3) Policy and Infrastructure

3) Policy and Infrastructure. Comprehensive policies and infrastructure for learning that provide every student, educator, and level of the education system (e.g., classroom, school, and LEA) with the support and resources they need, when and where they are needed, including:

  1. The extent to which the LEAs have practices, policies, and rules that enable personalized learning through—

    1. Learning resources and instructional practices that are fully accessible, including for students with disabilities and English learners;
    2. The opportunity for students to progress and earn credit based on demonstrated mastery, not the amount of time spent on a topic; and
    3. The opportunity for students to demonstrate mastery of standards at multiple times and in multiple comparable ways.

  2. The extent to which the LEA and school infrastructure supports personalized learning through—

    1. 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;
    2. Ensuring students, parents, educators, and other stakeholders (as appropriate and relevant to students' teaching and learning) have appropriate levels of technical support which may be provided through a range of strategies (e.g., peer support, online, or local support);
    3. Using information systems that maintain student data and provide the capability for parents and students to export their information in an open data format (as defined in this document) that allows them to use the data in other electronic learning systems (such as electronic tutors, tools that make recommendations for additional learning supports, or software that securely stores personal records); and
    4. Ensuring that LEAs and schools use interoperable data systems (e.g., human resources, student information, and budget data systems) (as defined in this document).


I would like to make the recommend for a language clarification change as follows:

i. "Learning resources and instructional practices that are fully accessible (in and out of school) , including for students with disabilities and English learners; "

One of the key elements of personalization is providing flexibility for students who need more time. Therefore it is important that districts have policies for the extended graduation rate.

There are lots of reasons that students need more time: they were underserved in earlier years in schools and are entering school 2 or more grade levels behind; they need to work to support their family; take care of family members when illness strikes; or begin to take on tribal responsibilities. The extended graduation rate is also a balance against heavy-handed use of school discipline policies, especially for young people of color that are disproportionately suspended and expelled. Some leave school because they are bored or don't see value -- but a few months in the secondary labor market is enough to turn them around with new motivation to get their diploma and go to college.

Certainly personalized, mastery based pathways may accelerate learning so that students do not need to have a 5th year of high school. However, if they are entering high school more than 2 years behind in skills (which is often the case when their feeder schools are low-performing schools), then five years may be needed. In fact some of our best competency models are designed for students that are off-track including Boston Day and Evening Academy and Diploma Plus.

At this time only 12 states have embraced the extended graduation rate that provides incentives for districts and schools to serve those students that need more time to graduate. It is not clear how that may impact districts wanting to compete.

The Children's Defense Fund appreciates the opportunity to provide comments on the proposed guidance language for school districts applying for RTT funding.A full-day experience in kindergarten is one of the most critical components of the research-based Pre-K-3rd grade early childhood learning continuum; it is central to eliminating the third grade achievement gap that leaves so many children, particularly Black and Latino children, behind and likely to fail in later grades. The lack of Full-Day K in many states puts states that have adopted the Common Core State Standards for grades K-12 in English, Language Arts and Math on unequal footing as they assess the progress students are making from grade to grade. In schools and districts with half-day kindergarten programs where learning time is limited to 2.5 hours instead of the 5.0+ hours provided in full-day programs, quality early childhood instructional practice and curriculum offerings are compromised.
The Early Childhood Longitudinal Study-Kindergarten (ECLS-K) Class of 1989-99 has provided a wealth of data which has been studied over the years. This rich data source in addition to school-district-based studies has shown that children who participated in full-day programs when compared to their peers in half-day programs made statistically significant gains in early reading skills. With the adoption of the Common State Core Standards by forty-five states and DC, significantly more robust student outcomes will be required of kindergarten students successfully exiting kindergarten.

To give all children the full step they need between Pre-K and first grade and to increase access to free and publicly funded full-day kindergarten for all students, the Children’s Defense Fund strongly recommends the addition of a new section to Policy and Infrastructure to read as follows: “(3)(c) The extent to which the LEA and schools provide all eligible children with equal access to free and publicly-supported full-day kindergarten that is the same length of instructional time as first grade at no cost to the parent(s)/family, or has designed and is committed to implement a plan to provide full-day kindergarten that is the same length of instructional time as first grade at no cost to the parent(s)/family no later than the 2014-15 school year.”

CDF also recommends that the underlined language be added to part (3)(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, length of instructional day, and other learning resources both in-school and out-of-school;”

Recommendation for Policy and Infrastructure:

In order to strengthen RTT to be more inclusive especially those students that are over-age and undercredited, in foster care, juvenile justice or other marginalized students:

3.a.1: Insert and over-age and undercredit students after English learners.

3.b.1: The language here is problematic. As the Department knows many students are pushed out of school or unable to access programming. By referring to “participating” students it allows districts to continue to push out or deny access to students.

3b2: The language needs to be substantially strengthened in this section. It is not clear what “technical support” means. Students should be offered a full range of supports and opportunities including academic supports, enrichment opportunities to strengthen relevance and engagement, and social-emotional supports that are intricately interwoven with learning. See Motivation, Engagement and Student Voice for a review of the research on this topic. In addition, provision of support is not the same as effective or responsive support that is designed to meet the needs of students, parents, educators and other stakeholders. The text can be strengthened by changing language to say "a range of strategies that meet their needs."

Imagine a student grading system that eliminates the "tyranny of the zero" and truly looks at mastery.

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