, digital content, and professional development, from businesses, foundations and/or non-profits with experience serving the k12 community; or other support)”

We are pleased with this opportunity to add our thoughts and support fully the Department’s personalized learning direction in this application.

HOPE Fair Housing Center (Wheaton, IL) submits the following comment in response to “Race to the Top District Competition Draft.”

HOPE is concerned with the lack of any priority for proposals that would increase diversity and avoid racial isolation in schools. Discrimination in housing and discrimination in education are tightly woven, as one often leads to the other, forming cycle that is difficult to break. Fair housing is a fundamental right and a diverse learning environment is one of the major benefits of fair housing.

The importance of diversity in our education system has been widely acknowledged. Attorney General Eric Holder has stated that “diverse learning environments promote development of analytical skills, dismantle stereotypes, and prepare students to succeed in an increasingly interconnected world.” The National Commission on Fair Housing and Equal Opportunity reported that “minority students who attend diverse schools are more likely to graduate from high school, attend and graduate from college, and connect to social and labor networks that lead to higher earning potential as adults.” Diverse learning environments are beneficial to students of all races. School diversity has been shown to reduce racial prejudice, increase racial tolerance, and even improve critical thinking skills. Creating diverse schools will lead to diverse communities and help create true integration in housing. School integration will lead to shared communities and neighborhoods which, according to recent research lowers stereotyping and prejudice, both on conscious and subconscious levels. This is one of the many reasons there needs to be a priority for proposals that would increase diversity and avoid racial isolation of schools.

The Department of Education issued the “notice of final supplemental priorities and definitions for discretionary grant programs” on December 15, 2010. The notice outlines the permissible basis for a preference in federal funding competitions. Promoting diversity is listed as Priority 11 under Section II- Addressing the Needs of Student Subgroups (specifically, projects that are designed to promote student diversity, including racial and ethnic diversity, or avoid racial isolation). The Department also issued new guidance on December 2, 2011 that supports voluntary efforts to promote diversity and reduce racial isolation in education. The guidance clearly states that educators may consider the race of students in carefully constructed plans to promote diversity in education. The Supreme Court has also explicitly authorized race-conscious strategies which do not involve assignment of individual students, to integrate schools. In a recent decision, Justice Breyer wrote that racially diverse classrooms positively impact student achievement, intergroup relations, and life course trajectories. Accordingly, districts striving to end racial isolation and segregation should get priority over those that choose not to.
HOPE urges the US Department of Education to include racial diversity as a priority in its Race to the Top District Competition. Competitors should be required to show commitment to increasing diversity throughout the LEA. This competition provides an important opportunity for the Department to implement its stated commitment to school diversity in its most important competitive funding program. Equal education and fair housing go hand in hand. Without fair housing, diverse learning environments are almost impossible and without diverse learning environments, segregation is sure to continue.

Texas AFT offers the following comments regarding the announced elements of the Race to the Top--District proposal:

1. The provision for educator involvement in developing a district's application for an RTT-D grant does not go far enough as applied to non-collective-bargaining states such as Texas. First, though Texas may lack collective bargaining per se for school employees, the requirement of sign-off by the local union/association president should be extended explicitly to situations where local district policy has established formal consultation mechanisms with a representative employee organization negotiating on behalf of all employees in the unit. In addition, the requirement of evidence of support from 70 percent of educators involved should be modified to require specifically that at least this level of support be demonstrated by voting.

2. While this RTT-District proposal sets a laudable goal of flexibly developing individualized instruction plans, it undercuts the achievement of that goal by incorporating the overly prescriptive requirements of the SIG program and the state-level Race to the Top model, especially regarding school-improvement options and teacher evaluation based largely on an impoverished measure of student achievement derived from scores on state assessments. (See Texas AFT's prior comments on regulations implementing SIG and RTTT.) The proposal should be modified to encourage other possible improvement models such as community schools, and the requirements regarding teacher evaluation should be altered to de-emphasize state achievement tests. There is no substantial evidence of the effectiveness of programs meeting the Department's mandatory school-improvement and educator-evaluation design criteria. Over-emphasis on state standardized assessments under both our state and federal accountability systems already has had the effect of dumbing down instruction, narrowing curriculum, and encouraging the very one-size-fits-all approaches that the Department of Education professes to abjure.

3. The proposal also fails to take into account the resource constraints affecting school districts' capacity to implement all of the many facets of the RTT-District proposal. For example: From an already inadequate base level of funding, Texas school districts in the current biennium have suffered state-imposed budget cuts averaging more than $500 per pupil per year, with serious detrimental effects on students' educational opportunity. For a major urban district such as Houston ISD, the maximum RTT-District grant, at $20-25 million (roughly $100-125 per pupil district-wide) would not even begin to make up for lost state aid for a single year. Yet, as experts from the Milken Teacher Advancement Program have testified in the Texas legislature, effective implementation of just one piece of what RTT-District envisions--a new model of teacher evaluation and development--requires as much as $400 a year per pupil in targeted additional expenditures on a sustained basis, year after year.

4. Texas AFT continues to have a fundamental objection to the Race to the Top approach. This competitive approach guarantees that millions of children in districts that do not receive RTT grants will lose out on vital programs and services. Instead of using these competitive grants to promote unproven programs, the Department of Education should work to ensure that teachers in every classroom have the tools, resources, and conditions for teaching and learning that they and their students need to be successful.

Public Impact, an education research and consulting organization, appreciates the opportunity to comment on the draft guidelines for the Race to the Top District Competition. We are pleased to see several points in the guidance that encourage districts to expand students’ access to highly effective teachers. The Department is most likely to accomplish the aims of Race to the Top if districts find ways to sustainably extend excellent teachers’ reach to more students. In the process, districts will open up a wide array of opportunities for teachers who have achieved excellence to have more impact both directly and by leading and developing other teachers toward excellence, creating what we call an “Opportunity Culture.” In addition, we believe, as many do, that more teachers could achieve excellence if they had far more direction and plentiful, frequent feedback from those who have mastered the art of excellence in teaching.

We respectfully submit three comments, all designed to focus districts on enhancing excellent teachers’ impact.

  1. Improve performance measure related to number of students with highly effective teachers. We strongly support the inclusion of a measure of the number and percentage of students with access to highly effective teachers. This new metric encourages districts to think not just about how many teachers are highly effective, but also how to extend their impact to more students. We recommend two changes to strengthen the focus on excellence and the likely impact on students (rationales below):

    (a) The metric should be narrowed to reporting the number and percentage of students who are taught by highly effective teachers. Alternately, the metric should ask districts to report on “effective” and “highly effective” separately—that is, one set of measures for “effective” and one for “highly effective.” (This alternative may be the intention of the existing measure; clarification of two distinctly reported categories would help ensure that this intent is clear.)

    (b) Instead of measuring "daily access" to teachers, the metric should track the number and percentage of students whose teachers of record in the district's teacher evaluation system are highly effective.

    Rationale for (a): While good, solid teachers produce much better outcomes than the least effective, teachers in approximately the top 25% produce enough learning gains, on average, for students who start behind to catch up in a reasonable and motivating time period. Even with a teacher roughly in the middle of the top quartile, by some estimates it takes two consecutive years for a child who is one year behind grade level in a subject to catch up, and four consecutive years for a child who is two years behind to catch up. Students working at grade level need similar gains to become “honors students.”
    This kind of progress from one's beginnings at birth to achievement that exceeds those beginnings is the foundational hope of public education. Without aiming for consistent access to teaching excellence, no school or district can provide a trajectory-changing opportunity to large numbers of students.

    Rationale for (b): "Daily access” is both too loose and too tight of a standard. It is too loose, because “access” does not mean a highly effective teacher is actually responsible for a student's learning. Arguably all of a school’s students have “access” to a given teacher at that school. This form of the metric would not likely lead to meaningful increases in great teaching for students. "Daily access" is also too tight because some of the emerging school models that use blended learning involve approaches such as having students alternate days, with a teacher one day and in a digital lab the next, or having a remotely located teacher who may not be physically “accessible” despite full accountability for learning and strong, frequent personal connection using webcams and online whiteboards.

    In place of “daily access,” we suggest linking this metric to the teacher evaluation systems the district winners will be required to have under the competition's terms, counting the number and percentage of students whose teachers of record (in each designated subject) in those systems are highly effective. Both the districts and teachers of record then will be motivated to select means of extending each highly effective teacher’s reach that are likely to work with the specific teacher and students in a given school. The teacher’s “record” becomes professionally valuable to the teacher—(s)he can pursue opportunities to help more students and peer teachers based on it—and it becomes in everyone’s interest to extend reach responsibly.

    One complication this introduces is how to count students who have more than one teacher—which would be the case with all secondary students and some elementary students. The most accurate and simple approach would be to calculate for such students the proportion of their teachers in designated subjects who are highly effective. In the event that “designated subjects” are not defined in other parts of the guidance, we suggest that they be defined by each district, but must include all English Language Arts (ELA) and math for elementary students, and ELA, math, science, and social studies for secondary students. (We suggest that the Department encourage districts to measure excellence in other subjects as well, and include those teachers in the career advancement opportunities that become available when teachers can extend their reach.) So for example, if a student had 5 teachers in designated subjects and 3 were highly effective, this student would count as 0.6 in the count of the number of students with highly effective teachers.

  2. Reward high-quality plans for expanding access to highly effective teachers. Because expanding access to the most effective teachers is part of the competition’s absolute priority, the application should ask districts to present a high-quality plan for meeting this priority—for example, as part of the current Section C, Part 2 (Teaching). Specifically, districts should be awarded points for presenting high-quality plans that specify how schools will implement designs that:

    - change staff roles, school schedules, and/or the use of technology in ways that increase the number of students whose teachers of record in designated subjects are highly effective;
    - enable highly effective teachers to earn more for reaching more students as the teacher of record;
    - are financially sustainable with current per-pupil funding, after covering temporary, transitional costs; and
    - specify the new means by which teachers who have not achieved highly effective status can increase their effectiveness.

    The application should allow districts to meet this criterion by presenting specific school designs that qualify, or by proposing processes by which existing or new schools will compete for the opportunity to devise and implement qualifying designs.

  3. Reward policy conditions for expanding impact of highly effective teachers. The competition should award points to districts for putting into place a variety of policies/conditions that are important to enable highly effective teachers to reach more students. Among the most important, districts should receive points if their policies (and their state’s policies that govern the district):

    - Enable identification of highly effective teachers (even if a more fully developed teacher evaluation system is not yet in place);
    - Place no limits on increasing class sizes of highly effective teachers, voluntarily and for increased pay proportional to the increased class size;
    - Enable highly effective teachers to earn higher pay than the regular salary schedule for reaching more students; and,
    - Permit paraprofessional staff to monitor students during core instructional time, provided that the student’s teacher of record is an effective or highly effective teacher (this is important to enable blended learning without diminishing the critical role of adults who are accountable for learning outcomes)

Thank you again for the opportunity to provide comment.

Respectfully yours,
Bryan C. Hassel and Emily Ayscue Hassel, Co-Directors, Public Impact

Eligibility Criteria 4.a.
As representatives of a large, urban school system, we would like to recommend that the eligibility requirements be re-written as follows:
4.a. The LEA has, at minimum, designed and committed to implement no later than the 2014-2015 school year.
i. a teacher evaluation system (as defined in this document);
ii. a principal evaluation system (as defined in this document);
iii. a LEA superintendent evaluation (as defined in this document); and
iv. a LEA school board evaluation (as defined in this document).
For LEAs that cannot meet the 2014-2015 deadline, a clear plan to implement the systems in 4.a.i through 4a.iv. must be provided. This plan must include the reasons an LEA or consortium of LEAs cannot meet the 2014-2015 deadline and a timeline for implementation.
We are recommending this modification for because
, for some LEAs, ensuring the quality of teacher-student links will require more time than is currently suggested in the RTT-D competition draft. Specifically, districts will require adequate time to transition to data systems that allow for identification of the primary literacy and math teachers for students in middle and high school grades who may rotate among teams of teachers for various subjects. Following adoption of such a data system, districts would require at least three full school years to validate the teacher-student links and pilot the value-added component of a multiple measures evaluation system before utilizing such data to inform personnel decisions.

In addition to the technical data system considerations, time should be provided to enable LEAs the opportunity to research, work with stakeholders and establish systems and mechanisms for the evaluation of Superintendent and School Board members as defined in the proposal. A tiered approach to full implementation of teacher, principal, superintendent and school board evaluation systems might be more prudent.

June 8, 2012

RE: Comments Related to Race to the Top District Draft Guidance

Submitted by: The Public Education Network
601 Thirteenth Street, NW, Suite 710S
Washington, DC 20005
Wendy D. Puriefoy, President

The Honorable Arne Duncan
Secretary
U. S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202

Dear Secretary Duncan:

Introduction:
Public Education Network (PEN) thanks you for this opportunity to submit comments related to the proposed competitive Race to the Top District guidance. We are pleased that the proposal addresses personalized learning strategies with the maximum involvement, support, and ownership of the public, promoting student-centered, research-based outcomes that recognize the importance of linking school and community in changing the ‘infrastructure, capacity, and culture” of the school district. This allows districts and communities to concentrate their efforts on authentic student achievement, and away from passing tests, one-size fits all models, and top-down mandates without recognizing the differentiated needs of various communities and their students. Our major regret is that there will only be a few districts that receive grants, rather than providing the resources to all districts that meet the proposal criteria, or would otherwise like to participate if they had the capacity. As you finalize the draft guidance, we ask that you consider recommendations that we believe will further strengthen the success of RTT-D.

PEN is a national network comprised of 77 Local Education Funds (LEFs) in 34 states, working to advance public school reform in low-income, both rural and urban, communities across the country. LEFs are unique education reform organizations with deep on-the-ground relationships with both public schools/districts and community stakeholders. They have developed nationally significant practices to enhance teacher quality and professional development, public engagement, partnering with district urban residency programs, increasing high school graduation rates, promoting college and career readiness, supporting coordination and integration of services, developing researched-based frameworks that move children from cradle to careers---all with a focus on public engagement and community and family involvement.

PEN is partnering with its LEFs to increase the number of prepared youth by:
• monitoring low-income students' progress toward college readiness;
• ensuring completion of college prep curricula (e.g., algebra in 8th grade);
• boosting completion of accelerated learning courses (Advanced Placement/dual enrollment in colleges);
• improving scores on college entrance exams (ACT/SAT);
• Effective teachers and principals
• increasing FAFSA (financial aid application) completion rates; and
• tracking college enrollment and persistence data.

Because local education funds represent a broad range of community interests at the school district and community level, they are well positioned to bring together the various community stakeholders and citizens in demanding high performing public schools for all students. In addition, research demonstrates they can build the civic capacity in advocating for equity, demand public accountability based on meaningful and “deeper” multiple measures of data, closing the achievement gap, implement and support best practices, and prepare students who are college and career ready.

As PEN comments on RTT-D, our lens will focus on a number of elements that cut across all aspects of change and improvement that, if not addressed, would greatly diminish the RTT-D innovation objectives in improving the most difficult schools, and increasing the number of students that are career and college ready. These include: functions of capacity; opportunities to learn; qualified teachers and principals; resources; middle and high school intervention; needs of our most disconnected youth; community and family engagement; shared accountability based on continuous progress and multiple measures, and an improved and expanded longitudinal data systems.
Race to the Top Competition Draft Introduction: Paragraph 4
“More specifically, RTT-D will reward those LEAs that have the leadership and vision to implement the strategies, structures and systems of support to move beyond one-size–fits-all models of schooling, which have struggled to produce excellence and equity for all children, to personalized, student-focused approaches to teaching and learning that will use collaborative, data-based strategies and 21st century tools to deliver instruction and supports tailored to the {add academic, social and emotional needs} of each student, with the goal of enabling all students to graduate college- and career-ready.”

Eligibility Requirements:
Rural School Districts
We are concerned about the requirement that applicants must meet a threshold of serving a minimum of 2,500 students. While consortia of district and long distance learning are promising strategies, there is a cost in personnel, bringing communities together, and face to face planning in developing consortia that may make such applications challenging, if not prohibitive for small and very poor rural districts. We have a lot to learn from the approximately 11 percent of the rural school districts that would be excluded from this proposal. Oour goal should

PEN’s recommendation is to set aside funding that is discretionary or formula-based to meet these needs, and/or offer special accommodations and personal assistance in helping smaller communities in meeting the logistical prescriptions in applying for RTT-D Size, geography, culture, history, and context can have an impact on everything from effect size, conditions for learning, opportunities, funding, and equity.

Middle and High School Preference
As a result of inadequate preparation during secondary school, 1.3 million students do not graduate each year, and in nearly 1,600 high schools, fewer than sixty percent of students graduate on-time. The nation’s low performing high schools and their feeder middle schools must be reformed. Without losing the systemic focus on a continuum of education from cradle to career, it is critical that middle and high schools preparing students for graduating and transitioning to postsecondary education receive focused attention within RTT-D.

Recommendations:
1. A competitive preference priority should be given to applications that focus their reform efforts on low performing middle and high schools serving large proportions of low income students.
2. The requirement that at least forty percent of participating students must be from low-income families should be raised to at least fifty percent for all eligible applicants and a competitive preference priority should be set for applicants serving more than fifty percent.
3. In addition, poverty at the secondary school level should be more accurately measured by requiring the use of a feeder pattern.

Application Requirements
1. The RTT-D draft application requirements should include a appropriate focus on personalization and the utilization of data to address specific student needs. Although the application requires data systems that link teachers and students as well as P-12 and higher education data, it does not explicitly call on districts to utilize data systems for the implementation of Early Warning Indicator Systems.

Recommendations: All RTT-D applicants should be required to implement early warning indicator systems that utilize on-track indicators to identify students who unlikely to be prepared for college-level work and provide them with tailored support. This should include:
• Attendance
• Behavior
• course performance
• credit accumulation, and
• other measures validated against postsecondary outcomes (e.g., college entrance,
remediation rates, college completion, industry certification, career entry, etc.).

The use of an Early Warning Indicator System should not be a prerequisite for the receipt of a RTT-D grant; rather RTT-D funds should be utilized for the development and implementation of these systems.

2. “Be signed by the Superintendent/CEO, local School Board President, and local Union/Association President, {add major school and community stakeholders including community-based organizations and national and local education funds and other intermediary education organizations} (where applicable).”

Selection Criteria:
A. Vision
“The extent to which the applicant's vision will translate into increased improved student performance and equity as demonstrated by ambitious yet achievable annual goals, overall and by student subgroup (as defined in this document), for each participating LEA, in the following areas:
1. Performance on summative assessments (status and growth);
2. Decreasing the achievement gaps (as defined in this document);
3. Graduation rates (as defined in this document);
4. Credit Accumulation
5. College enrollment (as defined in this document) rates;
6. Student attendance(as defined in this document); and
7. Teacher attendance (as defined in this document);

8. {add Student chronic absenteeism}
9. {add Social and emotional development}
10. {add Development of metrics to gauge community engagement}
See measures above under Application Requirements, 1)

Strengthen the role for local education funds (LEFs) and other national and local intermediary organizations
The emerging field of personalized instruction focused on the low-income and low achieving schools is fortunate to have strong intermediary organizations and local education funds that play community engagement and instructional roles at the school district and school(s) level. These organizations serve as a resources in working with school districts to improve program quality, foster public-private collaboration, disseminate best practices, support educator professional development, promote school district report card data and utilization of data, and serves as a partner in supporting such mechanisms as student trackers, accelerated learning, and coordinated supports. As a result, we believe it is critical that such organizations have a strong role in the RTT-D applications, including the development, review and support of the application as described in the guidance. Many schools and non-profits lack the capacity by themselves to personalize instruction leading toward college and career readiness, and strong local education funds and national and local intermediary organizations have the capacity to fill this role effectively.

B. District Capacity and Success Factors
PEN recommends that this section be changed to:
Community and District Capacity and Success Factors

The addition of community is consistent with one of the goals of the RTT proposal: linking school district and community collaboration including municipalities with student centered instruction and capacity. In a labor-management document just released and signed by Secretary Duncan and six major national education organizations, it was recognized that “no community can flourish unless its children are safe, healthy, well-nourished, and well-educated; and no school can be a strong pillar of a thriving community without deep community responsibility for and ownership of the school’s academic success. Thus, recognizing that the fate of communities and their schools are inextricably linked, we must make schools stronger by educators embracing community resources, expertise, and activities; and we must make communities stronger by anchoring them around highly effective schools.

B3) under Community and District Capacity and Success Factors
“Meaningful stakeholder engagement and support”
PEN joins with the Coalition for Community Schools in applauding the Department’s focus on engaging local stakeholders.

For letters of support from key stakeholders (B3b) to be meaningful, these stakeholders must also have a voice in the planning process (B3a). This change would be consistent with the Department’s continued emphasis on deep community engagement and PEN’s emphasis in linking school and community.

Consequently, we propose adding to 3a the following in italics:
“A description of how families, teachers, and principals in participating schools (as defined in this document) and such key stakeholders as parents and parent organizations, students and student organizations, early learning programs, the business community, civil rights organizations, advocacy groups, local civic and community-based organizations, local government agencies, and/or institutions of higher education (IHEs)l…” In addition, PEN would add local education funds and other local and national intermediary organizations.

To strengthen the definition of key stakeholders throughout the document, we suggest adding a new definition to the guidelines based on the existing language.
Key Stakeholders: Includes parents and parent organizations, students and student organizations, early learning programs, the business community, civil rights organizations, advocacy groups, local civic and community-based organizations, local government agencies, local education funds and other local and national intermediary organizations, and/or institutions of higher education (IHEs).

C. Preparing Students for College and Careers; 1) Teaching a) and b)
Consistent with the definitions under “Community and District Capacity and Success Factors” above, we recommend that stakeholder support be expanded. In the communities they serve, LEFs working with their partners, have committed themselves “to increase by 100,000 the number of high school students who graduate, or are on track to graduate, college and career ready, by 2013.” The work of LEFs along with many other community stakeholders around the country demonstrates the importance of broad partnerships partnership working in concert to ensure that personalized learning is achieved and leads to increased college and career readiness. Under these two sections, we note that the role of community partners and LEFs is noticeably absent from the key actors responsible for learning in this section. We suggest changing C1a and C1b to include the italicized:

“With the support of parents, teachers, and other educational support specialists and personnel, and such key stakeholders as

D. Preparing Students for College and Careers; 2) Teaching c)
We suggest modifying the definition of “school leadership team” which is used in 2c to more clearly define “community members.” We suggest adding: “community members and a representative of key community stakeholders”. We further suggest that the Department add “community stakeholders” as a definition in the guidelines and which should be defined according to existing language in the guidelines: Key stakeholders includes: parents and parent organizations, students and student organizations, early learning programs, the business community, civil rights organizations, advocacy groups, local civic and community-based organizations, local education funds and other local and national intermediary organizations, and/or institutions of higher education (IHEs).

2) Teaching
Add “d” to read: All participating educators work with community stakeholders as partners in exploring experiential models where students' (including pre-service teachers') education involves transformative experiences that include a clinical model of teaching, research, and practice both within the classroom and outside it building on well-established models of participatory learning, apprenticeship, mentorship, coaching and requires strong partnerships between universities, school districts, community stakeholders and industry.

1. Work with the school district and higher education to create partnerships with higher education and community stakeholders to support highly effective recruitment efforts, preparation programs, induction and professional development services through the first seven years of a teacher’s career, and across principalship tenures that includes coaching, mentorships, shadowing, continuous professional development, observation, feedback and improvement, especially for those teachers needing special preparation in special education, ELL, STEM and intervention schools.
2. Provide parents and the community information about teacher qualifications such as certification, expertise in content area, teachers who are still in training, and disaggregated by student disability, income, ELL and ethnicity related to the schools in their district. This should include notice to Title I parents as to whether their child’s teacher is currently enrolled in an alternative certification program, or has been taught for four or more consecutive weeks by, a teacher who is participating in an alternative route to certification program.
3. Collect annual information about school and district climate, leadership, and community services that are coordinated and accessible to teachers, students and families in support of personalized instruction
4. Work with the district in creating community and higher education partnerships, helping to connect parents and teachers, promote home and school visitations, and build support for such experiments as using time differently, year round schools, summer programs, 21st Century Alliances, and digital learning
5. Teacher evaluation systems should focus on building the teacher profession and on a system of evaluation developed with the input of key stakeholders including parents and parent organizations, students and student organizations, early learning programs, the business community, civil rights organizations, advocacy groups, local civic and community-based organizations, local education funds and other local and national intermediary organizations, local education funds and other local and national intermediary organizations, and/or institutions of higher education (IHEs).
6. School districts should establish data systems that connect school-based data (i.e. academic, attendance, behavioral) with nonprofit service provider data (e.g. tutoring and after school). With such a system in place, districts will be able to work with providers more effectively and efficiently, students get exactly what they need to succeed, and funders and policymakers can better determine which programs are working, and which ones are not. School-level resource coordination will be important to the success of these systems.

Often, the community stakeholders are overlooked in teacher recruitment, induction, retention and professional development. In addition, RTT-D works with the teachers already in the classroom, whereas community stakeholders can work with the district to create new talent pipelines such as grow-your-own models, STEM inservice, and urban residency Some of the more successful pipeline programs have involved community partnerships with the school district and higher education. For instance,
• PEN believes that using the teacher urban residency model, now being supported and led by PEN’s LEFs in Denver area, New York, Boston, Philadelphia, and Los Angeles, Chatanooga, and Seattle as well as elsewhere in the nation, provides the transformational model that can turn around difficult and struggling schools, and meet the objectives of RTT-D.
• Another example is Humanitas model employed by the Los Angeles Education Partnership which focuses on transforming the school to create more effective teaching and learning focusing on teacher effectiveness, and not on a minimum and arbitrary standards of “highly qualified” as in NCLB.
• Yes another example is that of the Public Education Fund of Chattanooga and the Benwood Initiative working with the most low-income schools to provide the kind of personalized professional development and support called for in the RTT-D producing staggering increases in reading and literacy.

PEN continues to be concerned about the distribution of less qualified teachers who are significantly overrepresented in schools that serve minority and low-income students. In fact,
schools serving the most African- American and Hispanic students are nearly twice as likely to be to employed to be teachers who are newest to the profession. In the most recent US Department of Education OCR report, the study concludes that there is a growing disparity between the least experienced teachers placed in schools with predominately African-American American and Latino students. It has been suggested that, even for highly effective teachers, the first few years of their career can be difficult. Research has shown that Black and White students have different levels of exposure to novice teachers (Clotfelter, Ladd, and Vigdor 2004). And according to the National Center for Educational Statistics (NCES), Schools and Staffing Survey (SASS), in most intervention models, the teacher workforce was more likely to be White, younger, and less experienced and more likely to have provisional certification after intervention than before it. In addition, the study found that the largest sector of current teachers has only one year of experience, a revolving door pattern of instability and inexperience, whereas in 1987-l988, the modality was 15 years of experience.

C. Preparing Students for College and Careers; 4) Performance Measurement
PEN joins the Coalition for Community Schools in recommending that surveys of educators (f) and students (g) should also include climate, culture, and the conditions for learning in order to paint a complete picture of the conditions in which teachers teach and students learn.

Thus, we suggest making the following changes to the definitions for student survey:
“Student survey: Measures students’ perspectives on teaching, learning, and related supports (e.g., school climate, school culture, and the conditions for learning) in their classrooms and schools. The surveys must be research-based, valid, and reliable. Over time these results should be predictive of rates of student growth.”
We suggest adding a parallel definition for educator survey (currently mentioned, but undefined) that would read:
Educator survey: Measures educators’ perspectives on teaching, learning, and related supports (e.g., school climate, school culture, the conditions for learning, faculty trust, etc.) in their classrooms and schools. The surveys must be research-based, valid, and reliable.
We strongly urge the Department to add a parent survey that would help districts learn more about parent engagement and their needs in supporting student learning. We suggest adding C4h) to read:
Parent survey: Measures parents’ perspectives on teaching, learning, and related supports (e.g., school climate, school culture, and the conditions for learning, teacher and principal support, opportunities for parent engagement) in classrooms and schools. The surveys must be research-based, valid, and reliable.
Lastly, we strongly urge the Department to add a community survey that would help districts and the community learn more about community and stakeholder involvement (see stakeholders definition above) and ownership in advocating for change and building public will to support the special needs of the most difficult schools: We suggest adding C4i) to read:
Community Survey: Measures and assesses individual and organizational community capacity and perspectives on their understanding of the academic and developmental student and school data, the needs of the most difficult schools, the supports they are able to commit and provide, and their responsibility in supporting quality public education for all children in their community. The surveys must be research-based, valid, and reliable.

Competitive Preference Priority for Middle and High Schools
A competitive preference priority should be given to applications that focus their reform efforts on low performing middle and high schools serving large proportions of low income students. The requirement that at least forty percent of participating students must be from low-income families should be raised to at least fifty percent for all eligible applicants and a competitive preference priority should be set for applicants serving more than fifty percent. In addition, poverty at the middle and secondary school level should be more accurately measured by requiring the use of a feeder pattern.

Budget Supplement
• Recommendation: PEN recommends converting the optional budget supplement to competitive preference priority for supporting the ttransition from high school to college and disconnected youth. Districts should be encouraged to focus attention on young people who are:
o among the least likely to enter postsecondary education; and
o students who are over-age/under credited and students who have dropped out of high school or are otherwise disconnected from the education system

In order to incentivize applicants to target our most vulnerable students and support the transition to college and career, the optional budget supplement should be converted to a competitive preference for applications that:

• Implements strategies for supporting the successful transition between secondary and post- secondary school through the expansion of rigorous secondary curricula (e.g., Advanced Placement and International Baccalaureate); effective models, such as dual enrollment and Early College High Schools; college-focused school counseling programs; and targeted assistance in grade 12 transition courses based on grade 11 grade assessments to reduce the need for remediation in postsecondary education; and
• Develops partnerships between the school district, the workforce system, employers, nonprofit organizations, and social service providers to identify and connect students who have dropped out of school, are exiting the juvenile justice system, or are over-aged and under-credit and connect them to education, job training, and wraparound support services.

In order to increase the number of students who enter and persist in postsecondary education, we recommend:
• focused efforts be made to ensure that high school students, particularly low-income high school students, are prepared for the rigor of postsecondary education. Such efforts can include:
o expanding school counseling programs;
o providing rigorous course options such as Advanced Placement, International Baccalaureate, early college high school, and dual enrollment; and
o offering further practices that create a college-going culture within high schools.

PEN recommends that the following data be collected on a longitudinal basis to measure and report performance on college and career readiness:
• percent and number of ninth graders who graduate college and career ready in four years
• percent increase and number of students on-track to be college and career ready
• percent and number of low-income/minority students being taught by effective teachers
• new assessments should be used to inform high school curriculum rather than high school exit requirements, pursuing better learning opportunities, rather than often counterproductive exit exams
• on-track metrics such as college preparatory course work in key subjects such as Algebra, GPAs, and credit accumulation; high school graduation rates;
• college acceptance, enrollment, and persistence rates
• student participation in college access, such as counseling, college visits

In addition, PEN recommends that when focusing on college and career readiness, that school districts with community partnership develop metrics, indicators and a report card which tracks the following student information and progress from the early years to college or a career based on a project led and coordinated by PEN Network member, Strive Together serving Cincinnati and Northern Kentucky.

1. Preparation for school
2. Every child will be supported in and out of school
3. Every child will succeed academically
4. Every student will enroll in college
5. Every student graduates and enters a career

Robert L. Hughes, president of New Visions for Public Schools, and one of PEN’s members talks about his experiences turning around struggling schools, “You need to have an accurate diagnosis of why each of those 5,000 schools [to which U.S. Secretary of Education Arne Duncan refers] are failing. It’s crucial. Sometimes you need a two-by-four to get change. Other times you need a scrapple.” In our view, RTT-D recognizes that changes is not about adopting yet another program, but seeks comprehensive restructuring and transformation based on institutional and school system capacity, competencies, public will, and trust in the democratic process.

Public Education Network and its members welcome the opportunity to speak more with you or your staff about how we can help you reach your goal for accomplishing the RTT-D objectives.

Sincerely,

Wendy D. Puriefoy, President and CEO
Public Education Network

************************************************************************************

June 8, 2012

The Honorable Arne Duncan
U.S. Department of Education
400 Maryland Ave., S.W.
Washington, DC 20202

Dear Mr. Secretary:

ASCD, representing more than 160,000 educators, appreciates the opportunity to comment on the notice of proposed priorities, selection criteria, and definitions for the Race to the Top District (RTT-D) competition. We support the department’s efforts to incentivize districts to personalize teaching and learning, encourage them to provide differentiated instruction, and require them to devise and implement effective evaluations.

We have several recommendations and questions that we hope will be addressed prior to posting the final application.

Selection Criteria—Vision: The RTT-D competition draft requires applicants to delineate a vision that “will translate into increased improved student performance...as demonstrated” by several specific indicators. However, the only indicators listed are those that pertain to college readiness. We hope that the Department does not intend to indicate a preference for college readiness over career preparation but recognize that both are legitimate paths for high school graduates. For many students, the measure of success after high school graduation will certainly be acceptance to and enrollment in college. However, for many more students, success will be post-graduation employment and so career-ready indicators should also be reflected in the district’s vision statement.

An additional measure required in the applicant’s vision statement is students’ performance on summative assessments. College, career, and citizenship readiness are not limited to proficiency on state standardized reading and math tests, but they include all disciplines and the comprehensive knowledge and skills required of students after high school graduation. Provid¬ing challenging, comprehensive curriculum across all content areas is essential for college, career, and civic preparation. Accordingly, curriculum and instruction in all areas must demonstrate high expectations for students and reflect evidence-based strategies. Measuring student achievement in all core content areas would provide a more comprehensive picture of achievement and growth. Thus, we recommend broadening the performance measure required in the vision statement to include multiple measures of student achievement in all core academic subjects including, but not limited to, subject areas in which statewide summative assessments exist, as well as requiring districts and schools to publicly report student achievement in core subjects, however it is measured or collected at those levels.

College- and Career-Ready Standards: We applaud the requirement that applicants adopt standards and assessments “that prepare students to succeed in college and the workplace and to compete in the global economy” as part of the core educational assurance areas. ASCD supports high standards for students, educators and schools. A rigorous curriculum and high standards are the means by which our children will receive a world-class education enabling them to compete in our global economy.

The current definition of college- and career-ready standards in the draft executive summary provides two types of acceptable standards. One is that states may use standards that are “approved by a State network of institutions of higher education.” We would appreciate clarification about whether this needs to be a discrete and affirmative certification of the standards by the state network of institutions of higher education. The question arises if the institutions of higher education in a state network are members of the National Collegiate Athletic Association (NCAA), which requires adherence to the association’s initial eligibility requirements for prospective student athletes. These requirements are intended to ensure that students can handle the rigors of first-year college coursework and thus be considered college ready. Initial eligibility criteria include a certification that students have satisfactorily met the state-required secondary school courses necessary for graduation. Would a state network’s membership in the NCAA (and application of its initial eligibility requirements) be sufficient to meet the draft’s certification of standards requirement?

Evaluations: ASCD supports rigorous but fair evaluations for educators and school leaders. Any evaluation of a teacher’s effectiveness must be based on a combination of inputs, including, but not limited to, student performance, classroom observations, and parental feedback. In addition, such evaluations must be used for educators’ continual improvement and professional growth. Evaluations for teachers and school leaders should include valid, clearly defined, and reliable performance standards and rubrics. School leader evaluations should also be based on demonstrated leadership skills, including providing a clear school vision and direction; implementing rigorous curriculum and related activities; and supporting a culture of learning, collaboration, and professional behavior.

The RTT-D Executive Summary definitions of teacher and principal evaluation systems should reflect all of these components, in particular differentiating between those components relevant to teachers from those relevant to school leaders.

The teacher and principal evaluation system definitions identify “data on student growth for all students” as a “significant factor” in the evaluation criteria. We recommend language to ensure that student performance or “student growth” constitutes not more than 50 percent of this measurement.

The proposed superintendent and school board evaluations are required to reflect “student outcomes performance”, rather than the “student growth” language in the teacher and principal evaluations. Would aligning the language in the four evaluation requirements provide clearer guidance to districts as they develop these evaluation systems? There is significant variance between student growth and student outcomes performance, the latter of which could be construed to reflect only testing results in reading and math. In any case, we would again urge the Department to ensure that this component does not constitute more than 50 percent of the evaluation of superintendents and school boards.

Personalized Learning: ASCD is pleased with the RTT-D’s strong focus on personalized learning, directing districts to differentiate instruction to meet the needs of each child. ASCD believes that a comprehensive approach to learning recognizes that successful young people are knowledgeable, emotionally and physically healthy, safe and cared for, motivated, civically inspired, engaged in the arts, prepared for work and economic self-sufficiency, and ready for the world beyond their own borders. Together, these elements support the development of a child who is healthy, safe, engaged, supported and challenged. Given the recognition by the department of personalized learning as paramount to student success (as demonstrated by this proposed grant competition), a belief ASCD shares, we recommend that the department similarly elevate personalized learning by requiring its inclusion in school turnaround strategies promoted by the department.

Effective integration of student supports in the school environment is crucial to supporting the whole child. We are heartened that the Competitive Preference Priority would require districts to address the social-emotional, behavioral and other needs of students—which are important components of meeting the needs of the whole child. Thus, we recommend that the department consider making the integrated services option part of the core educational assurance areas to ensure that the services that districts provide to students are coordinated and delivered in a way that supports the whole child.

Teaching: ASCD strongly supports the draft’s requirements with regard to teaching. Effective teaching is the number one indicator of student success. Empowering educators to become effective in their role by enabling them to implement personalized teaching and learning for all students is an important step toward improved student achievement and success after graduation.

ASCD has been a long-time advocate of a whole child approach to education for each child, in each school, in each community. Personalized learning strategies that best meet and support each individual student’s needs are an essential component of a whole child education. We are gratified and commend the U.S. Department of Education for recognizing and promoting the importance of personalized learning as reflected in this competition proposal. True student success and effective school reform are dependent upon an education system that recognizes the individual needs of each student, accommodates the diversity of the school and the community it serves, and offers worthy educational opportunities for everyone. We look forward to continuing to work with the department toward the attainment of our mutual goals.

Cordially,

David A. Griffith
Director, Public Policy
dgriffith@ascd.org

June 8, 2012

RE: Comments Related to Race to the Top District Draft Guidance

Submitted by: The Public Education Network
601 Thirteenth Street, NW, Suite 710S
Washington, DC 20005
Wendy D. Puriefoy, President

The Honorable Arne Duncan
Secretary
U. S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202

Dear Secretary Duncan:

Introduction:
Public Education Network (PEN) thanks you for this opportunity to submit comments related to the proposed competitive Race to the Top District guidance. We are pleased that the proposal addresses personalized learning strategies with the maximum involvement, support, and ownership of the public, promoting student-centered, research-based outcomes that recognize the importance of linking school and community in changing the ‘infrastructure, capacity, and culture” of the school district. This allows districts and communities to concentrate their efforts on authentic student achievement, and away from passing tests, one-size fits all models, and top-down mandates without recognizing the differentiated needs of various communities and their students. Our major regret is that there will only be a few districts that receive grants, rather than providing the resources to all districts that meet the proposal criteria, or would otherwise like to participate if they had the capacity. As you finalize the draft guidance, we ask that you consider recommendations that we believe will further strengthen the success of RTT-D.

PEN is a national network comprised of 77 Local Education Funds (LEFs) in 34 states, working to advance public school reform in low-income, both rural and urban, communities across the country. LEFs are unique education reform organizations with deep on-the-ground relationships with both public schools/districts and community stakeholders. They have developed nationally significant practices to enhance teacher quality and professional development, public engagement, partnering with district urban residency programs, increasing high school graduation rates, promoting college and career readiness, supporting coordination and integration of services, developing researched-based frameworks that move children from cradle to careers---all with a focus on public engagement and community and family involvement.

PEN is partnering with its LEFs to increase the number of prepared youth by:
• monitoring low-income students' progress toward college readiness;
• ensuring completion of college prep curricula (e.g., algebra in 8th grade);
• boosting completion of accelerated learning courses (Advanced Placement/dual enrollment in colleges);
• improving scores on college entrance exams (ACT/SAT);
• Effective teachers and principals
• increasing FAFSA (financial aid application) completion rates; and
• tracking college enrollment and persistence data.

Because local education funds represent a broad range of community interests at the school district and community level, they are well positioned to bring together the various community stakeholders and citizens in demanding high performing public schools for all students. In addition, research demonstrates they can build the civic capacity in advocating for equity, demand public accountability based on meaningful and “deeper” multiple measures of data, closing the achievement gap, implement and support best practices, and prepare students who are college and career ready.

As PEN comments on RTT-D, our lens will focus on a number of elements that cut across all aspects of change and improvement that, if not addressed, would greatly diminish the RTT-D innovation objectives in improving the most difficult schools, and increasing the number of students that are career and college ready. These include: functions of capacity; opportunities to learn; qualified teachers and principals; resources; middle and high school intervention; needs of our most disconnected youth; community and family engagement; shared accountability based on continuous progress and multiple measures, and an improved and expanded longitudinal data systems.
Race to the Top Competition Draft Introduction: Paragraph 4
“More specifically, RTT-D will reward those LEAs that have the leadership and vision to implement the strategies, structures and systems of support to move beyond one-size–fits-all models of schooling, which have struggled to produce excellence and equity for all children, to personalized, student-focused approaches to teaching and learning that will use collaborative, data-based strategies and 21st century tools to deliver instruction and supports tailored to the {add academic, social and emotional needs} of each student, with the goal of enabling all students to graduate college- and career-ready.”

Eligibility Requirements:
Rural School Districts
We are concerned about the requirement that applicants must meet a threshold of serving a minimum of 2,500 students. While consortia of district and long distance learning are promising strategies, there is a cost in personnel, bringing communities together, and face to face planning in developing consortia that may make such applications challenging, if not prohibitive for small and very poor rural districts. We have a lot to learn from the approximately 11 percent of the rural school districts that would be excluded from this proposal. Oour goal should

PEN’s recommendation is to set aside funding that is discretionary or formula-based to meet these needs, and/or offer special accommodations and personal assistance in helping smaller communities in meeting the logistical prescriptions in applying for RTT-D Size, geography, culture, history, and context can have an impact on everything from effect size, conditions for learning, opportunities, funding, and equity.

Middle and High School Preference
As a result of inadequate preparation during secondary school, 1.3 million students do not graduate each year, and in nearly 1,600 high schools, fewer than sixty percent of students graduate on-time. The nation’s low performing high schools and their feeder middle schools must be reformed. Without losing the systemic focus on a continuum of education from cradle to career, it is critical that middle and high schools preparing students for graduating and transitioning to postsecondary education receive focused attention within RTT-D.

Recommendations:
1. A competitive preference priority should be given to applications that focus their reform efforts on low performing middle and high schools serving large proportions of low income students.
2. The requirement that at least forty percent of participating students must be from low-income families should be raised to at least fifty percent for all eligible applicants and a competitive preference priority should be set for applicants serving more than fifty percent.
3. In addition, poverty at the secondary school level should be more accurately measured by requiring the use of a feeder pattern.

Application Requirements
1. The RTT-D draft application requirements should include a appropriate focus on personalization and the utilization of data to address specific student needs. Although the application requires data systems that link teachers and students as well as P-12 and higher education data, it does not explicitly call on districts to utilize data systems for the implementation of Early Warning Indicator Systems.

Recommendations: All RTT-D applicants should be required to implement early warning indicator systems that utilize on-track indicators to identify students who unlikely to be prepared for college-level work and provide them with tailored support. This should include:
• Attendance
• Behavior
• course performance
• credit accumulation, and
• other measures validated against postsecondary outcomes (e.g., college entrance,
remediation rates, college completion, industry certification, career entry, etc.).

The use of an Early Warning Indicator System should not be a prerequisite for the receipt of a RTT-D grant; rather RTT-D funds should be utilized for the development and implementation of these systems.

2. “Be signed by the Superintendent/CEO, local School Board President, and local Union/Association President, {add major school and community stakeholders including community-based organizations and national and local education funds and other intermediary education organizations} (where applicable).”

Selection Criteria:
A. Vision
“The extent to which the applicant's vision will translate into increased improved student performance and equity as demonstrated by ambitious yet achievable annual goals, overall and by student subgroup (as defined in this document), for each participating LEA, in the following areas:
1. Performance on summative assessments (status and growth);
2. Decreasing the achievement gaps (as defined in this document);
3. Graduation rates (as defined in this document);
4. Credit Accumulation
5. College enrollment (as defined in this document) rates;
6. Student attendance(as defined in this document); and
7. Teacher attendance (as defined in this document);

8. {add Student chronic absenteeism}
9. {add Social and emotional development}
10. {add Development of metrics to gauge community engagement}
See measures above under Application Requirements, 1)

Strengthen the role for local education funds (LEFs) and other national and local intermediary organizations
The emerging field of personalized instruction focused on the low-income and low achieving schools is fortunate to have strong intermediary organizations and local education funds that play community engagement and instructional roles at the school district and school(s) level. These organizations serve as a resources in working with school districts to improve program quality, foster public-private collaboration, disseminate best practices, support educator professional development, promote school district report card data and utilization of data, and serves as a partner in supporting such mechanisms as student trackers, accelerated learning, and coordinated supports. As a result, we believe it is critical that such organizations have a strong role in the RTT-D applications, including the development, review and support of the application as described in the guidance. Many schools and non-profits lack the capacity by themselves to personalize instruction leading toward college and career readiness, and strong local education funds and national and local intermediary organizations have the capacity to fill this role effectively.

B. District Capacity and Success Factors
PEN recommends that this section be changed to:
Community and District Capacity and Success Factors

The addition of community is consistent with one of the goals of the RTT proposal: linking school district and community collaboration including municipalities with student centered instruction and capacity. In a labor-management document just released and signed by Secretary Duncan and six major national education organizations, it was recognized that “no community can flourish unless its children are safe, healthy, well-nourished, and well-educated; and no school can be a strong pillar of a thriving community without deep community responsibility for and ownership of the school’s academic success. Thus, recognizing that the fate of communities and their schools are inextricably linked, we must make schools stronger by educators embracing community resources, expertise, and activities; and we must make communities stronger by anchoring them around highly effective schools.

B3) under Community and District Capacity and Success Factors
“Meaningful stakeholder engagement and support”
PEN joins with the Coalition for Community Schools in applauding the Department’s focus on engaging local stakeholders.

For letters of support from key stakeholders (B3b) to be meaningful, these stakeholders must also have a voice in the planning process (B3a). This change would be consistent with the Department’s continued emphasis on deep community engagement and PEN’s emphasis in linking school and community.

Consequently, we propose adding to 3a the following in italics:
“A description of how families, teachers, and principals in participating schools (as defined in this document) and such key stakeholders as parents and parent organizations, students and student organizations, early learning programs, the business community, civil rights organizations, advocacy groups, local civic and community-based organizations, local government agencies, and/or institutions of higher education (IHEs)l…” In addition, PEN would add local education funds and other local and national intermediary organizations.

To strengthen the definition of key stakeholders throughout the document, we suggest adding a new definition to the guidelines based on the existing language.
Key Stakeholders: Includes parents and parent organizations, students and student organizations, early learning programs, the business community, civil rights organizations, advocacy groups, local civic and community-based organizations, local government agencies, local education funds and other local and national intermediary organizations, and/or institutions of higher education (IHEs).

C. Preparing Students for College and Careers; 1) Teaching a) and b)
Consistent with the definitions under “Community and District Capacity and Success Factors” above, we recommend that stakeholder support be expanded. In the communities they serve, LEFs working with their partners, have committed themselves “to increase by 100,000 the number of high school students who graduate, or are on track to graduate, college and career ready, by 2013.” The work of LEFs along with many other community stakeholders around the country demonstrates the importance of broad partnerships partnership working in concert to ensure that personalized learning is achieved and leads to increased college and career readiness. Under these two sections, we note that the role of community partners and LEFs is noticeably absent from the key actors responsible for learning in this section. We suggest changing C1a and C1b to include the italicized:

“With the support of parents, teachers, and other educational support specialists and personnel, and such key stakeholders as

D. Preparing Students for College and Careers; 2) Teaching c)
We suggest modifying the definition of “school leadership team” which is used in 2c to more clearly define “community members.” We suggest adding: “community members and a representative of key community stakeholders”. We further suggest that the Department add “community stakeholders” as a definition in the guidelines and which should be defined according to existing language in the guidelines: Key stakeholders includes: parents and parent organizations, students and student organizations, early learning programs, the business community, civil rights organizations, advocacy groups, local civic and community-based organizations, local education funds and other local and national intermediary organizations, and/or institutions of higher education (IHEs).

2) Teaching
Add “d” to read: All participating educators work with community stakeholders as partners in exploring experiential models where students' (including pre-service teachers') education involves transformative experiences that include a clinical model of teaching, research, and practice both within the classroom and outside it building on well-established models of participatory learning, apprenticeship, mentorship, coaching and requires strong partnerships between universities, school districts, community stakeholders and industry.

1. Work with the school district and higher education to create partnerships with higher education and community stakeholders to support highly effective recruitment efforts, preparation programs, induction and professional development services through the first seven years of a teacher’s career, and across principalship tenures that includes coaching, mentorships, shadowing, continuous professional development, observation, feedback and improvement, especially for those teachers needing special preparation in special education, ELL, STEM and intervention schools.
2. Provide parents and the community information about teacher qualifications such as certification, expertise in content area, teachers who are still in training, and disaggregated by student disability, income, ELL and ethnicity related to the schools in their district. This should include notice to Title I parents as to whether their child’s teacher is currently enrolled in an alternative certification program, or has been taught for four or more consecutive weeks by, a teacher who is participating in an alternative route to certification program.
3. Collect annual information about school and district climate, leadership, and community services that are coordinated and accessible to teachers, students and families in support of personalized instruction
4. Work with the district in creating community and higher education partnerships, helping to connect parents and teachers, promote home and school visitations, and build support for such experiments as using time differently, year round schools, summer programs, 21st Century Alliances, and digital learning
5. Teacher evaluation systems should focus on building the teacher profession and on a system of evaluation developed with the input of key stakeholders including parents and parent organizations, students and student organizations, early learning programs, the business community, civil rights organizations, advocacy groups, local civic and community-based organizations, local education funds and other local and national intermediary organizations, local education funds and other local and national intermediary organizations, and/or institutions of higher education (IHEs).
6. School districts should establish data systems that connect school-based data (i.e. academic, attendance, behavioral) with nonprofit service provider data (e.g. tutoring and after school). With such a system in place, districts will be able to work with providers more effectively and efficiently, students get exactly what they need to succeed, and funders and policymakers can better determine which programs are working, and which ones are not. School-level resource coordination will be important to the success of these systems.

Often, the community stakeholders are overlooked in teacher recruitment, induction, retention and professional development. In addition, RTT-D works with the teachers already in the classroom, whereas community stakeholders can work with the district to create new talent pipelines such as grow-your-own models, STEM inservice, and urban residency Some of the more successful pipeline programs have involved community partnerships with the school district and higher education. For instance,
• PEN believes that using the teacher urban residency model, now being supported and led by PEN’s LEFs in Denver area, New York, Boston, Philadelphia, and Los Angeles, Chatanooga, and Seattle as well as elsewhere in the nation, provides the transformational model that can turn around difficult and struggling schools, and meet the objectives of RTT-D.
• Another example is Humanitas model employed by the Los Angeles Education Partnership which focuses on transforming the school to create more effective teaching and learning focusing on teacher effectiveness, and not on a minimum and arbitrary standards of “highly qualified” as in NCLB.
• Yes another example is that of the Public Education Fund of Chattanooga and the Benwood Initiative working with the most low-income schools to provide the kind of personalized professional development and support called for in the RTT-D producing staggering increases in reading and literacy.

PEN continues to be concerned about the distribution of less qualified teachers who are significantly overrepresented in schools that serve minority and low-income students. In fact,
schools serving the most African- American and Hispanic students are nearly twice as likely to be to employed to be teachers who are newest to the profession. In the most recent US Department of Education OCR report, the study concludes that there is a growing disparity between the least experienced teachers placed in schools with predominately African-American American and Latino students. It has been suggested that, even for highly effective teachers, the first few years of their career can be difficult. Research has shown that Black and White students have different levels of exposure to novice teachers (Clotfelter, Ladd, and Vigdor 2004). And according to the National Center for Educational Statistics (NCES), Schools and Staffing Survey (SASS), in most intervention models, the teacher workforce was more likely to be White, younger, and less experienced and more likely to have provisional certification after intervention than before it. In addition, the study found that the largest sector of current teachers has only one year of experience, a revolving door pattern of instability and inexperience, whereas in 1987-l988, the modality was 15 years of experience.

C. Preparing Students for College and Careers; 4) Performance Measurement
PEN joins the Coalition for Community Schools in recommending that surveys of educators (f) and students (g) should also include climate, culture, and the conditions for learning in order to paint a complete picture of the conditions in which teachers teach and students learn.

Thus, we suggest making the following changes to the definitions for student survey:
“Student survey: Measures students’ perspectives on teaching, learning, and related supports (e.g., school climate, school culture, and the conditions for learning) in their classrooms and schools. The surveys must be research-based, valid, and reliable. Over time these results should be predictive of rates of student growth.”
We suggest adding a parallel definition for educator survey (currently mentioned, but undefined) that would read:
Educator survey: Measures educators’ perspectives on teaching, learning, and related supports (e.g., school climate, school culture, the conditions for learning, faculty trust, etc.) in their classrooms and schools. The surveys must be research-based, valid, and reliable.
We strongly urge the Department to add a parent survey that would help districts learn more about parent engagement and their needs in supporting student learning. We suggest adding C4h) to read:
Parent survey: Measures parents’ perspectives on teaching, learning, and related supports (e.g., school climate, school culture, and the conditions for learning, teacher and principal support, opportunities for parent engagement) in classrooms and schools. The surveys must be research-based, valid, and reliable.
Lastly, we strongly urge the Department to add a community survey that would help districts and the community learn more about community and stakeholder involvement (see stakeholders definition above) and ownership in advocating for change and building public will to support the special needs of the most difficult schools: We suggest adding C4i) to read:
Community Survey: Measures and assesses individual and organizational community capacity and perspectives on their understanding of the academic and developmental student and school data, the needs of the most difficult schools, the supports they are able to commit and provide, and their responsibility in supporting quality public education for all children in their community. The surveys must be research-based, valid, and reliable.

Competitive Preference Priority for Middle and High Schools
A competitive preference priority should be given to applications that focus their reform efforts on low performing middle and high schools serving large proportions of low income students. The requirement that at least forty percent of participating students must be from low-income families should be raised to at least fifty percent for all eligible applicants and a competitive preference priority should be set for applicants serving more than fifty percent. In addition, poverty at the middle and secondary school level should be more accurately measured by requiring the use of a feeder pattern.

Budget Supplement
• Recommendation: PEN recommends converting the optional budget supplement to competitive preference priority for supporting the ttransition from high school to college and disconnected youth. Districts should be encouraged to focus attention on young people who are:
o among the least likely to enter postsecondary education; and
o students who are over-age/under credited and students who have dropped out of high school or are otherwise disconnected from the education system

In order to incentivize applicants to target our most vulnerable students and support the transition to college and career, the optional budget supplement should be converted to a competitive preference for applications that:

• Implements strategies for supporting the successful transition between secondary and post- secondary school through the expansion of rigorous secondary curricula (e.g., Advanced Placement and International Baccalaureate); effective models, such as dual enrollment and Early College High Schools; college-focused school counseling programs; and targeted assistance in grade 12 transition courses based on grade 11 grade assessments to reduce the need for remediation in postsecondary education; and
• Develops partnerships between the school district, the workforce system, employers, nonprofit organizations, and social service providers to identify and connect students who have dropped out of school, are exiting the juvenile justice system, or are over-aged and under-credit and connect them to education, job training, and wraparound support services.

In order to increase the number of students who enter and persist in postsecondary education, we recommend:
• focused efforts be made to ensure that high school students, particularly low-income high school students, are prepared for the rigor of postsecondary education. Such efforts can include:
o expanding school counseling programs;
o providing rigorous course options such as Advanced Placement, International Baccalaureate, early college high school, and dual enrollment; and
o offering further practices that create a college-going culture within high schools.

PEN recommends that the following data be collected on a longitudinal basis to measure and report performance on college and career readiness:
• percent and number of ninth graders who graduate college and career ready in four years
• percent increase and number of students on-track to be college and career ready
• percent and number of low-income/minority students being taught by effective teachers
• new assessments should be used to inform high school curriculum rather than high school exit requirements, pursuing better learning opportunities, rather than often counterproductive exit exams
• on-track metrics such as college preparatory course work in key subjects such as Algebra, GPAs, and credit accumulation; high school graduation rates;
• college acceptance, enrollment, and persistence rates
• student participation in college access, such as counseling, college visits

In addition, PEN recommends that when focusing on college and career readiness, that school districts with community partnership develop metrics, indicators and a report card which tracks the following student information and progress from the early years to college or a career based on a project led and coordinated by PEN Network member, Strive Together serving Cincinnati and Northern Kentucky.

1. Preparation for school
2. Every child will be supported in and out of school
3. Every child will succeed academically
4. Every student will enroll in college
5. Every student graduates and enters a career

Robert L. Hughes, president of New Visions for Public Schools, and one of PEN’s members talks about his experiences turning around struggling schools, “You need to have an accurate diagnosis of why each of those 5,000 schools [to which U.S. Secretary of Education Arne Duncan refers] are failing. It’s crucial. Sometimes you need a two-by-four to get change. Other times you need a scrapple.” In our view, RTT-D recognizes that changes is not about adopting yet another program, but seeks comprehensive restructuring and transformation based on institutional and school system capacity, competencies, public will, and trust in the democratic process.

Public Education Network and its members welcome the opportunity to speak more with you or your staff about how we can help you reach your goal for accomplishing the RTT-D objectives.

Sincerely,

Wendy D. Puriefoy, President and CEO
Public Education Network

************************************************************************************

June 8, 2012

RE: Comments Related to Race to the Top District Draft Guidance

Submitted by: The Public Education Network
601 Thirteenth Street, NW, Suite 710S
Washington, DC 20005
Wendy D. Puriefoy, President

The Honorable Arne Duncan
Secretary
U. S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202

Dear Secretary Duncan:

Introduction:
Public Education Network (PEN) thanks you for this opportunity to submit comments related to the proposed competitive Race to the Top District guidance. We are pleased that the proposal addresses personalized learning strategies with the maximum involvement, support, and ownership of the public, promoting student-centered, research-based outcomes that recognize the importance of linking school and community in changing the ‘infrastructure, capacity, and culture” of the school district. This allows districts and communities to concentrate their efforts on authentic student achievement, and away from passing tests, one-size fits all models, and top-down mandates without recognizing the differentiated needs of various communities and their students. Our major regret is that there will only be a few districts that receive grants, rather than providing the resources to all districts that meet the proposal criteria, or would otherwise like to participate if they had the capacity. As you finalize the draft guidance, we ask that you consider recommendations that we believe will further strengthen the success of RTT-D.

PEN is a national network comprised of 77 Local Education Funds (LEFs) in 34 states, working to advance public school reform in low-income, both rural and urban, communities across the country. LEFs are unique education reform organizations with deep on-the-ground relationships with both public schools/districts and community stakeholders. They have developed nationally significant practices to enhance teacher quality and professional development, public engagement, partnering with district urban residency programs, increasing high school graduation rates, promoting college and career readiness, supporting coordination and integration of services, developing researched-based frameworks that move children from cradle to careers---all with a focus on public engagement and community and family involvement.

PEN is partnering with its LEFs to increase the number of prepared youth by:
• monitoring low-income students' progress toward college readiness;
• ensuring completion of college prep curricula (e.g., algebra in 8th grade);
• boosting completion of accelerated learning courses (Advanced Placement/dual enrollment in colleges);
• improving scores on college entrance exams (ACT/SAT);
• Effective teachers and principals
• increasing FAFSA (financial aid application) completion rates; and
• tracking college enrollment and persistence data.

Because local education funds represent a broad range of community interests at the school district and community level, they are well positioned to bring together the various community stakeholders and citizens in demanding high performing public schools for all students. In addition, research demonstrates they can build the civic capacity in advocating for equity, demand public accountability based on meaningful and “deeper” multiple measures of data, closing the achievement gap, implement and support best practices, and prepare students who are college and career ready.

As PEN comments on RTT-D, our lens will focus on a number of elements that cut across all aspects of change and improvement that, if not addressed, would greatly diminish the RTT-D innovation objectives in improving the most difficult schools, and increasing the number of students that are career and college ready. These include: functions of capacity; opportunities to learn; qualified teachers and principals; resources; middle and high school intervention; needs of our most disconnected youth; community and family engagement; shared accountability based on continuous progress and multiple measures, and an improved and expanded longitudinal data systems.
Race to the Top Competition Draft Introduction: Paragraph 4
“More specifically, RTT-D will reward those LEAs that have the leadership and vision to implement the strategies, structures and systems of support to move beyond one-size–fits-all models of schooling, which have struggled to produce excellence and equity for all children, to personalized, student-focused approaches to teaching and learning that will use collaborative, data-based strategies and 21st century tools to deliver instruction and supports tailored to the {add academic, social and emotional needs} of each student, with the goal of enabling all students to graduate college- and career-ready.”

Eligibility Requirements:
Rural School Districts
We are concerned about the requirement that applicants must meet a threshold of serving a minimum of 2,500 students. While consortia of district and long distance learning are promising strategies, there is a cost in personnel, bringing communities together, and face to face planning in developing consortia that may make such applications challenging, if not prohibitive for small and very poor rural districts. We have a lot to learn from the approximately 11 percent of the rural school districts that would be excluded from this proposal. Oour goal should

PEN’s recommendation is to set aside funding that is discretionary or formula-based to meet these needs, and/or offer special accommodations and personal assistance in helping smaller communities in meeting the logistical prescriptions in applying for RTT-D Size, geography, culture, history, and context can have an impact on everything from effect size, conditions for learning, opportunities, funding, and equity.

Middle and High School Preference
As a result of inadequate preparation during secondary school, 1.3 million students do not graduate each year, and in nearly 1,600 high schools, fewer than sixty percent of students graduate on-time. The nation’s low performing high schools and their feeder middle schools must be reformed. Without losing the systemic focus on a continuum of education from cradle to career, it is critical that middle and high schools preparing students for graduating and transitioning to postsecondary education receive focused attention within RTT-D.

Recommendations:
1. A competitive preference priority should be given to applications that focus their reform efforts on low performing middle and high schools serving large proportions of low income students.
2. The requirement that at least forty percent of participating students must be from low-income families should be raised to at least fifty percent for all eligible applicants and a competitive preference priority should be set for applicants serving more than fifty percent.
3. In addition, poverty at the secondary school level should be more accurately measured by requiring the use of a feeder pattern.

Application Requirements
1. The RTT-D draft application requirements should include a appropriate focus on personalization and the utilization of data to address specific student needs. Although the application requires data systems that link teachers and students as well as P-12 and higher education data, it does not explicitly call on districts to utilize data systems for the implementation of Early Warning Indicator Systems.

Recommendations: All RTT-D applicants should be required to implement early warning indicator systems that utilize on-track indicators to identify students who unlikely to be prepared for college-level work and provide them with tailored support. This should include:
• Attendance
• Behavior
• course performance
• credit accumulation, and
• other measures validated against postsecondary outcomes (e.g., college entrance,
remediation rates, college completion, industry certification, career entry, etc.).

The use of an Early Warning Indicator System should not be a prerequisite for the receipt of a RTT-D grant; rather RTT-D funds should be utilized for the development and implementation of these systems.

2. “Be signed by the Superintendent/CEO, local School Board President, and local Union/Association President, {add major school and community stakeholders including community-based organizations and national and local education funds and other intermediary education organizations} (where applicable).”

Selection Criteria:
A. Vision
“The extent to which the applicant's vision will translate into increased improved student performance and equity as demonstrated by ambitious yet achievable annual goals, overall and by student subgroup (as defined in this document), for each participating LEA, in the following areas:
1. Performance on summative assessments (status and growth);
2. Decreasing the achievement gaps (as defined in this document);
3. Graduation rates (as defined in this document);
4. Credit Accumulation
5. College enrollment (as defined in this document) rates;
6. Student attendance(as defined in this document); and
7. Teacher attendance (as defined in this document);

8. {add Student chronic absenteeism}
9. {add Social and emotional development}
10. {add Development of metrics to gauge community engagement}
See measures above under Application Requirements, 1)

Strengthen the role for local education funds (LEFs) and other national and local intermediary organizations
The emerging field of personalized instruction focused on the low-income and low achieving schools is fortunate to have strong intermediary organizations and local education funds that play community engagement and instructional roles at the school district and school(s) level. These organizations serve as a resources in working with school districts to improve program quality, foster public-private collaboration, disseminate best practices, support educator professional development, promote school district report card data and utilization of data, and serves as a partner in supporting such mechanisms as student trackers, accelerated learning, and coordinated supports. As a result, we believe it is critical that such organizations have a strong role in the RTT-D applications, including the development, review and support of the application as described in the guidance. Many schools and non-profits lack the capacity by themselves to personalize instruction leading toward college and career readiness, and strong local education funds and national and local intermediary organizations have the capacity to fill this role effectively.

B. District Capacity and Success Factors
PEN recommends that this section be changed to:
Community and District Capacity and Success Factors

The addition of community is consistent with one of the goals of the RTT proposal: linking school district and community collaboration including municipalities with student centered instruction and capacity. In a labor-management document just released and signed by Secretary Duncan and six major national education organizations, it was recognized that “no community can flourish unless its children are safe, healthy, well-nourished, and well-educated; and no school can be a strong pillar of a thriving community without deep community responsibility for and ownership of the school’s academic success. Thus, recognizing that the fate of communities and their schools are inextricably linked, we must make schools stronger by educators embracing community resources, expertise, and activities; and we must make communities stronger by anchoring them around highly effective schools.

B3) under Community and District Capacity and Success Factors
“Meaningful stakeholder engagement and support”
PEN joins with the Coalition for Community Schools in applauding the Department’s focus on engaging local stakeholders.

For letters of support from key stakeholders (B3b) to be meaningful, these stakeholders must also have a voice in the planning process (B3a). This change would be consistent with the Department’s continued emphasis on deep community engagement and PEN’s emphasis in linking school and community.

Consequently, we propose adding to 3a the following in italics:
“A description of how families, teachers, and principals in participating schools (as defined in this document) and such key stakeholders as parents and parent organizations, students and student organizations, early learning programs, the business community, civil rights organizations, advocacy groups, local civic and community-based organizations, local government agencies, and/or institutions of higher education (IHEs)l…” In addition, PEN would add local education funds and other local and national intermediary organizations.

To strengthen the definition of key stakeholders throughout the document, we suggest adding a new definition to the guidelines based on the existing language.
Key Stakeholders: Includes parents and parent organizations, students and student organizations, early learning programs, the business community, civil rights organizations, advocacy groups, local civic and community-based organizations, local government agencies, local education funds and other local and national intermediary organizations, and/or institutions of higher education (IHEs).

C. Preparing Students for College and Careers; 1) Teaching a) and b)
Consistent with the definitions under “Community and District Capacity and Success Factors” above, we recommend that stakeholder support be expanded. In the communities they serve, LEFs working with their partners, have committed themselves “to increase by 100,000 the number of high school students who graduate, or are on track to graduate, college and career ready, by 2013.” The work of LEFs along with many other community stakeholders around the country demonstrates the importance of broad partnerships partnership working in concert to ensure that personalized learning is achieved and leads to increased college and career readiness. Under these two sections, we note that the role of community partners and LEFs is noticeably absent from the key actors responsible for learning in this section. We suggest changing C1a and C1b to include the italicized:

“With the support of parents, teachers, and other educational support specialists and personnel, and such key stakeholders as

D. Preparing Students for College and Careers; 2) Teaching c)
We suggest modifying the definition of “school leadership team” which is used in 2c to more clearly define “community members.” We suggest adding: “community members and a representative of key community stakeholders”. We further suggest that the Department add “community stakeholders” as a definition in the guidelines and which should be defined according to existing language in the guidelines: Key stakeholders includes: parents and parent organizations, students and student organizations, early learning programs, the business community, civil rights organizations, advocacy groups, local civic and community-based organizations, local education funds and other local and national intermediary organizations, and/or institutions of higher education (IHEs).

2) Teaching
Add “d” to read: All participating educators work with community stakeholders as partners in exploring experiential models where students' (including pre-service teachers') education involves transformative experiences that include a clinical model of teaching, research, and practice both within the classroom and outside it building on well-established models of participatory learning, apprenticeship, mentorship, coaching and requires strong partnerships between universities, school districts, community stakeholders and industry.

1. Work with the school district and higher education to create partnerships with higher education and community stakeholders to support highly effective recruitment efforts, preparation programs, induction and professional development services through the first seven years of a teacher’s career, and across principalship tenures that includes coaching, mentorships, shadowing, continuous professional development, observation, feedback and improvement, especially for those teachers needing special preparation in special education, ELL, STEM and intervention schools.
2. Provide parents and the community information about teacher qualifications such as certification, expertise in content area, teachers who are still in training, and disaggregated by student disability, income, ELL and ethnicity related to the schools in their district. This should include notice to Title I parents as to whether their child’s teacher is currently enrolled in an alternative certification program, or has been taught for four or more consecutive weeks by, a teacher who is participating in an alternative route to certification program.
3. Collect annual information about school and district climate, leadership, and community services that are coordinated and accessible to teachers, students and families in support of personalized instruction
4. Work with the district in creating community and higher education partnerships, helping to connect parents and teachers, promote home and school visitations, and build support for such experiments as using time differently, year round schools, summer programs, 21st Century Alliances, and digital learning
5. Teacher evaluation systems should focus on building the teacher profession and on a system of evaluation developed with the input of key stakeholders including parents and parent organizations, students and student organizations, early learning programs, the business community, civil rights organizations, advocacy groups, local civic and community-based organizations, local education funds and other local and national intermediary organizations, local education funds and other local and national intermediary organizations, and/or institutions of higher education (IHEs).
6. School districts should establish data systems that connect school-based data (i.e. academic, attendance, behavioral) with nonprofit service provider data (e.g. tutoring and after school). With such a system in place, districts will be able to work with providers more effectively and efficiently, students get exactly what they need to succeed, and funders and policymakers can better determine which programs are working, and which ones are not. School-level resource coordination will be important to the success of these systems.

Often, the community stakeholders are overlooked in teacher recruitment, induction, retention and professional development. In addition, RTT-D works with the teachers already in the classroom, whereas community stakeholders can work with the district to create new talent pipelines such as grow-your-own models, STEM inservice, and urban residency Some of the more successful pipeline programs have involved community partnerships with the school district and higher education. For instance,
• PEN believes that using the teacher urban residency model, now being supported and led by PEN’s LEFs in Denver area, New York, Boston, Philadelphia, and Los Angeles, Chatanooga, and Seattle as well as elsewhere in the nation, provides the transformational model that can turn around difficult and struggling schools, and meet the objectives of RTT-D.
• Another example is Humanitas model employed by the Los Angeles Education Partnership which focuses on transforming the school to create more effective teaching and learning focusing on teacher effectiveness, and not on a minimum and arbitrary standards of “highly qualified” as in NCLB.
• Yes another example is that of the Public Education Fund of Chattanooga and the Benwood Initiative working with the most low-income schools to provide the kind of personalized professional development and support called for in the RTT-D producing staggering increases in reading and literacy.

PEN continues to be concerned about the distribution of less qualified teachers who are significantly overrepresented in schools that serve minority and low-income students. In fact,
schools serving the most African- American and Hispanic students are nearly twice as likely to be to employed to be teachers who are newest to the profession. In the most recent US Department of Education OCR report, the study concludes that there is a growing disparity between the least experienced teachers placed in schools with predominately African-American American and Latino students. It has been suggested that, even for highly effective teachers, the first few years of their career can be difficult. Research has shown that Black and White students have different levels of exposure to novice teachers (Clotfelter, Ladd, and Vigdor 2004). And according to the National Center for Educational Statistics (NCES), Schools and Staffing Survey (SASS), in most intervention models, the teacher workforce was more likely to be White, younger, and less experienced and more likely to have provisional certification after intervention than before it. In addition, the study found that the largest sector of current teachers has only one year of experience, a revolving door pattern of instability and inexperience, whereas in 1987-l988, the modality was 15 years of experience.

C. Preparing Students for College and Careers; 4) Performance Measurement
PEN joins the Coalition for Community Schools in recommending that surveys of educators (f) and students (g) should also include climate, culture, and the conditions for learning in order to paint a complete picture of the conditions in which teachers teach and students learn.

Thus, we suggest making the following changes to the definitions for student survey:
“Student survey: Measures students’ perspectives on teaching, learning, and related supports (e.g., school climate, school culture, and the conditions for learning) in their classrooms and schools. The surveys must be research-based, valid, and reliable. Over time these results should be predictive of rates of student growth.”
We suggest adding a parallel definition for educator survey (currently mentioned, but undefined) that would read:
Educator survey: Measures educators’ perspectives on teaching, learning, and related supports (e.g., school climate, school culture, the conditions for learning, faculty trust, etc.) in their classrooms and schools. The surveys must be research-based, valid, and reliable.
We strongly urge the Department to add a parent survey that would help districts learn more about parent engagement and their needs in supporting student learning. We suggest adding C4h) to read:
Parent survey: Measures parents’ perspectives on teaching, learning, and related supports (e.g., school climate, school culture, and the conditions for learning, teacher and principal support, opportunities for parent engagement) in classrooms and schools. The surveys must be research-based, valid, and reliable.
Lastly, we strongly urge the Department to add a community survey that would help districts and the community learn more about community and stakeholder involvement (see stakeholders definition above) and ownership in advocating for change and building public will to support the special needs of the most difficult schools: We suggest adding C4i) to read:
Community Survey: Measures and assesses individual and organizational community capacity and perspectives on their understanding of the academic and developmental student and school data, the needs of the most difficult schools, the supports they are able to commit and provide, and their responsibility in supporting quality public education for all children in their community. The surveys must be research-based, valid, and reliable.

Competitive Preference Priority for Middle and High Schools
A competitive preference priority should be given to applications that focus their reform efforts on low performing middle and high schools serving large proportions of low income students. The requirement that at least forty percent of participating students must be from low-income families should be raised to at least fifty percent for all eligible applicants and a competitive preference priority should be set for applicants serving more than fifty percent. In addition, poverty at the middle and secondary school level should be more accurately measured by requiring the use of a feeder pattern.

Budget Supplement
• Recommendation: PEN recommends converting the optional budget supplement to competitive preference priority for supporting the ttransition from high school to college and disconnected youth. Districts should be encouraged to focus attention on young people who are:
o among the least likely to enter postsecondary education; and
o students who are over-age/under credited and students who have dropped out of high school or are otherwise disconnected from the education system

In order to incentivize applicants to target our most vulnerable students and support the transition to college and career, the optional budget supplement should be converted to a competitive preference for applications that:

• Implements strategies for supporting the successful transition between secondary and post- secondary school through the expansion of rigorous secondary curricula (e.g., Advanced Placement and International Baccalaureate); effective models, such as dual enrollment and Early College High Schools; college-focused school counseling programs; and targeted assistance in grade 12 transition courses based on grade 11 grade assessments to reduce the need for remediation in postsecondary education; and
• Develops partnerships between the school district, the workforce system, employers, nonprofit organizations, and social service providers to identify and connect students who have dropped out of school, are exiting the juvenile justice system, or are over-aged and under-credit and connect them to education, job training, and wraparound support services.

In order to increase the number of students who enter and persist in postsecondary education, we recommend:
• focused efforts be made to ensure that high school students, particularly low-income high school students, are prepared for the rigor of postsecondary education. Such efforts can include:
o expanding school counseling programs;
o providing rigorous course options such as Advanced Placement, International Baccalaureate, early college high school, and dual enrollment; and
o offering further practices that create a college-going culture within high schools.

PEN recommends that the following data be collected on a longitudinal basis to measure and report performance on college and career readiness:
• percent and number of ninth graders who graduate college and career ready in four years
• percent increase and number of students on-track to be college and career ready
• percent and number of low-income/minority students being taught by effective teachers
• new assessments should be used to inform high school curriculum rather than high school exit requirements, pursuing better learning opportunities, rather than often counterproductive exit exams
• on-track metrics such as college preparatory course work in key subjects such as Algebra, GPAs, and credit accumulation; high school graduation rates;
• college acceptance, enrollment, and persistence rates
• student participation in college access, such as counseling, college visits

In addition, PEN recommends that when focusing on college and career readiness, that school districts with community partnership develop metrics, indicators and a report card which tracks the following student information and progress from the early years to college or a career based on a project led and coordinated by PEN Network member, Strive Together serving Cincinnati and Northern Kentucky.

1. Preparation for school
2. Every child will be supported in and out of school
3. Every child will succeed academically
4. Every student will enroll in college
5. Every student graduates and enters a career

Robert L. Hughes, president of New Visions for Public Schools, and one of PEN’s members talks about his experiences turning around struggling schools, “You need to have an accurate diagnosis of why each of those 5,000 schools [to which U.S. Secretary of Education Arne Duncan refers] are failing. It’s crucial. Sometimes you need a two-by-four to get change. Other times you need a scrapple.” In our view, RTT-D recognizes that changes is not about adopting yet another program, but seeks comprehensive restructuring and transformation based on institutional and school system capacity, competencies, public will, and trust in the democratic process.

Public Education Network and its members welcome the opportunity to speak more with you or your staff about how we can help you reach your goal for accomplishing the RTT-D objectives.

Sincerely,

Wendy D. Puriefoy, President and CEO
Public Education Network

************************************************************************************

June 8, 2012

Secretary Arne Duncan
U.S. Secretary of Education
U.S. Department of Education
400 Maryland Avenue, SW
Washington, DC 20202

Secretary Duncan:

On behalf of the United Farm Workers, I want to thank you for all that you for your tireless efforts on behalf of underprivileged students across America. Your work will help give these students the educations they need and they deserve.

I write you today regarding the Race to the Top District Competition. We at the United Farm Workers are very excited about the competition and its goals. We applaud many of its promises, including:

- Closing the “digital divide” and provide greater access to cutting-edge educational technologies that underserved and minority students will need to master in order to compete for the jobs of tomorrow;
- Enhancing personalized learning, allowing students from different backgrounds – particularly English Language Learners (ELL) – to receive the individualized instruction they need to improve achievement;
- Providing greater “transparence on treatment,” enabling concerned parents of underprivileged and minority students a clear window in to what is being done on behalf of their children;
- Granting underprivileged and minority students – particularly in urban and rural areas – greater access to Advanced Placement (AP) and credit recovery courses.

As the Race to the Top District Competition is so promising, we want to make sure that Department of Education’s requirements and priorities align with its laudable goals. The United Farm Workers see a number of areas where its draft regulations could be tightened or improved, including:

- The final rules should narrowly focus on personalized learning and closing the digital divide. Those are the most promising avenues for improving achievement for underprivileged, minority, and English Language Learner students. The United Farm Workers wants to ensure that winning applications will focus on these core priorities.
- The final rules should more closely define evaluation systems. Evaluation systems need to be designed and immediately lined up for implementation. The United Farm Workers sees program transparency – in particular, public reporting of program expenditures – as a priority, and want to make sure the final rules require it.
- We are skeptical of the human capital reforms proposed in the draft rules and requirements. The United Farm Workers has found that these reforms do not work well in rural areas, as rural districts lack a critical mass of teachers to swap in and out.

We are very excited about this program, and we applaud your moving forward with it. We also applaud your decision to open the draft rules and requirements to public comment, allowing the students and organizations who will feel the effects of this competition most directly to have their say.

Sincerely,

Sonia Rodriguez
Education Coordinator
United Farm Workers

Regarding the Race to the Top District competition, Parents as Teachers National Center urges the Department to include Tribal schools, or consortia of Tribal schools, as eligible applicants. Parents as Teachers has decades of experience in working with Tribal schools and has been very pleased to see funds designated specifically for Tribal governments in the Maternal, Infant, Early Childhood Home Visiting initiative contained in the Affordable Care Act.
While we are not suggesting a set-aside for Tribal schools, we do encourage the department to specifically include Tribal schools as eligible applicants.

The National Black Child Development Institute (NBCDI) appreciates the opportunity to comment on the Race to the Top – District competition. We are deeply grateful for this Administration’s commitment to ensuring educational excellence and equity for all children, and commend your efforts to support LEAs in moving beyond “one-size-fits-all models of schooling.” We believe this approach is critical particularly for young children and children of color, and our comments focus on how the RTT-D guidelines can be used to help districts integrate and prioritize both developmentally and culturally appropriate standards, metrics, practices and policies.

Include Professional Development Opportunities focused on Child Development, Cultural Competence and Family Engagement
We applaud the focus on professional development for teachers in Selection Criteria C.2.a, but believe that in order to fully empower educators of young children to improve instruction and increase their effectiveness, they must participate in professional teams or communities and training that support their individual and collective capacity to build a deep knowledge of child development principles and culturally relevant practices as well as to engage in positive, supportive and ongoing relationships with children’s families.

Provide Additional Opportunities for Meaningful Family Engagement
While RTT-D includes meaningful stakeholder engagement and support in its Reform Conditions, and includes engaging parents and families in decision-making through the Competitive Priority, we believe there are additional opportunities to prioritize families as a critical component of student achievement. NBCDI recommends including parent surveys in the Performance Measures, particularly for young children who cannot complete their own student surveys. The parent surveys should measure perspectives on teaching, learning, school culture, family engagement efforts, and existing home environments with respect to early learning. We also believe the measure should go beyond the number and percentage of parents completing the survey, and should hold schools and districts accountable for acting on the results of the surveys themselves, moving towards comprehensively and consistently engaging a diverse range of families.

Modify Definitions and Metrics Impacting Children Through Third Grade
Districts who choose to work with children in third grade and younger must be guided by developmentally and culturally appropriate practice in creating personalized learning plans, measuring student growth, evaluating teachers, and identifying goals and standards. Each of these elements must incorporate multiple domains of child development, including social-emotional and physical development, and should rely on assessments and evaluation approaches that are used to inform and improve instruction and that encompass screening measures, formative assessments, measures of environmental quality, and measures of the quality of adult-child interactions.

Pay Attention to the Issue of Mobility
Data from a national study indicates that only 45 percent of Black third graders are enrolled in their kindergarten school, compared to 60 percent of White and Asian third graders; yet neither schools nor districts have implemented systemic approaches to supporting the mobile children, the non-mobile children, and the teachers whose educational experiences are disrupted by this type of ongoing transition (Burkam, Lee, Dwyer, 2009). RTT-D, particularly in the areas of Selection Criteria C.3.b. and D.1.a., provides an ideal opportunity to experiment with data systems, family involvement, student tracking, and professional development opportunities that minimize the harmful effects of student mobility.

Finally, we know that many schools and districts are not currently building on the particular academic, social and developmental strengths and needs of children of color, and that in order to achieve the best outcomes for our children, schools must feature culturally competent staff engaging in strengths-based practice. Research shows that when students of color are taught with culturally responsive techniques, their academic performance improves significantly. We encourage the Department, districts and schools to think about how to respectfully and honestly talk about, understand, and integrate culture into our collective work, and to that end, thank the Department for requiring districts where minority students are overly-represented in discipline and expulsion rates to undergo a district assessment of the root cause and to develop a plan to address those causes. In fact, we encourage all districts to examine their discipline and expulsion policies, and to include a focus on family engagement, positive school climate and social-emotional supports that will make a real difference in improving student achievement and teacher effectiveness in our schools and communities.

We, the undersigned providers and advocates for high quality after school, summer, and expanded learning programs in California, believe in strong partnerships between schools and community partners that increase learning time through a full range of enrichment opportunities before or after the traditional school day and during summer.

California Alliance of Boys and Girls Clubs K.J. Lavoie, State Director
California State Alliance of YMCAs Catherine Barankin, Director
Central Valley Afterschool Foundation Kim Boyer, Executive Director
Children Now, California Ted Lempert, President
Citizen Schools Joe Ross, Executive Director, California
Partnership for Children and Youth Jennifer Peck, Executive Director
Pro-Youth/HEART Laurie Isham, CEO
THINK Together Randy Barth, Founder and CEO
Woodcraft Rangers, Los Angeles Chris Johnson, Interim CEO

To help ensure successful outcomes for RTT-D grants, we believe the proposed criteria should be amended so that it encourages partnerships with intermediary organizations and strengthens expanded learning opportunities for students. Accordingly, we ask the Department to include the following recommendations in the final criteria for the RTT-D program:

ELIGIBLE APPLICANTS – To ensure meaningful participation of partner organizations and to help facilitate the successful implementation of grants, eligible applicants should be expanded in a manner similar to i3 grants to include non-profit organizations (including intermediary organizations) in partnership with an LEA or consortia of LEAs.

RECOMMENDATION – Eligibility criteria should be amended to read as follows:

Eligibility Criteria:

1. Eligible applicants include individual local educational agencies (LEAs) (as defined in this document), consortia of LEAs, and non-profit organizations (including intermediary organizations) in partnership with an LEA or consortia of LEAs.

a. An eligible applicant may apply for all or a portion of their schools, for specific grades, or for subject area bands (e.g., lowest-performing schools, secondary schools, feeder pattern, middle school math, or preschool through third grade).

b. An eligible applicant may join a consortium that includes LEAs across one or more states.

c. An eligible applicant may only sign on to one Race to the Top District application.

In addition, eligible applicants should be required to obtain approval (signatures) from non-profit organizations that are participating in the grants as well as from those already required under the proposed criteria (superintendent/CEO, local school board, and local union/association president) to ensure buy-in from all key stakeholders at the outset, increasing the likelihood of a strong partnership and overall success.

RECOMMENDATION – Eligibility criteria should be amended to read as follows:

Eligibility Criteria:

5. Required Signatures for the eligible applicant

a. Superintendent/CEO, local school board, local union/association president (where applicable), and representative from a non-profit organization that forms a partnership with an LEA or consortia of LEAs (as applicable).

PERSONALIZED LEARNING ENVIRONMENTS – To help ensure personalized learning environments are effective, language under Absolute Priority 1 should be revised to include expanded learning opportunities (including before school, after-school, summer learning, and/or expanded learning time programs) as a way to significantly improve teaching and learning through the personalization of strategies, tools, and supports for teachers and students that are aligned with college- and career-ready standards.

RECOMMENDATION – Absolute Priority 1 should be amended to read as follows:

Absolute Priority 1, Personalized Learning Environment(s): To meet this priority, the application must coherently and comprehensively address how it will build on the four core educational assurance areas (as defined in this document) in Race to the Top to create student centered learning environment(s) that are designed to:

(1) Significantly improve teaching and learning through the personalization of strategies, tools, and supports for teachers and students that are aligned with college- and career-ready standards (as defined in this document) including through expanded learning opportunities such as before school, after-school, summer learning, and/or expanded learning time programs;

(2) Increase the effectiveness of educators, and expand student access to the most effective educators in order to raise student achievement;

(3) Decrease the achievement gap across student groups; and

(4) Increase the rates at which students graduate from high school prepared for college and careers.

POINTS AWARDED FOR THE COMPETITIVE PREFERENCE PRIORITY – The language related to the competitive preference priority is vague with regard to the number of additional points that could be awarded under the application. To help encourage partnerships under the RTT-D program, the Department should award significant points as part of the competitive preference priority to adequately incentivize partnerships.

PARTNERSHIPS – In determining the extent to which the eligible applicant receives extra points under the competitive preference priority, the Department proposed that it will consider whether the applicant has formed a coherent and sustainable partnership with public and private organizations. This language should be amended to allow applicants that commit to forming partnerships to also be eligible to apply for a grant (as opposed to only allowing existing partnerships to apply for a grant).

RECOMMENDATION – The Competitive Preference Priority should be amended to read as follows:

Competitive Preference Priority—Results, Resource Alignment, and Integrated Services

An applicant receives points under this priority based on the extent to which it integrates public and private resources to augment the schools’ core resources by providing additional student and family supports, such as addressing the social-emotional, behavioral, and other needs of the participating students (as defined in this document), giving highest priority to those students in high- needs schools. A reform proposal does not need to be comprehensive, but could address a subset of these needs.

In determining the extent to which the applicant meets this priority, the Department will consider –

(1) Whether the applicant has committed to form or has formed a coherent and sustainable partnership with public and private organizations, such as public health, after-school, and social service providers; businesses, philanthropies, civic groups, and other community-based organizations; early learning programs; and post-secondary institutions to support the plan described in Absolute Priority 1…

PARTNER ORGANIZATIONS – The competitive preference priority only mentions “after-school” as a possible partner organization. To ensure the full range of expanded learning opportunities is included under the grant, the language should be revised to include intermediaries as well as before school, after-school, summer learning, and/or expanded learning time programs as possible partner organizations.

RECOMMENDATION – The Competitive Preference Priority should be amended to read as follows:

Competitive Preference Priority—Results, Resource Alignment, and Integrated Services

An applicant receives points under this priority based on the extent to which it integrates public and private resources to augment the schools’ core resources by providing additional student and family supports, such as addressing the social-emotional, behavioral, and other needs of the participating students (as defined in this document), giving highest priority to those students in high- needs schools. A reform proposal does not need to be comprehensive, but could address a subset of these needs.

In determining the extent to which the applicant meets this priority, the Department will consider –

(1) Whether the applicant has committed to form or has formed a coherent and sustainable partnership with public and private organizations and intermediaries, such as public health, before school, after-school, summer learning, and/or expanded learning time, and social service providers; businesses, philanthropies, civic groups, and other community-based organizations; early learning programs; and post-secondary institutions to support the plan described in Absolute Priority 1…

STAFF PARTICIPATION – Under the competitive preference priority, the Department will consider how the eligible applicant will build the capacity of staff in participating schools to meet the purposes of the grant. To ensure adequate coordination and collaboration, staff development activities should be conducted jointly among LEAs and partner organizations.

RECOMMENDATION – The Competitive Preference Priority should be amended to read as follows:

Competitive Preference Priority—Results, Resource Alignment, and Integrated Services

An applicant receives points under this priority based on the extent to which it integrates public and private resources to augment the schools’ core resources by providing additional student and family supports, such as addressing the social-emotional, behavioral, and other needs of the participating students (as defined in this document), giving highest priority to those students in high- needs schools. A reform proposal does not need to be comprehensive, but could address a subset of these needs.

In determining the extent to which the applicant meets this priority, the Department will consider –

(4) How the partnership will build the capacity of staff in the partnering organization as well as participating schools (as defined in this document) by providing them with tools and supports to –

i. assess the needs and assets of participating students that are aligned with the goals for improving the education and family and community results identified by the partnership;

ii. identify and inventory the needs and assets of the school and community that are aligned with the goals for improving the education and family and community results identified by the partnership;

iii. create a decision-making process and infrastructure to select, implement, and evaluate solutions that address the individual needs of participating students (as defined in this document) and support improved results;

iv. engage parents and families of participating students in both decision-making about solutions and in addressing student, family, and school needs; and

v. routinely assess the partnership’s implementation progress and resolve challenges and problems.

Dear Secretary Duncan:

On behalf of College Summit, the nation’s largest provider of college going culture and a service provider to 170 high schools in 13 states, we write to comment on the Department of Education’s proposed criteria for the Race to the Top District (RTT-D) Competition. We applaud the Department for emphasizing college readiness in the latest round of the RTT competition by including college enrollment rates (CER) as one of the measurable goals identified in the “Vision” section of the RTT-D proposal. As you work to finalize the requirements of the program, we offer three recommendations:

  1. In addition to CER, Districts and schools should be asked to set goals for improvements in their credit accumulations rate (CAR), as states were in the first round of RTT;
  2. CER and CER should be added to the performance measures section of the application;
  3. There should be an additional competitive preference within the competition for applicants that outline a detailed plan for assisting students with the transition from high school to college.

Recommendation 1: Setting a goal to improve persistence or credit accumulation
Setting postsecondary outcomes as the focus of the nation’s high schools is the single most important shift to accelerate college access and success. As outlined in our 2011 White Paper, Seizing the Measurement Moment, “In order to improve college students’ readiness, high schools need to know what is working, and what is not. Yet, educators rarely have access to that information….In a 2010 survey conducted by the professional services organization Deloitte, fully 92 percent of high school educators said that having data on students’ academic performance in college was critical for evaluating the effectiveness of high school curriculum and instruction. Moreover, 83 percent said that having that data would help them decide which subjects to improve. By contrast, only 13 percent of high school educators said they actually received information from school-wide reports; to the extent educators received any feedback on student performance, it was anecdotal and from former students or parents.”

Inspired in part by the Department’s efforts in the NCLB waiver process and earlier rounds of RTT, states are making progress in their public reporting of enrollment and persistence. Fifty states have already committed to publishing college enrollment and credit accumulation data in 2012. Forty-eight states have the technical capacity to measure postsecondary outcomes, and 30 states already issue high school feedback reports. Just this week, Colorado became the latest state to embrace the importance of public reporting on these issues, enacting a new law that will result in publicly reported CER and academic achievement, disaggregated by school, district, and other important characteristics. It is essential that schools begin referencing the data as they set goals and outline reform measures. Even in states where the data is not yet readily available, goal setting should include a consideration of student performance once students enroll in college, not simply graduation and college enrollment. Accordingly, the Vision section should include credit accumulation goals in addition to CER.

Recommendation 2: CER and CAR should be added to the performance measures section of the application
Once in college, low-income students are failing at alarming rates: even though they appeared college-ready at admission time, too many were unprepared for the rigor of college-level work. As a result, ensuring actual college readiness has become the primary goal of K-12 education. In line with that goal, RTT-D’s absolute priority 1 includes an expectation that an LEA “increase the rates at which students graduate from high school prepared for college and careers.” There is no better indicator of whether schools are graduating students that are actually prepared for college than to track and evaluate student performance in the post-secondary setting. For the reasons noted in Recommendation 1, and based on our experience raising enrollment and achievement among graduates of low-income high schools, we recommend that applications describe the extent to which the applicant has established annual ambitious yet achievable annual targets for CER and CAR.

Recommendation 3: A competitive preference for applicants that outline a detailed plan for assisting students with the transition from high school to college
In order to further the Department’s objectives for individualization and college readiness, we recommend the RTT-D program include a competitive preference for applicants that outline a detailed plan for assisting students with the transition from high school to college. Applications should include a plan for how a district will:

  1. support a college-going culture through setting school-level goals for college enrollment and persistence;
  2. ensure all students create postsecondary plans, beginning in 9th grade;
  3. provide individualized coaching by staff, volunteers, and other student peers;
  4. provide students with support for the college application and financial aid processes through a postsecondary planning course or expanded counseling programs;
  5. use postsecondary performance and remediation data to strengthen high school instruction; and
  6. provide professional development to educators on effective practices in supporting the transition between high school and postsecondary education.

The RTT-D program focuses on two powerful instruments of educational change: data and individualization. We applaud the Department for focusing on those two important priorities, and we encourage you to further embed those priorities in the performance measures and competitive preference sections of Race to the Top.
Sincerely,
J.B. Schramm
CEO and Founder

June 8, 2012

To whom it may concern:

The Cambridge Public School District in Massachusetts is dedicated to school integration; in fact, since the early 1980's, the Cambridge School Committee developed a school choice policy to enable parents and children to gain access to the best education for their families. The district remains committed to diversity in staffing, as well. The school district follows the mandates of the Supreme Court decision which allows that racial isolation can be addressed legally and that school districts can lawfully work toward achieving their compelling interest in diversity. We believe that federal funding should be used as a permissible basis for preference in funding programs.

In Cambridge Public Schools, we support the emphasis on cultural proficiency that the Massachusetts Department of Elementary and Secondary Education has included within its teacher evaluation process. Also, we applaud the Massachusetts Board of Education's commitment to a 100% standard when measuring academic achievement for all students, rather than comparisons by race which may or may not reach a standard of excellence

In conclusion, the staff of the Cambridge Public Schools believe that federal funding should reward innovative approaches to achieving diversity and that the need for diversity should be a priority in important new funding for school districts.

Sincerely,

Jeffrey M. Young
Superintendent of Schools
Cambridge Public Schools
159 Thorndike Street
Cambridge, MA 02141

Thank you for providing this opportunity to comment on the U.S. Department of Education's proposed priorities, requirements, definitions, and selection criteria for the Race to the Top District (RTT-D) program. The National Center on Time & Learning (NCTL) (www.timeandlearning.org) supports the Department's decision to use the competition to encourage the development and implementation of innovative, student-centered learning environments. Next generation educational models that support highly personalized, data-driven instruction are unquestionably needed to equip students with the knowledge and skills they will need to graduate ready for college and careers. Whole school redesign utilizing high-quality expanded learning time (ELT) as a framework can be a key to achieving these goals, and we urge the Department to include high-quality ELT as part of the grant program’s Competitive Preference Priorities.

OVERVIEW AND RECOMMENDATION

RTT-D Program Goals and Priorities: The RTT-D program is a competitive grant program designed to spur innovation in student-centered learning environments to improve teaching and learning through personalization, support for teachers and students aligned to college and career-ready curriculum; increase the effectiveness of educators and expand access to the most effective educators; decrease the achievement gap; and increase the rate at which students graduate prepared for college and careers. Rules for the evaluation of applicant’s plans include focusing on the educational experience of the individual student to tailor learning to meet his or her evolving needs, strengths, and interests; an approach to teaching and professional development that drives improved educator effectiveness; and frequent, focused use of data to accomplish both goals.

NCTL Recommendation for Accomplishing Program Goals: High-quality expanded learning time schools are closing the achievement gap and raising performance for high-needs students across the country, providing important models worthy of replication. NCTL believes that high-quality ELT schools are uniquely well-suited to accomplish each of the goals of RTT-D.

Because high-quality ELT schools are so well matched to the RTT-D program’s goals and requirements, NCTL recommends adding high-quality expanded learning time schools to the “Competitive Preference Priority” section that is intended to award points to the best applications. By incorporating a priority for districts that create a set of high-quality ELT schools into the application evaluation process, the Department can help ensure that the strongest plans rise to the top of the applicant pool.

Below is a detailed analysis of the relevant sections of the RTT-D program requirements and principles and how high-quality ELT schools serve the goals underlying those principles followed by a full explanation of the recommendation and language to accomplish it.

I. High-Quality Expanded Learning Time Schools Embody the Requirements and Principles Underpinning RTT-D's Absolute Priority and Selection Criteria Sections.

Creating personalized learning environments is specified as both RTT-D’s only Absolute Priority required of all applicants and as the means by which teaching and learning should be improved in section C of the Selection Criteria. Well-designed high-quality expanded learning time schools align well with the RTT-D program's focus by using extra time to personalize learning environments and going beyond the standardized curriculum to add opportunities for remediation, enrichment, and advanced work as needed to meet the needs of each student.

High-quality ELT schools are distinguished from other schools by offering at least 300 additional hours above and beyond the standard 6 ½ hour, 180 day school year. ELT schools are then able to leverage this additional time to: (1) have focused achievement goals; (2) use interim assessments to drive improved instruction and to target academic interventions; (3) provide teachers at least 120 minutes per week to collaborate with peers and to review student data; (4) have a culture of high academic and behavioral expectations; and (5) offer engaging enrichment classes, giving students the opportunity to build new skills and interests.

• The NCTL report, Time Well Spent: Eight Powerful Practices of Successful, Expanded-Time Schools (http://www.timeandlearning.org/?q=node/102), is a study of 30 high-performing, high-poverty expanded-time schools that provides real world evidence demonstrating the important relationship between more time and successfully achieving the goals of the RTT-D program. It is organized around powerful practices common to successful expanded time schools, one of which is individualization. Personalization of learning time is foundational to the success of ELT schools. More than just providing extra dosing of needed subjects, high-quality ELT schools continuously adjust instruction to meet each student’s specific learning needs. (See Time Well Spent, Powerful Practice #3, Individualize Learning Time and Instruction Based on Student Needs, pp. 30-37; additional supporting material and multimedia resources available online at http://www.timeandlearning.org/node/8).

The Selection Criteria include that the quality of an applicant’s plan will be determined based on the extent to which it addresses how learning and teaching will support individualization, specifically:

SECTION (C)(1): Learning. Plans will be evaluated based on the engagement and empowerment of all students through “high-quality content aligned with college and career-ready standards, frequently updated data about individual student progress, and intervention support options.”

• High-quality ELT schools provide an unparalleled opportunity to align curriculum and tools with new, higher-level college- and career-ready standards, including providing teachers and school leaders with the time needed for training and collaboration to implement the Common Core. The benefits created by these opportunities apply to all students in the school throughout the day, not just in the “extended time.” High-performing ELT schools, such as those profiled in Time Well Spent, also invest time in a range of programs geared toward preparing their students for success after high school graduation. In addition to the direct academic content and standards, high-performing ELT schools are also uniquely well-suited to take advantage of college and business partners, create school-wide cultures focusing on college completion, and provide support to first-generation college-goers as they navigate the selection, application, and financial aid process. (See Time Well Spent, Powerful Practice #6, Use Time to Prepare Students for College and Career, pp. 54-61; additional supporting material and multimedia resources available online at http://www.timeandlearning.org/prepare-college-and-career).

• High-quality ELT schools offer educators significantly more time to analyze student data, discover each student’s unique needs and abilities, and respond to the individual characteristics of their students to ensure that learning conditions match student needs. Analyzing student data takes time, which is in short supply in most schools. Knowing individual student deficits and strengths—as identified through data analysis—enable high-quality ELT schools to place students in extra classes targeting a particular need or in smaller groups, with teachers who have received additional training; and whenever the extra time is being used to create personalized learning time in this way, it also creates the opportunity for targeted assessments to more frequently monitor the progress of students and further fine-tune their learning environment. Data collection, analysis and application thus become a positive feedback loop that continuously improves educational practice. (See Time Well Spent, Powerful Practice #8, Use Time to Relentlessly Assess, Analysis, and Respond to Student Data, pp. 68-75; additional supporting material and multimedia resources available online at http://www.timeandlearning.org/analyze-and-respond-data).

• High-quality ELT schools have more time to recognize and meet the unique intervention support needs of at-risk students. Within the context of a well-designed expanded school schedule, teachers and school administrators have the time they need to get to know students and their families and adopt a more holistic approach to providing the academic, social, emotional, and extracurricular supports each student needs. Professional cultures that are built around collaboration and shared responsibility are better able to meet the full needs of each individual student. High-performing ELT schools included in the Time Well Spent report use a wide variety of programs, ranging from home visits and extended office hours to structured one-on-one weekly check-in time with a school liaison for at-risk students. (See, for example, Time Well Spent, Individualized Supports and Safety Nets at Golder College Prep, p. 36; additional supporting material and multimedia resources available online at http://www.timeandlearning.org/individualize-instruction).

SECTION (C)(2): Teaching. The Selection Criteria requires that programs demonstrate that “all participating educators participate in professional teams or communities and training that support their individual and collective capacity” to support effective implementation of personalized learning, adapt instruction to respond to individual needs, frequently measure student progress, and use the data to personalize instruction and improve educator practice.

Additionally, all participating school leaders and leadership teams must have the policies and resources necessary to structure schools as effective learning environments, including “sufficient flexibility and autonomy over such factors as school schedules and calendars, school staffing models, roles and responsibilities for educators and non-educators, and school-level budgets.” (emphasis added)

• High-quality ELT schools create far more time for collaborative teacher planning and professional development, allowing them to build professional learning communities capable of full implementation of personalized teaching and learning for all students. Through formal professional development, additional planning days and periods, extra opportunities to observe colleagues and meet with mentors, and collaborative team work, high-performing schools are using expanded time to build the highest-quality teaching corps. Teachers can be trained to assess data and put that data to use to identify and respond to individual student needs, and they are in the best position to do so; but the training takes time. The actual work that results – responding to the assessments by personalizing curriculum and instruction – requires even more time. The difficult challenge of refining lessons plans, analyzing student data to identify areas of improvement, and sharing instructional strategies cannot be done in isolation and requires that teachers and administrators have sufficient time to collaborate. Highly successful schools, like those in Time Well Spent, provide that time for teachers, focusing it on clear goals and providing teachers with frequent feedback and coaching to create a culture of continuous improvement of educational practice. (See Time Well Spent, Powerful Practice #7, Use Time to Continuously Strengthen Instruction, pp. 62-67; additional supporting material and multimedia resources available online at http://www.timeandlearning.org/strengthen-instruction).

• High-quality ELT schools provide school leaders with autonomy to design and implement new scheduling and staffing models and to invest leadership and staff with the control and “buy-in” necessary for accountability and sustainable performance. Local planning including school-level design teams led by principals and teachers coupled with district-level support and union negotiations has been the key to successful implementation of the Massachusetts Expanded Learning Time Initiative, a statewide program supporting 19 expanded-time schools in 11 districts, five of which are profiled in Time Well Spent. In all Massachusetts ELT Initiative schools, a minimum of 300 hours must be added to the school schedule, but how that new time is used as well as the full redesign of the existing schedule and staffing model, is left up to each school that applies for the state competitive grant program. (See National Center on Time & Learning, Learning Time in America: Trends to Reform the American School Calendar (2011), pp. 9-10, available online at http://s384478517.onlinehome.us/sites/default/files/Learning Time in America.pdf ; additional supporting material on the Massachusetts ELT Initiative available at http://www.mass2020.org/node/10).

II. High-Quality ELT should be Included in the Competitive Preference Priority to Reward Programs that are so Well-Suited to Meet RTT-D’s Requirements.

The only existing Competitive Preference Priority for “Results, Resource Alignment, and Integrated Services” focuses on securing outside partnerships to support the proposed plan. NCTL supports this priority. NCTL also supports, advocates for, and provides direct technical assistance to expanded-time schools to build partnerships with a full range of outside organizations, including higher education, businesses, community-based organizations, health and social service agencies, afterschool providers, and others. High-quality ELT schools have a unique ability to incorporate community partners into their school day, making the best partners integral to their educational mission, rather than just a disconnected program added when school is not in session.

RECOMMENDATION: Add a second Competitive Preference Priority for “High-Quality Expanded Learning Time” to the application scoring rubric.

High-quality expanded learning time provides a comprehensive and research-based means of meeting the RTT-D Absolute Priority and Selection Criteria. Thus, NCTL recommends adding a competitive preference priority for ELT with clear definitions and high-quality standards. High standards are key to ensuring that ELT applicants will accomplish the goals of the program and are particularly appropriate in the context of deciding whether applicants should earn a competitive priority while trying to drive application quality “to the top.”

There is significant evidence supporting the efficacy of the high-quality design elements for ELT schools. In addition to Time Well Spent’s practice-based documentation of high-performing ELT schools, recent research has provided powerful quantitative evidence supporting the need for substantially more time, demonstrating the powerful impact of increasing school time by more than 300 hours above the traditional district schedule. Roland Fryer studied the charter schools of New York City and found that students in schools with at least 25 percent more time than the district significantly outperformed students in charters with less time. In fact, almost all the city’s charters have more time than regular district schools, but what distinguished the high-performers from the rest was having significantly more time – more than 300 hours of additional time, on average. High-performing middle schools averaged 1,560 annual hours (345 hours more than the traditional district schedule); non-high performers operated with an average of 1,473 hours (258 hours more time than the district). The same distinction was true for elementary schools, where high-performers averaged 1,539 annual hours (324 hours more than the district), with the non-high performers averaging only 1,353 hours (138 more hours than the district). (See Will Dobbie and Roland G. Fryer, Jr, “Getting Beneath the Veil of Effective Schools: Evidence from New York City,” NBER Working Paper, No. 17632, December 2011 at http://www.nber.org/papers/w17632.)

In addition to directly advancing the RTT-D program requirements and being consistent with the proposal's existing partnership-focused priority, adding a high-quality ELT Competitive Preference Priority would be consistent with the Department’s other signature initiatives to advance school innovation and reform. In addition to the School Improvement Grant program’s requirement of “increased learning time” in the school Turnaround and Transformation models, the recent ESEA Flexibility waivers explicitly included high-quality expanded learning time in its school turnaround principles, alternative interventions for Priority and Focus schools, and as an alternative to afterschool programs funded through the 21st Century Community Learning Center program.*

The one distinction worth emphasizing to set RTT-D apart from ESEA Waivers or the required use of increased time in SIG is that this recommendation is limited to the context of providing points to gain a priority within an already competitive grant program designed to spur the highest-quality innovations. In this context, it makes sense to set the highest possible bar, providing clear and specific guidelines that take advantage of known success factors to lift the highest-quality plans to the top.

To accomplish this goal, NCTL recommends the following section be added:

“Competitive Preference Priority—High-Quality Expanded Learning Time Initiatives.

An applicant receives points under this priority based on the extent to which it utilizes high-quality expanded learning time in a subset of schools as a component of its plan to create student-centered learning environments that are designed to significantly improve teaching and learning through personalization.

In determining the extent to which an applicant meets this priority, the Department will consider –
(1) The applicant’s initial planning process to determine which schools would be included in the proposed expanded learning time initiative, including specifically:
a. Demonstrated evidence of a strong rationale for determination of which schools were selected;
b. School leader and teacher engagement at specific schools considered and ultimately chosen;
c. Community engagement; and
d. Relative poverty rates with the applicant’s higher poverty schools having received priority consideration in the process.
(2) The applicant’s plan for its post-RTT-D grant school-level planning for implementation of expanded learning time, including:
a. Commitment of district resources and technical assistance to schools;
b. Baseline requirements within which individual schools will have to operate when designing their specific schedules. In order to receive points under this priority, applicants must provide for both school-level autonomy around specific daily scheduling issues and set the following broad requirements:
i. School leaders will conduct an inclusive planning process that engages teachers and the community;
ii. The school schedule will be redesigned from the ground up, reexamining all use of existing time, not just adding hours at the end of the day, or days to the end of the year;
iii. A minimum of 300 hours will be added to the school schedule over the course of the day, week, or year, or any combination thereof;
iv. Additional student learning time will include significant increases in time for core academics, other subjects, and enrichment activities to ensure a well-rounded education; and
v. Significant additional time will be devoted to creating a professional learning community through avenues like collaborative teacher planning and professional development that will include the time necessary for the school to ensure that student data can be and will be analyzed and used by teachers to inform and improve practice and personalize learning.
(3) The applicant’s potential for union and management collaboration on expanded learning time, as evidenced by either contractual agreements around scheduling autonomy and flexibility or a demonstrated willingness to work together to create flexibility for expanded learning time schools.”

Thank you again for this opportunity to provide comments to the U.S. Department of Education regarding the future of this important program. NCTL would be pleased to respond to any questions the Department may have about our recommendation and looks forward to working with you to help make the program a success.

Sincerely,

Jennifer Davis David Goldberg
Co-Founder & President Director of Federal Policy

Endnote:
* This approach would also be wholly consistent with the Department's Supplemental Priorities for Discretionary Grant Programs, which include a priority for projects that are designed to significantly increase efficiency in the use of time, staff, money, or other resources in order to improve results and increase productivity. Supplemental Priorities for Discretionary Grant Programs, U .S. Department of Education, 75 FR 78586.

June 8, 2012

The Honorable Arne Duncan
U.S. Secretary of Education
400 Maryland Avenue SW
Washington, DC 20202

Dear Secretary Duncan,

Thank you for the opportunity to comment on the proposed rules for the district Race to the Top (RTTT) program. The AFT offers the following comments based on our members’ experiences implementing the state RTTT program, as well as our experiences with the School Improvement Grant program, and the Elementary and Secondary Education Act. Our members and the students they teach every day are the people most directly affected by these policies and programs.

The AFT was pleased to see that the department included the evaluation of school boards and superintendents. The AFT has long called for shared responsibility, or 360-degree accountability, for student learning, and the inclusion of that requirement in this RTTT grant competition is an important first step in that direction.

We also appreciate that the department would require evidence of union engagement in the development of an application, and evidence that teachers’ feedback has been incorporated into the final application. This is in addition to requiring the signature of the union president in the final application submission. The AFT is in complete agreement with the department that labor-management collaboration is the key to successful implementation of school reform, and we know that no reform works over the long term without the support and buy-in of educators in the school system.

The AFT questions whether districts have the capacity to successfully implement all of the district RTTT requirements in addition to all of the other U.S. Department of Education requirements. Just to be eligible, districts must commit to doing everything within the state RTTT program. This includes full implementation of the Common Core State Standards and assessments; developing and using data systems to inform instruction; fully implementing teacher evaluation systems; and supporting low-performing schools. We are already seeing districts struggling just to implement Common Core to the degree necessary, or just to get teacher evaluation systems up and running. Neither of these can be done without the full engagement of all staff. This is on top of many of these districts having to figure out their new accountability systems and other requirements as part of the ESEA waiver packages. It is not clear how layering a personalized learning environment that includes among other things, a personalized learning plan (defined as a formal document) for every student, on top of all of these other requirements will serve students.

While this competition would require districts to do a lot, it neglects to require them to do some basic things that would have a positive impact on student learning. Nowhere in the document, including the detailed criteria for a personalized learning environment, is there any mention of barriers to student success and what the system would do to address these barriers. Absent are requirements for districts to provide the tools, conditions and resources to enable teachers to do their jobs successfully.

The AFT also is concerned that that this district RTTT application process favors charter schools, especially online charters with the focus on digital learning content. This in despite of the incontrovertible evidence that states which allow unfettered expansion of charter schools and digital learning programs have experienced ongoing problems with quality and mismanagement—including financial irregularities. Taxpayers in California, Colorado and Pennsylvania have been fleeced by “virtual school” operators, who profit by taking in the full per-pupil amount that traditional brick-and-mortar public schools receive, rather than the amount of their actual instructional costs, which are much lower. Digital schools also are a major affront to America’s tradition of local control of education, with no requirements for digital education providers to demonstrate community support through a threshold number of petitioners or some other method.

Finally, the AFT reiterates our fundamental problem with the RTTT program. The RTTT brand serves to sort states—and now districts—into winners and losers. The real losers in this program are, of course, the millions of children in districts that will not receive RTTT funding, and who will thus miss out on much-needed programs and services.

Following are AFT comments on specific sections of the proposal.

Sincerely,

Kristor Cowan
Director, Legislation

Background
Schools and the students who attend them should not be dependent upon the results of a competition for funds ostensibly designed to help improve teaching and learning. This is particularly true in times of budget cuts and austerity measures in so many school systems. The AFT has always been troubled by the competitive nature of the U.S. Department of Education’s Race to the Top grant programs. Rather than picking winners and losers, our education policies should represent a comprehensive approach focused on preparing every student, not just a select few, to succeed in college, work and life.

Eligibility Criteria
Regarding Eligibility Criteria 4(a), the AFT is pleased to see that for the first time superintendent and school board members are also evaluated. The AFT has long called for shared responsibility, or 360-degree accountability, for student learning; including that requirement into this RTTT grant competition is an important first step in that direction.

The AFT will be watching the application process to see what districts propose, with an eye to whether the department will hold as rigorous a standard to proposals for the evaluation of teachers as it does for the evaluation of superintendents and school boards.

It is not lost on us that while teacher evaluations must include student growth measures, including state standardized tests if they are available, evaluations for school board and superintendent must only include an undefined “student outcomes performance.” The difference in treatment is striking. The AFT recommends that if teacher and principal evaluations must include student growth measures, including standardized tests if they are available, then superintendent and school board evaluations must be tied to the same standard.

Regarding Eligibility Criteria 4(b-c) and the requirement that applying districts must enable “access and use by stakeholders,” given the legitimate concerns about the quality of teacher evaluation systems and reliability of using test score data, the AFT recommends that applicants be required to guarantee teacher privacy with regard to the release of teacher evaluation and test score data. We also approve of limiting the availability and use of these data as in Reform Condition B(1)(c) to “students, educators, and parents” who can use the data “to inform and improve instruction and services.”

The AFT firmly believes that labor-management collaboration is the key to successful implementation of school reform, and we know that no reform works over the long term without the support and buy-in of educators in the school system. Consequently, regarding Eligibility Criteria 5(a), the AFT supports the requirement that union leaders sign on to the RTTT applications.

Application Requirements
Regarding 3(C)(iv), the AFT recommends that community-based partners also sign the application. These partners are key to successful implementation of reforms.

Selection Criteria
Regarding A(2)(e), student attendance, research indicates that chronic absenteeism—often defined as missing 10 or more days per year for any reason—leads to lower student achievement and a greater likelihood of dropping out of school. The AFT recommends that instead of a rather nebulous goal of improving attendance, districts focus their efforts on improving the attendance of those at-risk of missing 10 or more school days per year by offering supports that have a track record of helping to keep such students in school.

Related to chronic absence is chronic tardiness, which is often as damaging to the tardy student as chronic absence, but even more disruptive to the education of other students because students who are chronically tardy disrupt the teaching and learning environment for everyone else in the classroom. The AFT recommends that districts also be encouraged to focus on improving chronic tardiness.

Regarding A(2)(f), the AFT questions why the department would include teacher attendance in this group, and strongly objects to this being yet another mechanism to identify “bad” teachers. First of all, there needs to be some critical look at the data behind teacher attendance. For example, teachers are more often ill because they work in settings with lots of ill children. Teachers in high-poverty schools are probably more likely to be sick than teachers in low-poverty schools because their students are less able to access their own healthcare. Also, teachers are predominantly women and women miss work more often than men so that they can care for their own sick family members. If the department is going to require an examination of teacher attendance, it should also require districts to examine the health of their buildings (are teachers missing schools because of mold?), how principals treat teachers (is morale so low that teachers need a break?) and many other factors that may cause teacher absences.

Reform Conditions
Regarding Reform Condition B(1)(b), the intervention models are not defined in the document. If, as we believe, the intervention models are the four “School Improvement” models previously defined by the U.S. Department of Education, the concerns articulated in our prior comments submitted to the department about the efficacy of these models remain unchanged. Further, we believe that our concerns are even more warranted as we witness continued implementation of these models in schools across the country and no body of evidence justifying their preferred status:
“Overall, we believe that the four options are too narrow, rigid and preclude the very reforms that have proven to be effective. Based on our experience and evidence, there are common characteristics that run through many—if not most—successful turnaround models. We recommend that the department consider offering districts a fifth model that would allow a school to choose the appropriate components that meet the needs of the students in that school. … Schools choosing this fifth model will need appropriate supports from experienced technical-assistance providers to facilitate successful, coordinated implementation of the strategies.”

The AFT would consider community schools as a viable and appropriate fifth model.

Regarding Reform Condition B(1)(c): The AFT believes that limiting student data to use by “students, educators and parents” to “inform and improve instruction and services” is an appropriate use of such data.

Regarding Reform Condition B(2): If the aim of this requirement is to improve teaching and learning, and ensure equity, we believe that the U.S. Department of Education is focusing too narrowly on salaries. This will provide an incomplete picture of the real problems underpinning hard-to-staff schools. To ensure that all schools and students have what they need, questions regarding building conditions, school discipline and safety policies, transportation and housing availability, and the level of professional respect and opportunities for growth each school offers should be asked and addressed.

Regarding Reform Condition B(3), the AFT appreciates that the department is requiring districts to submit evidence that stakeholders, including teachers, have been engaged in the development of the proposal and how the proposal has been revised based on their engagement and feedback.

We recommend that “community partners” be added to the list of those who should be engaged in the development of the proposal.

Specifically regarding B(3)(a)(i), the AFT strongly recommends that “evidence of direct engagement and support for” be replaced with “a certification signed by the recognized collective bargaining representative in support of.”

And specifically regarding B(3)a)(ii), the AFT strongly recommends that “have voted to” be inserted prior to “support the proposal.”

Preparing Students for College and Careers
Overall, related to “C. Preparing Students for College and Careers,” the AFT supports the concept of a personalized learning environment with the caution that it will require a significant coordination of resources and shift in how district staff works together. Implementation of this personalized learning environment is going to require significant time and effort. It is not apparent from these requirements that a phase-in of these components would be permitted. The AFT highly recommends having such a phase-in, and that the phase-in last beyond the first year of the grant.

Also, the creation of such personalized learning environments is going to require significant professional development and significant time to implement (akin to the current transition to the Common Core State Standards). We recommend that the provision of appropriate time and professional development be worked into the components of the personalized learning environment.

The AFT recommends inserting “community partners” after “teachers” in C(1)(b). Community partners are key to any successful school improvement initiative. In this specific case, community partners can offer engaging and relevant material that will enhance the personalized learning environment.

Regarding C(1)(b)(iii): This seems to suggest that within this personalized learning environment, the district would have to provide every student with a personalized learning plan defined as a formal document that would include personalized learning recommendations based on a student’s current knowledge and skills aligned with college and career-ready standards, and available content, instructional approaches and supports. The AFT believes that there is an appropriate role for such highly structured, formalized and individually personalized learning plans (for students with disabilities and students at-risk of dropping out, for example), but we also believe that the requirement that such plans be created for every student in the district would be overly burdensome and not result in increased student learning outcomes.

C(2)(c) would reward applicants that ensure school leaders have sufficient flexibility and autonomy over such factors as school schedules and calendars, school staffing models, roles and responsibilities for educators and non-educators, and school level budgets. The AFT objects to this for two reasons: First, this could conflict with provisions of IDEA and IEPs that are currently being used for thousands of children across the country. These IEPs are by definition very prescriptive in terms of student schedules, and staff required to serve such students. Second, calendars, schedules and staffing are subject to collective bargaining, and we strongly object to a program that would bypass the collective bargaining process in pursuit of principals’ “flexibility and autonomy.”

Regarding C(4)(f and g), the way these performance measurements are structured, the department has set as the goal of these two measurements simply to achieve targets in the number and percentage of educators and students completing a survey. The AFT believes that the department should be holding districts to the goal of reviewing survey data results and then planning for and implementing measures to improve outcomes. For example, by the department’s definition, student surveys should measure students’ perspectives on teaching, learning and related supports. The goal should not be that a certain percentage of students complete such surveys, but that over time, survey results produce increasing levels of satisfaction for such teaching and learning supports.

Competitive Preference Priority
The AFT commends the department for including community partnerships as a competitive preference priority. Given how essential such partnerships are to the success of a school system, we would have liked for them to be included in this grant competition as a mandatory requirement for all district applicants, rather than as an add-on that could earn applicants extra points in the competition.

We strongly believe that community partnerships with schools can only succeed if there is strong coordination between all parties. To that end, we recommend that Competitive Preference Priority 3 be revised to read, the integration “and coordination” of education. … And we recommend adding an additional bullet under Competitive Preference Priority 4: “coordinate the resources and services that support teaching and learning.”

Program Requirements
The AFT unequivocally supports program requirement 4. Requiring district grantees to develop plans to ensure that minority and disabled students are not overrepresented in discipline and expulsion cases is an appropriate condition that should be met.

Definitions
The AFT recommends adding a definition for “stakeholder” and requiring that this definition be applied whenever the term “stakeholder” is used in the document, because school improvement cannot succeed without the involvement of these crucial partners. Our recommended definition is: “parents, students, teachers, principals, LEA leaders, community residents and community partners.” Such community partner organizations may include groups such as public and private agencies; community-based organizations; local government; institutions of higher education; family support groups; after-school program providers; museums and other cultural institutions; faith-based organizations; civic organizations; teachers unions; researchers; city, county and state elected officials; grant-making foundations; and other funding sources.

America Forward is a nonpartisan initiative, spearheaded by the national venture philanthropy fund New Profit Inc., that connects policy makers with social entrepreneurs to advance policy principles that embrace innovation, reward results, and catalyze cross-sector partnerships. The America Forward Coalition is a network of social entrepreneurs and high-impact organizations who believe that a public policy approach that incorporates the principles of innovation, performance, competition, accountability, and results will generate real solutions to otherwise intractable social problems. The members of the America Forward Coalition support a variety of innovative, results-focused federal education policy proposals in areas including teacher and leader effectiveness, wrap-around services, quality charter school expansions, whole school transformation of low performing high poverty schools, and expanded learning opportunities. Our Coalition members' missions, while they vary in wording, share a common purpose: to ensure that all children, whatever their background, receive a first-class education, one that leads to economic security and the chance for a successful life.

Too often school districts are required or incentivized to use federal funding internally when quality external partners could provide more effective solutions. Such solutions may range from comprehensive whole school transformation interventions to a collection of specific initiatives that, taken together, provide the full array of supports and assistance to remove barriers to learning and build teachers’ capacities. America Forward believes these supports should extend from early childhood through higher education, be data-driven, coordinated with the school’s own improvement efforts, and provide high performing nonprofit partners with access to the data and information they require to ensure students from even the most disadvantaged backgrounds have the support needed to reach their full potential.

In order to help ensure successful outcomes for RTT-D grants, America Forward believes the proposed criteria should be amended so that it encourages partnerships with high-performing, non-profit organizations and strengthens expanded learning opportunities for students. Accordingly, America Forward asks the Department to consider the following recommendations:

Eligible Applicants – To ensure meaningful participation of partner organizations and to help facilitate the successful implementation of grants, eligible applicants should be expanded in a manner similar to i3 grants to include LEAs, a consortia of LEAs, LEAs or consortia of LEAs in partnership with a nonprofit organization (including an intermediary organization), and a nonprofit organization (including an intermediary organization) in partnership with an LEA or consortia of LEAs.

We recommend amending the following section to read as follows:

    Eligibility Criteria

1. Eligible applicants include individual local educational agencies (LEAs) (as defined in this document), consortia of LEAs, LEAs or consortia of LEAs in partnership with a nonprofit organization (including an intermediary organization), and a nonprofit organization (including an intermediary organization) in partnership with an LEA or consortia of LEAs.

a. An eligible applicant may apply for all or a portion of their schools, for specific grades, or for subject area bands (e.g., lowest-performing schools, secondary schools, feeder pattern, middle school math, or preschool through third grade).

b. An eligible applicant may join a consortium that includes LEAs across one or more states.

In addition, eligible applicants should be required to obtain approval (signatures) from non-profit organizations that are participating in the grants as well as from those already required under the proposed criteria (superintendent/CEO, local school board, and local union/association president) to ensure buy-in from all key stakeholders at the outset, increasing the likelihood of a strong partnership and overall success.

We recommend amending the following section to read as follows:

    Eligibility Criteria

5. Required Signatures for the eligible applicant

a. Superintendent/CEO, local school board, and local union/association president (where applicable), and representative from a non-profit organization that forms a partnership with an LEA or consortia of LEAs (as applicable).

Personalized Learning Environments – To help ensure personalized learning environments are effective, language under Absolute Priority 1 should be revised to include expanded learning opportunities (including before school, after-school, summer learning, and/or expanded learning time programs) as a way to significantly improve teaching and learning through the personalization of strategies, tools, and supports for teachers and students that are aligned with college- and career-ready standards.

We recommend amending the following section to read as follows:

    Absolute Priority 1, Personalized Learning Environment(s)

To meet this priority, the application must coherently and comprehensively address how it will build on the four core educational assurance areas (as defined in this document) in Race to the Top to create student centered learning environment(s) that are designed to:

(1) Significantly improve teaching and learning through the personalization of strategies, tools, and supports for teachers and students that are aligned with college- and career-ready standards (as defined in this document) including through expanded learning opportunities such as before school, after-school, summer learning, and/or expanded learning time programs;

(2) Increase the effectiveness of educators, and expand student access to the most effective educators in order to raise student achievement;

(3) Decrease the achievement gap across student groups; and

(4) Increase the rates at which students graduate from high school prepared for college and careers.

Points Awarded for the Competitive Preference Priority – The language related to the competitive preference priority is vague with regard to the number of additional points that could be awarded under the application. To help encourage partnerships under the RTT-D program, the Department should award significant points as part of the competitive preference priority to adequately incentivize partnerships.

Partnerships – In determining the extent to which the eligible applicant receives extra points under the competitive preference priority, the Department proposed that it will consider whether the applicant has formed a coherent and sustainable partnership with public and private organizations and fails to recognize the need to not only provide services outside of the school, but to change school culture to better support all students. This language should be amended to allow applicants that commit to forming partnerships to also be eligible to apply for a grant (as opposed to only allowing existing partnerships to apply for a grant); ensure partnerships are high-quality and with high-performing partners; and to also focus on the goal of transforming school culture into a positive teaching and learning environment.

We recommend amending the following section to read as follows:

    Competitive Preference Priority—Results, Resource Alignment, and Integrated Services

An applicant receives points under this priority based on the extent to which it integrates public and private resources to augment the schools’ core resources by providing additional student and family supports, such as addressing the social-emotional, behavioral, and other needs of the participating students (as defined in this document), giving highest priority to those students in high- needs schools; and by providing supports that build schools’ capacities and competencies to confront nonacademic and academic barriers to student success, establish a positive culture for teaching and learning, and provide professional development to enhance teachers’ skills and achieve excellence in teaching and learning. A reform proposal does not need to be comprehensive, but could address a subset of these needs.

In determining the extent to which the applicant meets this priority, the Department will consider –

(1) Whether the applicant has committed to form or has formed a coherent and sustainable partnership with public and private organizations, such as public health, after-school, and social service providers; businesses, philanthropies, civic groups, and other community-based organizations; early learning programs; and post-secondary institutions to support the plan described in Absolute Priority 1…

(6) Whether the applicant has included partners that will help build schools’ capacities and competencies to make dramatic improvements in student and school performance by confronting nonacademic and academic barriers to student success, delivering evidence-based interventions to struggling students, establishing a positive culture for teaching and learning, and providing professional development to enhance teachers’ skills and achieve excellence in teaching and learning.

(7) Whether the applicant has established benchmarks for outcomes and quality measurements for partners.

Partner Organizations – The competitive preference priority only mentions “after-school” as a possible partner organization. To ensure the full range of expanded learning opportunities is included under the grant, the language should be revised to include intermediaries as well as before school, after-school, summer learning, and/or expanded learning time programs as possible partner organizations.

We recommend amending the following section to read as follows:

    Competitive Preference Priority—Results, Resource Alignment, and Integrated Services

An applicant receives points under this priority based on the extent to which it integrates public and private resources to augment the schools’ core resources by providing additional student and family supports, such as addressing the social-emotional, behavioral, and other needs of the participating students (as defined in this document), giving highest priority to those students in high- needs schools. A reform proposal does not need to be comprehensive, but could address a subset of these needs.

In determining the extent to which the applicant meets this priority, the Department will consider –

(1) Whether the applicant has committed to form or has formed a coherent and sustainable partnership with public and private organizations and intermediaries, such as public health, before school, after-school, summer learning, and/or expanded learning time, and social service providers; businesses, philanthropies, civic groups, and other community-based organizations; early learning programs; and post-secondary institutions to support the plan described in Absolute Priority 1…

Staff Participation – Under the competitive preference priority, the Department will consider how the eligible applicant will build the capacity of staff in participating schools to meet the purposes of the grant. To ensure adequate coordination and collaboration, staff development activities should be conducted jointly among LEAs and partner organizations.

We recommend amending the following section to read as follows:

    Competitive Preference Priority—Results, Resource Alignment, and Integrated Services

An applicant receives points under this priority based on the extent to which it integrates public and private resources to augment the schools’ core resources by providing additional student and family supports, such as addressing the social-emotional, behavioral, and other needs of the participating students (as defined in this document), giving highest priority to those students in high- needs schools. A reform proposal does not need to be comprehensive, but could address a subset of these needs.

In determining the extent to which the applicant meets this priority, the Department will consider –

(4) How the partnership will build the capacity of staff in the partnering organization as well as participating schools (as defined in this document) by providing them with tools and supports to –

i. assess the needs and assets of participating students that are aligned with the goals for improving the education and family and community results identified by the partnership;

ii. identify and inventory the needs and assets of the school and community that are aligned with the goals for improving the education and family and community results identified by the partnership;

iii. create a decision-making process and infrastructure to select, implement, and evaluate solutions that address the individual needs of participating students (as defined in this document) and support improved results;

iv. engage parents and families of participating students in both decision-making about solutions and in addressing student, family, and school needs; and

v. routinely assess the partnership’s implementation progress and resolve challenges and problems.

These recommendations are submitted by the undersigned members of the America Forward Education Task Force: ACCESS, America’s Promise Alliance, AppleTree Institute, Be the Change, Inc., BUILD, The Children’s Aid Society, Citizen Schools, City Year, College Possible, College Summit, Commongood Careers, Genesys Works, “I Have a Dream” Foundation, Jumpstart, KIPP Foundation, Playworks, Public Allies, Save the Children USA, Teach for America, Turnaround for Children, Inc., YouthBuild USA.

Significant Race to the Top funding – over $4 BILLION - is currently allocated to 18 states plus the District of Columbia. Of this amount, states are obligated to allocate half to school districts. In the State of Florida, for example, the sum should be approximately $350 million for the State and $350 million for school districts. Given access to these sizeable funds through state grant, it would seem reasonable to level the playing field by either limiting the district RTT awards given to districts within these states or by adding significant competitive priority points to districts within states with no RTT award. The result of ignoring this elephant in the room could easily be school districts with millions of support dollars in state RTT plus millions of additional support dollars in their own district RTT funds while other districts have no sources of support.

In 2009, the announcement of the Race to the Top program signified a critical shift in Federal policy towards finding, supporting and helping replicate educational practices and innovations that have been proven to truly work for student achievement. This shift has already begun to result in marked improvements across the nation, with the program’s competitive grant process spurring districts and states to implement the proven reforms and innovations that will drive them towards improved academic outcomes for students. For this potential to continue to be fulfilled, however, the Race to the Top program must now cross a critical juncture and begin to make accommodations for the hundreds of mid-sized urban school districts like Bridgeport CT which have long been ignored.
The stories behind mid-sized urban cities like Bridgeport are all too familiar. The booming industrial and manufacturing centers of the country throughout the 1940s and 1950s, these cities quickly found themselves in the 1970s suffering from rapid deindustrialization and economic decline. In Bridgeport, a city which once hosted 500 different factories, jobs quickly became scarce. To compound the economic devastation of deindustrialization in these cities, as factories closed and jobs were lost, property values quickly plummeted. In states like Connecticut where education funding comes primarily from local tax bases, this all too often meant that funding and resources for schools rapidly dried up. The end result for all of these cities has been destructive, the students living in poverty who need the most support are provided with the fewest resources. What’s worse; while larger urban centers have more recently benefited from both public and private investment in school reform, the medium sized cities like Bridgeport for the most part continue to remain ignored.
It is the medium sized cities, however, where the greatest potential for dramatic impact on student achievement can be found. The reason for this potential lies in the very reason for which they are often ignored; their size. Unlike a typical larger city like New York, with its 1,700 schools and 1.1 million students, it does not take an overly significant investment to produce major changes in place like Bridgeport. Instead, smaller investments into mid-sized cities can rapidly transform entire school systems, producing transformational outcomes for students in a far shorter period of time. Furthermore, by limiting these investments to states like Connecticut where NCLB waivers have been granted, we can ensure that investments are being implemented in state legislative environments which have the flexibility necessary for effective reform.
The implications for these types of investments are clear, with smaller investments needed and quicker turnaround times required, accommodating mid-sized cities in the Race to the Top program can lead to the transformation of not just four to five urban districts over the course of a few years, but hundreds. It is in these hundreds, in places like Harrisburg PA, Buffalo NY, Sacramento CA, Bridgeport CT and so many more, where the most significant impact on the achievement gap can be made through Race to the Top, and ultimately it is for that reason why we urge the Department of Education to consider this change.

The Arkansas Association for Infant Mental Health would like to voice support for Race to the Top as we recognize laying an effective life foundation is essential. We must, however, begin to focus on the earliest years of life, as getting ready for school begins at birth.

The incontrovertible evidence from research in early brain development tells us that a child’s earliest experiences play a dramatic role in a child’s ability to form a strong foundation for learning, to grow up healthy and to enjoy success in later life. Babies are born to learn; the emergence of basic skills and competencies is directly linked to the later development of more sophisticated, complicated skills and competencies.

Children who have experienced early life trauma or a “vacant” early childhood seldom arrive at education’s door ready to learn. They bring with them their own unique set of challenges that do not easily resolve with only traditional educational experiences—especially when intervention begins much too late. Sustained exposure to risks (extreme poverty, chaotic home environments, malnutrition, abuse, neglect, toxins, or poor quality child care) can influence the developing architecture of the brain, preventing infants and toddlers from fully developing the neural pathways and connections that facilitate later learning. Scientists now know that toxic stress experienced in early childhood can lead to life-long problems with learning, behavior, and physical and mental health. Because the brain’s capacity for change decreases with age, it is much easier to positively influence the baby’s growing brain than to try to repair its circuitry in later years.

Good quality research-based early intervention programs can improve the odds of positive outcomes. We must translate what science tells about the needs of infants and toddlers into effective, evidence based policies and practices. Dollars invested early in a child’s life can yield extraordinary societal returns. The public reaps benefits of reduced crime, abuse, neglect, and welfare dependency—all of which lead to a more productive workforce.

Early childhood education must be included as a priority in public education. Please give first consideration for grants to programs that include early childhood education in their plan.

Thank you so much for the opportunity to comment.

Bonnie Limbird
President, Arkansas Association for Infant Mental Health

EdLeader21 Comments
Race to the Top for Districts (RTTTd) Guidelines

Contact: Valerie Greenhill, CLO, EdLeader21, vgreenhill@edleader21.com

These comments have been submitted by Valerie Greenhill, Chief Learning Officer, EdLeader21. EdLeader21 is the nation’s first professional learning community of district and school leaders committed to 21st century student outcomes. We have over 90 members in 30 states representing 1.7 million students.

Overall recommendation:
While we applaud the RTTTd initiative for encouraging district-level reform led by district leaders themselves, these guidelines present a narrow definition of innovation that depends on traditional metrics for student success. But there are many districts at the cutting edge of innovation that are working on the "next generation" of what defines student success.

We recommend that the administration consider an expansion of the current proposal that supports innovative district leaders who are focused on 21st century student outcomes such as critical thinking, communication, collaboration, creativity, global competence and financial/entrepreneurial literacy. By doing so, the administration will broaden the RTTTd program to truly support some of the most innovative reforms happening in districts throughout the country.

We are encouraged by the following elements in the guidelines:
• The criteria for proposals do not prevent districts from focusing their RTTTd initiatives on the 4C’s/deeper learning/21st century skills. There are clearly ways (though we wish they would be more explicitly supported) that innovative district leaders can meet the application guidelines while also focusing on innovation around critical thinking and problem solving skills for students.

• The eligibility requirements are creatively constructed in ways to encourage maximum participation by a wide range of districts (the ability to meet the 40% free/reduced price lunch requirement by selecting a subset of students from a particularly school or group of schools or across a consortia of districts). The attention given to including rural schools is commendable.

• The section C1 (Learning) includes powerful goals for students to direct their learning via personal learning plans, and to pursue learning in ways that are collaborative. There is also a specific mention of the need to develop skills such as critical thinking, problem solving, teamwork and creativity in addition to content mastery. The guidelines are particularly strong here.

• Section C2 (Teaching) contains excellent goals for teachers to work collectively to improve personalized instruction.

• The focus on individualized instruction and high quality content is very strong throughout the guidelines. These are important areas of emphasis for truly innovative district leaders who are integrating critical thinking, communication, collaboration and creativity skills into their systems of teaching and learning. This emphasis supports initiatives that include project/problem/challenge based learning, blended learning, flipped classrooms, etc.

• The current approach as described is bold in the sense that it bypasses states regardless of Race to the Top (RTTT) funding status (i.e., a district is not required to be implementing common core or some of the other requirements in the state-focused Race to the Top).

• The guidelines correctly place emphasis on the need for community based partnerships.

• There is a strong emphasis on continuous improvement (though this is entirely focused on traditional metrics).

Concerns about the guidelines:

• Overall, the guidelines are intensely focused on tactics (such as individualized learning, metrics around graduation rates) rather than college and career ready student outcomes such as critical thinking, communication, etc.; despite the accommodations made for rural districts, the theory of action seems intended primarily for large urban districts.

• The selection criteria “A” around vision requires applicants to focus solely on traditional measurements of teaching and learning systems: summative assessment data, the achievement gap, graduation rates, college enrollment and student & teacher attendance – these metrics (with the exception perhaps of equity) are ones that EdLeader21 members (and many other education innovators) are currently trying to reshape. These guidelines codify traditional measures and in doing so, make it more difficult for education leaders to strengthen teaching and learning in ways that truly serve 21st century students.

• The requirement for evaluations of individual teachers, principals, superintendents and school boards make no mention of the urgent need for high quality assessments that measure the 4C’s. This is a significant concern. If traditional metrics continue to be used to assess student success this program will not create innovation in teaching and learning and may, instead, do great harm.

• There is only a slight mention of the 4C’s (in item C1 p.6) and only in relation to “college and career ready standards”; collaboration skills are not specifically mentioned and they should be a priority.

• There is a very weak reference to the notion of educator collaboration. Instead, guidelines focus on student performance data and individual teacher work. There do not appear to be any incentives for teachers to work in collaborative instructional teams across disciplines and/or grades.

• Item 4: Performance Measurement (p.10) is a glaring weakness in the guidelines – this list of annual targets is not compelling in terms of the student outcomes and learning environments that truly innovative district leaders focus upon. This section could be vastly improved by including specific references to the importance of formative measurement tools such as rubrics for critical thinking, communication, creativity and collaboration (EdLeader21 district leaders are developing and using these kinds of rubrics to measure student work currently, for example—innovations like this should be encouraged.) Portfolios, capstone projects and common performance tasks, and the data collection around such student performances, are being used today in EdLeader21 schools and districts—these are important to include.

Recommendations:

• Expand the current guidelines to incentivize proposals that focus on 21st century student outcomes such as critical thinking, communication, collaboration, creativity, global competence and financial/entrepreneurial literacy.

• Articulate a more innovative vision for student success. Specifically: in the vision section, be specific about the 4C’s (critical thinking, communication, collaboration, creativity, etc.) as the key focus for student success in addition to content mastery. It is critical that college and career readiness is defined/spelled out explicitly and repeatedly this way.

• Item 4 on performance measurement should be completely re-thought and re-written (see notes above) to include the use of rubrics, portfolios, capstone projects, project/problem based tasks, etc., all of which should be used to evaluate student mastery of the 4C’s and content.

• Any section describing the evaluation of teachers, principals and other school and district leaders must clearly describe the urgent need to use high quality evaluation processes and tools that integrate the 4C’s – critical thinking, communication, collaboration and creativity. The guidelines should also incentivize districts to create their own innovative tools and measures for this purpose.

• Establish clear incentives for districts to establish balanced accountability approaches for evaluating student performances that integrate the 4C’s.

• Fine-tune the language on “personalized learning” to include clear expectations that students become better self-directed learners.

• Include more emphasis on collaborative teacher teams that are pursuing interdisciplinary approaches to instruction.

Comments on the United States Department of Education’s Proposed District Race to the Top Program

June 8, 2012

The Honorable Arne Duncan
Secretary
U.S. Department of Education
400 Maryland Ave, SW
Washington, DC 20202

Dear Secretary Duncan:

Thank you for the opportunity to submit comments on the U.S. Department of Education’s proposal for a new District Race to the Top Program.

Strive commends the U.S. Department of Education for addressing the important role that districts play in comprehensive education reform. While it is critical to provide individual schools with the resources for dramatic change, it is equally important to create regional systems to ensure sustainability of school improvement efforts. At Strive, we are dedicated to the creation of community-wide systems of reform, collaborating with district leaders and community partners to scale the successful teaching and learning strategies that improve student success nationwide.

We are excited about many aspects of the proposal released by the Department in late May and hope to see the following policies remain in the final regulations to be released this summer. These include:

• Competitive Preference Priority for Results, Resource Alignment, and Integrated Services – The key to sustainability of results is widespread community engagement and alignment across the educational continuum. We are excited to see the Department’s inclusion of this competitive preference priority and hope this encourages more districts to seek expertise and resources beyond the bounds of the traditional education system. By engaging a wide range of local partners and aligning their resources to support shared goals, communities will realize and sustain significant gains in student improvement.

• Productivity & Data Driven Decision Making – The emphasis on productivity through greater transparency of resources, ongoing continuous improvement, and resource alignment is key to transformative thinking at the district level. District leaders have to learn how to do more with less and new processes that emphasize continuous improvement and data driven decision making will empower districts to make important decisions about educational investments.

In addition to maintaining the policies above, Strive encourages the Department to consider the following improvements to the proposed District Race to the Top program:

• Eligible Entity – Clarify that districts can partner with intermediary organizations to drive continuous improvement, identify impactful practices, and align and leverage local resources to scale practices that will help the district meet identified goals. These organizations can be critical partners in connecting siloed systems and services and engaging public and private funders seeking to reform education. Communities across the country have begun to partner with local intermediary organizations to identify what works and better organize community resources. The results are striking: improved student outcomes and significant social return on investment.

• Ongoing Engagement of Community Stakeholders – While we commend the Department for encouraging applicants to engage community stakeholders in the application process, we encourage the Department to ensure continued involvement of key stakeholders throughout the implementation process. This will help Local Education Agencies (LEAs) expand their capacity and achieve sustainability of their reform goals. The Department can achieve this by adding the following language at the end of B.3.b. “and a description of the roles that each stakeholder will play to help the LEA achieve its goals.”

• Inclusion of Non-Academic Indicators – As districts track progress toward the goals outlined in their vision, it is important for districts to also track non-academic indicators. Success must be defined by academic performance and improvements to culture and the social and emotional well-being of students. We encourage the Department to add “at least two non-academic indicators” to the list of areas LEAs must track under the section titled Vision. This will give districts the flexibility to identify indicators relevant to their student population.

• Encourage Regional Scale and Sustainability – As applicants demonstrate how they will achieve district wide reform beyond participating schools, we believe it is important to encourage districts to think beyond their traditional geographic boundaries. The Department should change the language in B.4.D. to read as follows:

How the implementation plan will translate into meaningful reform and support district wide change beyond participating schools, and help the LEA reach its improvement goals (e.g., the applicant’s logic model or theory of change of how this approach will improve Student outcomes across all schools in the LEA, community, and region.)

• Additional Metrics for Performance Measurement – The following measures should be included in the performance measurement section to ensure a more robust picture of student learning:
- Number and percentage of participating students reading on grade level
- Number and percentage of participating students assessed ready for kindergarten
- Number and percentage of participating students who enroll in and complete some form of postsecondary education and/or training

• Drive Quality Continuous Improvement – To ensure grantees implement a quality continuous improvement process, we recommend strengthening the proposed language in D.4. to read: “Strategy for implementing a rigorous continuous improvement process that provides timely and regular feedback on progress toward project goals and opportunities for ongoing corrections and improvements during and after the term of the grant. This must include how the applicant will monitor, measure and use data to improve and scale best practices, and publicly share the quality of its Race to the Top District funded investments, such as professional development, technology, and staff.”

• Elevate the Importance of Cradle to Career Partnerships and Alignment – Community collaboratives across the country have begun to move the needle on education reform, celebrating significant results that span from cradle to career. These collaboratives recognize the need for dramatic change across the entire education continuum and have committed to an ambitious vision that tracks success from kindergarten readiness to college and career success. The Department should encourage more communities to embrace this type of reform by applying a sliding scale to the competitive preference priority with maximum points awarded to districts seeking funds for a cradle to career approach.

Thank you for the opportunity to comment on this important proposal. We look forward to working with communities in the months ahead to support effective ideas that will better inform policy and practice.

Sincerely,

Jeff Edmondson
Managing Director
Strive Network

About Strive:
Strive is catalyzing a national movement focused on the success of every child from cradle to career. Building on the principles of collective impact, Strive is helping communities create the civic infrastructure to unite stakeholders around shared goals, measures and results in education, and organizing a national network of cradle to career communities. Strive is a subsidiary of KnowledgeWorks.

Dear Mr. Secretary:

On behalf of the Illinois State Board of Education, we thank you for the opportunity to submit comments to the draft requirements and criteria proposed under the Race to the Top District Competition (RTT-D).

We are pleased to be a Race to the Top Phase 3 grantee. The momentum our Race to the Top application has created is invaluable to our state’s reform agenda. We hope that the RTT-D competition will not preclude future state competitions. Furthermore, as our comments will detail, we hope that the RTT-D competition will work in close alignment and coordination with our Race to the Top Phase 3 grant.

We were pleased to see the focus on personalized learning via Absolute Priority 1. As a state we are working to create the conditions for more personalized learning to take place in our districts. At least two initiatives that are part of our Race to the Top application support districts to deliver personalized learning. The Illinois Shared Learning Environment, which incorporates the Gates and Carnegie Foundation funded Shared Learning Infrastructure and Illinois state-level enhancements and extensions, will create a common data and technology platform to support personalized learning including the use of learning maps. Our approach to Programs of Study includes a requirement for individualized learning plans aligned to P-20 STEM Programs of Study at the high school level.

The Role of the State Should Be Increased

The RTT-D “Application Requirements” propose that states may be provided an opportunity to comment on district applications. A state review of applications should be required. Further, the time period established for the state review of these applications should be extended. We suggest at least two weeks to permit states to provide substantive comments and to increase the likelihood of the state’s comments contributing to the final content of the application. Also, the LEA response to the state’s comments is suggested as “optional”. We suggest that the response to state’s comments be mandatory.

District participation and buy-in were crucial to previous Race to the Top competitions. Similarly, we strongly believe that the sustainability and benefits of RTT-D applications relies heavily upon state support and coordination. We suggest that district applications that are endorsed by the state be given scoring priority. District applications that have a state endorsement will make it more likely that the district’s plans can be implemented and sustained successfully.
Furthermore we suggest that, similar to the previous Race to the Top competition requirement that 50% of state funds go to Participating LEAs, a significant share of RTT-D funds should be set aside to implement state RTT initiatives at the district level. For example, in order to ensure that the work of RTT-D grantees is leveraged outside of their boundaries, grantees should be required to develop and implement a plan, in coordination with the SEA, to share and disseminate the lessons learned in the implementation of their application with other non-participating districts in the state.

As the final regulations are developed we strongly recommend that SEA involvement be clarified so that it is explicitly made part of the implementation period and not limited to the application period. The long-term sustainability of district innovations developed through RTT-D will depend upon coordination and collaboration with the state. Furthermore we also recommend that stakeholder engagement be clarified to include the implementation period. Broad stakeholder engagement and support beginning in the application period and extending to the conclusion of the grant and beyond is key to a successful and sustainable plan.

Finally, if no funds, supplemental or otherwise, will be made available we seek to have the final regulations clarify that SEAs will not be required to provide additional supports, technical assistance, monitoring, or evaluation for RTT-D grantees.

RTT-D Should Align with Previous Race to the Top Competitions

District applications should align to existing requirements and investments that are part of previous Race to the Top competitions. For example, we are a Race to the Top Phase 3 state and our application makes a substantial investment in our reform agenda. District applicants, especially Participating LEAs, should be required to align their RTT-D applications to existing RTT state initiatives and our state’s reform agenda. At minimum, the alignment should make certain that existing state investments are not contradicted by the RTT-D competition.
Furthermore our state’s Race to the Top application contains several initiatives that directly address RTT-D competition priorities and requirements. Districts should be required to align their applications to existing state initiatives that already support RTT-D priorities and requirements. Districts should also be required to demonstrate how they will leverage existing state resources and investments in these areas. Close attention to alignment will help to ensure support and sustainability of their efforts.

We wish to thank you again for the opportunity to provide comments about the draft requirements and criteria proposed under the Race to the Top District Competition (RTT-D).

Sincerely,
Christopher A. Koch, Ed.D.
State Superintendent of Education