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

I am a public school district grant writer. Thank you for considering these comments:

(1)Grant states that 40% of participating students must be from low-income families. This is sometimes difficult to ensure. Remember that federal law prohibits any school employee from knowing the specific FRL status of a given student. So even if your school is 50% FRL, you still have 50% that are not low income. While educators often figure out which kids struggle due to low family income levels, we're not allowed to know any child's family income status as per FRL data. Any grant sub-group in a school that has an overall FRL status of 50% does not necessarily consist of only youth who meet that FRL criteria. This is a concern with any federal grant that wants a school to ensure that participants are "low income." If we're to verify this, then give us access to knowing which students are on the FRL listing.

(2)Under reform conditions, section 2 about "increased transparency" please remove "a-d" (reporting personnel salaries). While I agree that schools and districts should be transparent, this just creates a ton of extra work for schools. It does nothing to improve the quality of the grant itself, and this single reporting will not ensure that a district suddenly becomes transparent. It also punishes the multitude of districts that are already transparent.

(3)The requirement to evaluate the Bd of Education needs to go. Most Bds of Education consist of elected officials. For a school system to evaluate its board is essentially a meaningless process as that evaluation will do little to impact a community election process. Plus, I think it's an infringement on the democratic community process of selecting elected officials.

(4)The program requirement to report discipline data for the purpose of addressing disproportionate minority representation is excessive and detracts from the grant. The heart of this grant is about instructional reform and engaged learning processes. When you have expert instruction, you improve school climate/culture and student behavior. This grant is not the place to furthering the dept's mission of treating discipline outcomes as civil rights violations, as the grant itself is quite massive in scope. If the Dept wishes to provide grant funds for examining LEA discipline outcomes, then a separate grant program is needed.

Thank you.

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.

June 6, 2012

The Honorable Arne Duncan
Secretary of Education
US Department of Education
Washington, DC 20201

Re: Comments on Race to the Top-District competition draft executive summary

Dear Secretary Duncan,

Urban Teacher Residency United (UTRU) is a national non-profit organization that supports the development of high-quality, effective urban teacher residency programs that prepare teachers to work in high-need schools—with a focus on performance-based preparation that leads to improved student achievement.

UTRU strongly supports the Race to the Top-District competition that aims to support the development of innovative, personalized teaching and learning models to promote college and career ready outcomes for all students, and emphasizes the District’s contribution to sustained, embedded school improvement efforts.

Through technical assistance and a national network of teacher residency programs, UTRU works to launch, scale, sustain, and improve residencies, concentrating on the key elements of high quality, effectiveness-based clinical teacher preparation, including: clinical preparation; evaluation; strategic recruitment; new teacher support through mentoring and induction; and partnership building with districts to target placement in high-need subject areas and grades.

Teacher residency programs are district-based teacher preparation programs that concentrate on preparing teachers to be effective from the first day in the classroom, and give them the knowledge and skills to be increasingly effective at moving student achievement and contributing to the school community over time. While residency programs are typically housed in a district, they are often developed and implemented in partnership with non-profit organizations and an institution of higher education. UTRU believes that no matter where teachers start, or how they enter the classroom, every teacher must be ready to be effective on their first day and be committed to education and the life-long learning cycle for children.

The Department’s draft executive summary provides an excellent foundation for the RTT-D competition that aligns well with the Race to the Top State competition, and the Department’s ESEA flexibility application requirements. UTRU strongly supports all efforts at strengthening teacher effectiveness outlined in the draft. Further, we commend the Department on prioritizing high need schools; flexibility and autonomy at the school level; sharing evaluation data and making data-driven decisions; and the ensuring transition plans concentrate on increasing the number of students who receive instruction from effective and highly effective teachers and principals, including hard-to-staff schools and subjects, especially STEM and special education.

UTRU believes the Race to the Top-District competition could be strengthened in the following ways:

1. Include teacher preparation programs at all levels of implementation and accountability for the Race to the Top-District competition requirements and competitive preference areas.
a. In establishing the policies and systems to enable teachers and teacher teams to continuously focus on improving individual student achievement, the theory of change should prioritize the engagement of preparation programs as key contributors to the learning cycle, professional development, and evaluation of effective teachers.
b. Sustainable partnerships with public and private organizations should include teacher preparation programs specifically. With a concentration on clinical-based preparation, and as districts become more strategic in utilizing multiple pathways for new teachers, teacher preparation programming has expanded its reach outside of traditional university-based models and this should be reflected in the supporting partnerships.

2. More explicitly describe and require professional development plans, for new and experienced teachers, to ensure they are prepared to differentiate instruction to meet the needs of every child, with a particular focus on those schools serving students in low-income communities.
a. Excellent classroom teachers are a core school-based resource for supporting the entire educator community and they must be equipped with the appropriate skills and training to meet the ambitious goal of improving learning outcomes for all students. Mentors and other clinical instruction faculty lay the foundation for new teachers and connect teacher preparation to the district’s existing student and teacher expectations.
b. Teacher preparation programs should align induction support for their candidates to the school and district professional development needs. Further, preparation programs should identify a graduating candidate’s strengths and needs as they enter the district to better align professional development planning.

3. Prioritize district human capital initiatives that seek to diversify teacher pathways and to integrate teacher preparation with district academic initiatives that enable teachers to differentiate instruction and personalize learning, such as teacher residency programs and other clinically-rich models. These models emphasize the theory-to-practice connection, and recruit and place teachers to meet district demand. Performance-based teacher preparation should:
a. Tailor programming to the district instructional curriculum and culture, and prepare educators in the content and pedagogy that is aligned to effective teacher standards.
b. Raise recruitment and selection standards, and concentrate on district priorities areas, such as STEM, middle school, diversity recruitment, special education, English language learners, or other areas determined by the district.
c. Address equitable distribution by training effective teachers to serve high-need schools, subjects, and grades, and commit to teaching in low-income communities.
d. Address academic achievement gaps by preparing excellent teachers with the specific skill sets needed to succeed in struggling schools and designed to excel from the first day as teacher of record.

4. Ensure that nonprofit organizations are included as key stakeholders, and that they are eligible partners for districts or consortiums of districts in designing and implementing the strategies determined for student-focused approach to teaching and learning.
a. Nonprofit organizations provide much-needed leadership, support and capacity, and as partners should provide letters of support for the application.
b. Nonprofit organizations should be included as part of the stakeholder community and as key members of any public-private partnerships to support LEAs.

5. Require LEAs to integrate teacher preparation program outcomes as part of a robust data system.
a. Structures must exist to track student achievement data and other indicators of teacher and student success across district departments and connect individual students with teachers, especially connecting human resources with curriculum, instruction, assessment, and evaluation, with the ability to report data on teacher effectiveness back to preparation programs.
b. Innovative programming that prepares and enables educators to determine their impact based on feedback from assessment and evaluation systems, and teacher preparation specifically, depends on student level P-12 data matched with higher education data.

Thank you for the opportunity to provide support and suggestions on the draft executive summary of the Race to the Top-District competition. We believe our suggestions will strengthen the program and we applaud the Department’s effort to identify reforms that will increase the effectiveness of educators and expand students’ access to the most effective educators.

Anissa Listak
Executive Director
Urban Teacher Residency United

The Cambridge NAACP in Massachusetts supports federal funding for integration initiatives within schools. Although the Cambridge NAACP is disappointed that many integration programs have been either eliminated or decreased in the last decade, we remain 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.

The Cambridge NAACP also supports the concept of cultural proficiency for all staff and we are pleased that the Massachusetts Department of Elementary and Secondary Education has included cultural proficiency within its teacher evaluation process.

Also, we agree with the Massachusetts Board of Education's commitment to a 100% standard when measuring academic achievement for all students rather than the stark analysis by race alone. We also applaud the MDESE in their goal of a Diversity Summit for educational leaders in Massachusetts in the near future. These efforts all assist in the realization of academic achievement and excellence for all children regardless of race or class.

In conclusion, the Cambridge NAACP believes 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. Please continue to consider all children in the effort to realize academic excellence and full social inclusion. This work cannot be achieved without dedicated funding.

Sincerely,

Kathy A. Reddick, President
Cambridge NAACP, Branch #2047

The National Council of La Raza (NCLR)—the largest national Hispanic civil rights and advocacy organization—is pleased to submit comments in response to the Department of Education’s (Department) proposed criteria for the fiscal year 2012 (FY12) Race to the Top District (RTT-D) Competition. This is an especially important opportunity for Hispanic students, given that over the past two decades, the share of Latino students in public schools has doubled from 11% to 22%. In 2009, Latinos accounted for 37% of all students enrolled in the 65 largest urban school districts, the highest proportion among all subgroups of students.

Although the educational outcomes of Hispanic students have improved slowly over time, gaps between low-income students of color and White students have not sufficiently closed. NCLR is deeply concerned about the educational progress of Latino students and sees the potential of initiatives like RTT-D as an opportunity to generate innovative policies and practices that improve educational outcomes for low-income students, including Hispanics and English language learners (ELLs). NCLR applauds the intent of the RTT-D competition, which is to promote innovative strategies for student learning. However, the Department should strengthen this framework to focus on developing new strategies to close the achievement and resources gaps that are so prevalent in our nation’s schools.

General Comments

NCLR has several general concerns with the proposed criteria and framework. First, the criteria provide little explicit mention of ELLs and students with disabilities. Although these students are included in the definition of “high need students,” NCLR strongly urges the Department to insert, “including ELLs and students with disabilities,” at every mention of “high need students” throughout this document to ensure that applicants make considerations for these student groups who are often ignored or overlooked. Secondly, the criteria are not clear on the role of charter schools and their eligibility to apply for the RTT-D competition. We urge the Department to clearly state how charter schools should be considered in this process. Lastly, NCLR feels that the overall approach of the criteria will limit a school district’s approach to innovation, rather than incentivizing school improvement.

Eligibility Criteria

NCLR questions the intent of the eligibility requirement that a local education agency must also design and implement a “school board evaluation” to qualify for this grant. Although it is important to develop systems of accountability for school board members, this requirement appears to be misaligned with the intent of this proposal. Being that school boards are elected and evaluations are technically handled by the public voting to retain or oust school board members, NCLR would urge the Department to require districts to facilitate the flow of information between the school board and parents, so that parents are fully aware of school board actions and activities. By facilitating this flow of information, parents will be well informed to take appropriate action to hold school boards accountable.

Selection Criteria

A. Vision

NCLR urges the Department to clearly articulate and define the word “equity” in this section. In its current form, this section of the proposed criteria lists performance indicators as areas for improvement (“a” through “e”); however it provides no guidance as to how these measures lead to “equity.” For example, improvements in the listed categories may not be sufficient to ensure that all students have access to high standards and effective teachers, nor would they be sufficient in ensuring that students have access to equitable funding. Without a clear framework and vision on how to achieve equity, districts may fall short of this goal.

B. District Capacity and Success Factors:

NCLR applauds the Department for including increased transparency in the proposed criteria for the RTT-D competition, including transparency in investments. Education reform and improvement are often hindered by inequitable resource distribution, and this inequity contributes to the existing achievement and attainment gaps between children from low-income communities and their more affluent peers. NCLR urges the Department to broaden the four categories of school-level expenditures listed under “Reform Conditions,” number 2, to explicitly include spending/funding associated with all of the conditions leading to school success, including school facilities. For example, high school students in all communities should have access to up-to-date science labs to prepare for college-level science classes leading to careers in technology and engineering. By requiring districts to report on these expenditures, schools, parents, and other education stakeholders will have a clearer sense of facility and resource gaps between schools.

NCLR also urges the Department to add an additional requirement that school districts have staff with expertise working with culturally and linguistically diverse and special needs students to implement programs for student learning. Without these experts, ELL and special needs students may not receive the supports they need to be successful.

C. Preparing Students for College and Careers

NCLR is very concerned that this section provides no clear timeline for districts to benchmark their progress or success. As currently drafted (“All participating students…should be able to, or be on a trajectory to, demonstrate content and skills mastery….”), districts can develop plans for moving students toward preparing for college and career indefinitely. Without the parameter of a timeline, the purpose of this section is unclear. Moreover, many of the approaches outlined in the “Learning” section are either too prescriptive or too vague to allow a district to develop a clear strategy for student learning. Lastly, the “Learning” and “Teaching” sections should make explicit mention of evidence-based strategies for supporting ELL students, like dual-language programs or early college high schools, and professional development targeted at enhancing the skills of educators who work with culturally and linguistically diverse students.

NCLR also suggests adding an additional category to the “Policy and Infrastructure” section, 3 (b), to require that school districts develop stronger, data-based professional development schemes to better prepare ELL and special needs students. By doing so, districts will be required to analyze the performance of ELL and special need students to better meet their instructional needs.

Lastly, NCLR recommends that the Department clarify the language included in the “Performance Measurement” section. Many of the enumerated categories are not performance indicators that require “annual ambitious yet achievable annual targets.” NCLR suggests that the Department create two sub-categories, one for actual achievement and gains toward college and career readiness currently listed as “a” through “c” and a second category for “d” through “g.”

D. Transition Plan and Continuous Improvement:

Consistent with our recommendation stated above, we urge the Department to explicitly include language on closing the achievement gap and the resource equity gap, including ensuring that students have access to high-quality facilities and materials.

E. Budget and Sustainability

NCLR urges the Department to include language in this section that requires applicants to realign their budgets and sustainability plans to close equity gaps. Districts should be required to show how their budgets and sustainability plans are effectively closing any resource gaps between schools in their districts.

Conclusion

NCLR anticipates that the Department’s proposed regulations will help schools provide high-quality services that will foster the academic success of students. We applaud the Department’s efforts to promote innovation in student learning and teaching, but we recognize that more must be done to ensure the success of all students. We thank you for considering our comments and look forward to working with the Department as it continues to implement RTT-D competition.

Sincerely,

Janet Murguía
NCLR President and CEO
National Council of La Raza

For more than a century Boys & Girls Clubs have helped put young people on the path to great futures. We annually serve nearly 4 million young people, through membership and community outreach. Our programs focus on three impact areas: Academic Success, Healthy Behaviors and Civic Engagement & Leadership.

To help ensure successful outcomes for RTT-D grants, we believe the proposed criteria should be amended so that it encourages partnerships between school districts and community-based partners and strengthens expanded learning opportunities to help increase the academic achievement of low-performing students. Accordingly, we ask 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 non-profit 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 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. LEAs 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 in 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.

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 form 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 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, 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.

Thank you for the opportunity to comment on the draft requirements, priorities, selection criteria, and definitions for the Race to the Top District competition. New Leaders strongly supports the RTT-D goal of growing district capacity to turn high aspirations into on-the-ground results for students.

Founded in 2000 by a team of social entrepreneurs, New Leaders is a national nonprofit that develops transformational school leaders and designs effective leadership policies and practices for school systems across the country. Research shows—and our experience confirms—that strong school leaders have a powerful multiplier effect, dramatically improving the quality of teaching and raising student achievement in a school.

As a research-based education organization that focuses on producing exceptional school leaders with the skills to dramatically improve school performance on a national scale, we believe that all districts can excel by committing to a strong vision of success that incorporates high standards and assessments for students; data systems that measure student growth and success, and inform teachers and principals about how they can improve instruction; recruiting, developing, rewarding, and retaining effective teachers and principals; and strategies for turning around the lowest-achieving schools.

As the Department considers the best approach to support districts through Race to the Top, we offer three areas for improvement:

1. Set the Goal and Let Districts Design the Strategy
New Leaders strongly believes that change happens at the school level, with district policies creating the supportive conditions for schools to succeed. District leaders, then, play a crucial role in helping schools prepare students for the future. To help districts in their efforts to build comprehensive and cohesive systems, New Leaders urges the Department to consider a modified approach to RTT-D. Currently, districts must demonstrate progress in the four core assurance areas (high standards, data systems, great teachers and leaders, and turning around the lowest performing schools) in order to be eligible for the program. Because the four core assurances are so critical to the success of schools and districts, we recommend that they be incorporated into more than just the eligibility requirements. Rather, strong district applications should demonstrate how these assurances will be brought to life in classrooms across the district. Selection criteria should directly call for applications that hold the core assurances at the forefront of strategies to build thriving learning environments for students.

Moreover, while we support personalized learning environments for students, we see them as one critical tool among a larger set of strategies that districts can deploy to increase student achievement. In keeping with the Department’s focus on outcomes with flexibility of design and implementation, we recommend recasting RTT-D to focus on the end goal of public school — healthy kids prepared for college and career. The grant program, then, should encourage a broad range of effective options in meeting this goal and provide the latitude for districts to construct plans that make the most sense given their individual needs. As one alternative, Absolute Priority One could be revised to read as, “To meet this priority, the LEA or consortium’s application must coherently and comprehensively address how it will raise student achievement, decrease the achievement gap across student groups, and increase the rates at which students graduate from high school prepared for college and career. In addressing these goals, an LEA or consortium’s application must demonstrate how it will leverage the four core education assurance areas as defined in this document.”

Under this new language, districts could choose to adopt personalized learning environments to meet the absolute priority. This broadened approach also allows for innovative ideas proposed in public comment by other organizations.

2. Remember the School Leader
The success of personalized learning environments, as well as many other approaches to instruction, is dependent upon the educators charged with teaching students. Great teachers and principals are crucial to student success. Several studies have shown that teacher effectiveness is the most important school-based factor influencing achievement . Teachers are critical to closing the achievement gap; yet, focusing too narrowly on teacher quality will not be sufficient to improve teacher practice, nor will it solve the other challenges that persist in schools. As will be presented in a soon-to-be-published New Leaders analysis of over 200 principals who were effective in driving gains in student achievement, principals improve teacher effectiveness by supporting teachers’ professional growth, providing effective management, and building positive environments where teachers want to work.

In order to transform low-performing schools, districts must increase the number of high-performing principals with strong instructional and adult leadership skills that enable them to recruit, select, develop and support strong teachers. On numerous occasions, U.S. Secretary of Education Arne Duncan has said, “There are no good schools without a great principal.” Further, researchers have noted repeatedly that there are virtually no cases of school turnarounds that have occurred without effective leadership. Principals have a significant impact on student achievement. A meta-analysis of 35 years of school leadership research found that principals’ actions account for 25% of a school’s total impact on student achievement. Additionally, principals play an important role in teacher retention—in a national survey of more than 40,000 teachers, 96% rated supportive leadership as absolutely essential or very important to retaining good teachers, more than any other factor.

Simply put, RTT-D must ensure greater focus on principal effectiveness.

While selection criteria C.2.c.i-iii address school leadership, they do so as a subcategory beneath the heading of Teaching, which conflates strategies for good teaching with strategies for good leadership. Schools need both. It also minimizes the importance of school leadership, which research shows is critical to school success. We recommend making School Leadership its own selection criterion. To be clear, a strong district proposal will recognize that strategies to recruit, select, develop and support teachers and leaders should be aligned. However, these strategies need not be identical; rather, they should reflect the differing expectations of these roles. In addition to strong instructional skills, school leaders also attend to other responsibilities such as building a school-wide culture of high achievement and aligning resources to needs across classrooms.

Across the country, states and districts working on RTT and ESEA Flexibility consistently give low visibility to principal effectiveness strategies. We believe that RTT-D can raise the focus on school leadership and encourage districts to implement sound strategies for principal effectiveness, which is critical to improving teacher effectiveness and student achievement.

Moreover, we recommend that the Department of Education expand the school leader selection criterion—which currently and rightly addresses the policies and conditions in which principals serve—to include skill building and training of the educators that are charged with raising the bar for students across an entire school. Supportive policies, tools, data, and resources are necessary but not sufficient to help school leaders achieve results. Districts must also think critically about the skills that principals need to lead high achieving schools. As such, we recommend that the Department include a selection criterion that asks districts to address the ways in which they will select, evaluate and develop their principal corps. A strong application will also demonstrate alignment and integration with other initiatives, such as teacher evaluation systems, new data systems, and high standards for kids. Because principals often have the primary responsibility for implementing teacher evaluations, setting expectations for the increased rigor of higher standards, and providing targeted support and development for staff, districts should think critically about building the skills of school leaders to meet their growing responsibilities.

3. Clarify What Success Looks Like
Finally, we recognize that in issuing final guidance for RTT-D, the Department has the opportunity to set scoring weights and guide districts toward strong and successful applications. To strengthen the final guidance, we have the following recommendations:

  • Differentiate the use of indicator and outcome data. Tracking indicators of success and evaluating outcomes of the RTT-D program is a vitally important management strategy for districts. To help differentiate their uses, we recommend that the Department of Education separate and retain outcome data from indicator data in the selection criteria. Outcome data is important for evaluating success; whereas, monitoring the right indicators of success helps districts stay nimble and approach implementation in a way that responds in real time to challenges and hurdles. For indicators to be most helpful they must be tailored to the district strategy and theory of change. Therefore, we also recommend removing the prescribed list of indicators for districts and instead permit applicants to demonstrate a sound theory of change and model appropriate indicators to their strategy. Including a list of example indicators (such as the percentage of participating students who access their personalized learning plan on a weekly basis or number and percentage of students on-track) in the RTT-D program may help districts as they undergo their own process of defining and adopting measures of success. To facilitate high standards and cross-grant evaluation, we support retaining a prescribed list of outcome data (such as the graduation rate and the number and percentage of participating educators who complete a survey on working conditions).
  • Define college to include community college pathways and include a measure for those students who commit to career training, which may lead to terminal certificates.
  • Expand sustainability to mean more than just dollars and cents. In these tough budget times it is essential that districts can demonstrate the means to continue important initiatives begun under RTT-D. Sustainability of the will to continue forward is also critically important. The journey to excellence is rarely short or easy. Districts can face many obstacles in continuing the momentum beyond the grant term, from leadership change to “reform fatigue” from stakeholders. A successful application should recognize this challenge and demonstrate in the proposal how the districts will actively approach sustainability, in terms of both the financial bottom line and the forward momentum.
  • Actively permit collaboration and partnerships with the non-profit sector. The Department rightly recognizes the importance of building bridges beyond the district and into the community. Partnerships with non-profits can provide needed expertise and capacity to districts looking to implement strategies. Though not currently prohibited by the language, we recommend that the Department explicitly make sub-grants and partnerships permissible under RTT-D.

Respectfully submitted by New Leaders
Jackie Gran, Chief Policy and Partnerships Officer
Erica Adams, Director of Policy
www.newleaders.org

June 7, 2012

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

Re: Race to the Top District Competition, Draft Requirements and Criteria

Dear Mr. Secretary,

On behalf of the National Governors Association, the Council of Chief State School Officers and the National Association of State Boards 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 (RTT-D) Competition.

State officials appreciate the leadership you have shown on education innovation. In particular, we appreciate that the proposed RTT-D competition takes into consideration some of our concerns and ensures better participation and representation from rural districts across the country. However, as education leaders tasked with managing education policy and reform in the states, we do not support directing limited federal funds to a district-based competition driven by prescriptive priorities. While we believe state innovation should be the primary driver of competitive funding streams, we appreciate RTT-D’s focus on personalized learning as well as its competitive priority around resource allocation and integration, as these are areas in which states are already leading.

As you know, many states applied under previous iterations of Race to the Top (RTTT) competitions with proposed innovative reforms and have yet to receive awards. We contend there is still much work to be done at the state level and believe that any funds authorized by Congress for RTTT should be awarded to the states in order to ensure that comprehensive reforms impact every student. State leaders continue to be concerned that RTTT is creating a federal education system that disadvantages many states, schools, and students. RTTT needs to be refined and adjusted to better support cross state and territory collaboration, recognize differences in capacity of states and territories, and support the development of a learning network that will disseminate best-practices among all states and territories. States have the primary responsibility for educating their students and the Department should continue to partner with states as its main priority to ensure all students succeed in the classroom and become college-and-career-ready.

We expect many states to submit their own comments to the draft requirements and criteria. However, this submission is a reflection of the overarching recommendations of governors, state departments of education, and state boards of education.

We assert that the Department can improve this proposed competition in the following ways:

District Applications Must be Consistent with State Laws and Regulations
Final application materials must clearly require that district applications be consistent with and not contravene state law. While we do not believe that it is the Department’s intent to supersede state law through RTT-D, the absence of an express requirement leaves open the possibility that districts could propose programs that conflict with state laws or policies. Long-term sustainability of district innovations developed through RTT-D will depend upon coordination, collaboration, and partnerships between districts and states. State education leaders strongly believe that providing funding for isolated reforms across a small handful of districts without requiring coordination with their respective states will lead to efforts that are neither scalable nor sustainable.

We also recommend that the Department require each application to include the signature of the state attorney general and/or the district(s) legal counsel attesting to the absence of any legal conflicts with state law. The Department imposed a similar requirement upon states during previous iterations of RTTT and is merited here to ensure compliance with applicable state laws.

Promote State and Local Partnerships
State education leaders appreciate that the RTT-D competition contemplates an opportunity for states to comment on their district applications. However, the limited comment window of five business days is a substantial barrier to a thorough, comprehensive state review of these applications, particularly when a single state may have multiple district applications. Individual states also have laws governing open meetings, freedom of information, and public comment to ensure full public participation and disclosure of the processes by which officials make decisions. These laws set specific timeframes that may exceed the five day requirement proposed in the draft criteria. We request that states receive a minimum of 30 days to review district applications in order to provide substantive commentary.

Furthermore, it is unclear the extent to which states’ comments will be part of the formal peer review scoring. Within earlier iterations of the RTTT grant program, district support was a critical component of states’ applications. We believe that similar consideration must be applied to states’ commentaries and support of their district applications. Alternatively, the RTT-D scoring system must strongly favor district applications that are endorsed by their respective states or completed in collaboration with their respective state departments of education. We strongly believe that the sustainability and benefits of district applications rely heavily upon state support and coordination.

RTT-D Should Align with State Efforts to Implement Other Federal Grant Programs and Initiatives
States are currently implementing a variety of federal grant programs including RTT and School Improvement Grants, as well as Elementary and Secondary Education Act waivers. States have worked carefully to ensure that the various performance measures and protocols required under these programs are aligned throughout the state and local level. To ensure that RTT-D does not frustrate the purposes and intended outcomes of these other policies, we believe that RTT-D must ensure that district applications do not establish requirements or performance measures in conflict with state efforts to implement existing federal programs. Additionally, we also recommend that within the proposed competitive priority around resource allocation, submitted applications should be required to demonstrate how they will leverage resources received under other grant programs and also align relevant program requirements.

RTT-D Must Not Pose Additional Requirements Upon States
RTT-D does not provide state education agencies (SEAs) with funds to provide additional support, technical assistance, monitoring or evaluation of districts being served by the grant competition. We seek express clarification that RTT-D does not require SEAs to provide such services.

RTT-D Should Ensure Rural Participation
Many small, rural, and frontier states were shut out of previous rounds of RTTT competitions. In fact, of the 29 states with populations of less than five million, only three were awarded funding in any round of RTTT. We seek an express guarantee that the department will fund quality applications within each of the proposed four Absolute Priority categories. As you are aware, 70% of districts in the country have fewer than 2,500 students. According to the Why Rural Matters 2011-2012 released by the Rural School and Community Trust, nearly 10 million public school students attend school in rural school districts. While we acknowledge the ability of districts to join consortia in order to apply for RTT-D, we still believe smaller districts will face a tremendous burden in dedicating staff time and resources to collaborate on applications. We strongly suggest that the Department develop a comprehensive plan and strategy to provide additional technical assistance to small, rural districts or consortia that include districts below the 2,500 student threshold.

Education Service Agencies and Districts Should Be Eligible to Apply with State Consent
We appreciate that any entity formally designated as a district will be eligible to apply under this competition. However, not every state formally recognizes Education Service Agencies or Departments as districts. We suggest that within states that lack such formal declarations, those entities be allowed to apply if they partner with districts and have the expressed consent from their state departments of education.

RTT-D Should be Open to All Territories
The U.S. territories of Guam, American Samoa, the Northern Mariana Islands, and the U.S. Virgin Islands were excluded from participating in the first three rounds of RTTT. We interpret the Fiscal Year 2012 Appropriations law (P.L. 112-74) to allow U.S. territories to compete in the RTT-D competition through a provision granting the U.S. Department of Education the authority to award funds to states, local education agencies (LEAs), or states and LEAs jointly.

Under the Race to the Top statute, LEAs are defined according to Section 9101 of the Elementary and Secondary Education Act (20 U.S.C. 7801), which provides that the term LEA “includes the State educational agency in a State in which the State educational agency is the sole educational agency for all public schools.” As you are aware, the U.S. territories are considered states for the purposes of the Elementary and Secondary Education Act. Further, the U.S. territories act as sole educational agencies for their respective public schools, consistent with the definition of an LEA. We urge the Department to use its vested statutory authority to ensure that all U.S. territories have the opportunity to compete in the RTTT program for the sake of fairness and equity.

Sincerely,

Dan Crippen, Executive Director
National Governors Association

Gene Wilhoit, Executive Director
Council of Chief State School Officers

Jim Kohlmoos, Executive Director
National Association of State Boards of Education

June 7, 2012

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

Re: Race to the Top District Competition, Draft Requirements and Criteria

Dear Mr. Secretary,

On behalf of the National Governors Association, the Council of Chief State School Officers and the National Association of State Boards 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 (RTT-D) Competition.

State officials appreciate the leadership you have shown on education innovation. In particular, we appreciate that the proposed RTT-D competition takes into consideration some of our concerns and ensures better participation and representation from rural districts across the country. However, as education leaders tasked with managing education policy and reform in the states, we do not support directing limited federal funds to a district-based competition driven by prescriptive priorities. While we believe state innovation should be the primary driver of competitive funding streams, we appreciate RTT-D’s focus on personalized learning as well as its competitive priority around resource allocation and integration, as these are areas in which states are already leading.

As you know, many states applied under previous iterations of Race to the Top (RTTT) competitions with proposed innovative reforms and have yet to receive awards. We contend there is still much work to be done at the state level and believe that any funds authorized by Congress for RTTT should be awarded to the states in order to ensure that comprehensive reforms impact every student. State leaders continue to be concerned that RTTT is creating a federal education system that disadvantages many states, schools, and students. RTTT needs to be refined and adjusted to better support cross state and territory collaboration, recognize differences in capacity of states and territories, and support the development of a learning network that will disseminate best-practices among all states and territories. States have the primary responsibility for educating their students and the Department should continue to partner with states as its main priority to ensure all students succeed in the classroom and become college-and-career-ready.

We expect many states to submit their own comments to the draft requirements and criteria. However, this submission is a reflection of the overarching recommendations of governors, state departments of education, and state boards of education.

We assert that the Department can improve this proposed competition in the following ways:

District Applications Must be Consistent with State Laws and Regulations
Final application materials must clearly require that district applications be consistent with and not contravene state law. While we do not believe that it is the Department’s intent to supersede state law through RTT-D, the absence of an express requirement leaves open the possibility that districts could propose programs that conflict with state laws or policies. Long-term sustainability of district innovations developed through RTT-D will depend upon coordination, collaboration, and partnerships between districts and states. State education leaders strongly believe that providing funding for isolated reforms across a small handful of districts without requiring coordination with their respective states will lead to efforts that are neither scalable nor sustainable.

We also recommend that the Department require each application to include the signature of the state attorney general and/or the district(s) legal counsel attesting to the absence of any legal conflicts with state law. The Department imposed a similar requirement upon states during previous iterations of RTTT and is merited here to ensure compliance with applicable state laws.

Promote State and Local Partnerships
State education leaders appreciate that the RTT-D competition contemplates an opportunity for states to comment on their district applications. However, the limited comment window of five business days is a substantial barrier to a thorough, comprehensive state review of these applications, particularly when a single state may have multiple district applications. Individual states also have laws governing open meetings, freedom of information, and public comment to ensure full public participation and disclosure of the processes by which officials make decisions. These laws set specific timeframes that may exceed the five day requirement proposed in the draft criteria. We request that states receive a minimum of 30 days to review district applications in order to provide substantive commentary.

Furthermore, it is unclear the extent to which states’ comments will be part of the formal peer review scoring. Within earlier iterations of the RTTT grant program, district support was a critical component of states’ applications. We believe that similar consideration must be applied to states’ commentaries and support of their district applications. Alternatively, the RTT-D scoring system must strongly favor district applications that are endorsed by their respective states or completed in collaboration with their respective state departments of education. We strongly believe that the sustainability and benefits of district applications rely heavily upon state support and coordination.

RTT-D Should Align with State Efforts to Implement Other Federal Grant Programs and Initiatives
States are currently implementing a variety of federal grant programs including RTT and School Improvement Grants, as well as Elementary and Secondary Education Act waivers. States have worked carefully to ensure that the various performance measures and protocols required under these programs are aligned throughout the state and local level. To ensure that RTT-D does not frustrate the purposes and intended outcomes of these other policies, we believe that RTT-D must ensure that district applications do not establish requirements or performance measures in conflict with state efforts to implement existing federal programs. Additionally, we also recommend that within the proposed competitive priority around resource allocation, submitted applications should be required to demonstrate how they will leverage resources received under other grant programs and also align relevant program requirements.

RTT-D Must Not Pose Additional Requirements Upon States
RTT-D does not provide state education agencies (SEAs) with funds to provide additional support, technical assistance, monitoring or evaluation of districts being served by the grant competition. We seek express clarification that RTT-D does not require SEAs to provide such services.

RTT-D Should Ensure Rural Participation
Many small, rural, and frontier states were shut out of previous rounds of RTTT competitions. In fact, of the 29 states with populations of less than five million, only three were awarded funding in any round of RTTT. We seek an express guarantee that the department will fund quality applications within each of the proposed four Absolute Priority categories. As you are aware, 70% of districts in the country have fewer than 2,500 students. According to the Why Rural Matters 2011-2012 released by the Rural School and Community Trust, nearly 10 million public school students attend school in rural school districts. While we acknowledge the ability of districts to join consortia in order to apply for RTT-D, we still believe smaller districts will face a tremendous burden in dedicating staff time and resources to collaborate on applications. We strongly suggest that the Department develop a comprehensive plan and strategy to provide additional technical assistance to small, rural districts or consortia that include districts below the 2,500 student threshold.

Education Service Agencies and Districts Should Be Eligible to Apply with State Consent
We appreciate that any entity formally designated as a district will be eligible to apply under this competition. However, not every state formally recognizes Education Service Agencies or Departments as districts. We suggest that within states that lack such formal declarations, those entities be allowed to apply if they partner with districts and have the expressed consent from their state departments of education.

RTT-D Should be Open to All Territories
The U.S. territories of Guam, American Samoa, the Northern Mariana Islands, and the U.S. Virgin Islands were excluded from participating in the first three rounds of RTTT. We interpret the Fiscal Year 2012 Appropriations law (P.L. 112-74) to allow U.S. territories to compete in the RTT-D competition through a provision granting the U.S. Department of Education the authority to award funds to states, local education agencies (LEAs), or states and LEAs jointly.

Under the Race to the Top statute, LEAs are defined according to Section 9101 of the Elementary and Secondary Education Act (20 U.S.C. 7801), which provides that the term LEA “includes the State educational agency in a State in which the State educational agency is the sole educational agency for all public schools.” As you are aware, the U.S. territories are considered states for the purposes of the Elementary and Secondary Education Act. Further, the U.S. territories act as sole educational agencies for their respective public schools, consistent with the definition of an LEA. We urge the Department to use its vested statutory authority to ensure that all U.S. territories have the opportunity to compete in the RTTT program for the sake of fairness and equity.

Sincerely,

Dan Crippen, Executive Director
National Governors Association

Gene Wilhoit, Executive Director
Council of Chief State School Officers

Jim Kohlmoos, Executive Director
National Association of State Boards of Education

The Children’s Defense Fund (CDF) Leave No Child Behind mission is to ensure every child a Healthy Start, a Fair Start, a Safe Start, and a Moral Start in life and successful passage to adulthood with the help of caring families and communities. CDF provides a strong, effective voice for all the children of America who cannot vote, lobby or speak for themselves. CDF educates the nation about the needs of children and encourages preventive investments before they get sick, into trouble, drop out of school, or suffer family breakdown. As part of our advocacy efforts, we launched the CDF Cradle to Prison Pipeline Campaign, a national call to action to stop the funneling of thousands of children, especially poor children and children of color, down life paths that often lead to arrest, conviction, incarceration, and even death.

The Children’s Defense Fund- New York (CDF-NY) respectfully submits the following comments regarding the proposed guidelines for Race to the Top- District (Guidelines).

REDUCING DISCIPLINARY DISPARITIES:
CDF-NY is a member of the Dignity in Schools Campaign (DSC), a nationwide coalition of parents, students, educators, and advocates, because we are fundamentally concerned about the detrimental impact of punitive school discipline on our nation’s students. This grant offers ED a unique opportunity to encourage districts to focus on dismantling the practices that push too many of our children out of school. As such, we fully support the comments submitted by DSC; in particular, we agree that all applicants with racial or disability-related disciplinary disparities should be required to undertake a needs assessment and develop a plan to address the root causes of these disparities. We hope that ED will make use of this opportunity in light of the Office of Civil Rights most recent data reporting as well as evidence from around the country of significant disparities in the application of discipline.

REVISING ATTENDANCE DEFINITION AND TRACKING REQUIREMENTS:
Additionally, CDF-NY applauds the call for districts to focus on more accurately measuring student attendance by requesting a student attendance count that does not include “excused absences, unexcused absences, or any period of time that students are out of their regularly assigned classrooms due to discipline measures (i.e., in- or out-of-school suspension).” In addition to this definition, we suggest that ED incorporate Attendance Works’ recommendation that districts be required to monitor chronic absenteeism (absences amounting to 10% or more in a given school year). However, as DSC suggests, we recommend that ED’s attendance tracking requirements for Race to the Top – District be structured in a way that will not negatively affect an individual student’s attendance record and unintentionally serve as another way in which schools push struggling children out – in this instance through grade retention based on attendance records.

CONCERN REGARDING COMPETITIVE GRANT STRUCTURE:
Finally, while we applaud ED’s intention of incentivizing districts to focus upon personalized learning environments and are likewise especially pleased to see emphasis placed on the role of social and emotional learning, we are concerned about the sustainability of initiatives that will be piloted through this grant. We recommend that more clarity be provided regarding how applicants will be given priority under each of the Absolute Priority categories.

With regard to Absolute Priorities Two - Five, our position is that ED should give preference to applicants that prioritize investments in low-performing schools through thorough needs assessment (that includes analysis of disciplinary rates and disparities) and a plan to address those needs in partnership with community.

We thank you for the opportunity to comment.

Sincerely,

Children’s Defense Fund- New York

For forty-seven years, the METCO program has served to reduce racial isolation in Massachusetts by sending thousands of urban students from Boston and Springfield to suburban school districts. As urban students gain access to a quality education, resident students gain an integrated school experience and racial isolation is decreased. The METCO experience demonstrates that although integrated housing is difficult to achieve, both within the city and throughout the suburbs, schools can serve
successfully as agents of diversity and positive change.

Through the METCO Program, both urban and resident students are able to have authentic relationships which ultimately prepare them for the 21st century and the diversity they will encounter in their careers and later in life. Further schools have been a place of safety where both staff and students have been able to learn a more equitable process of sharing the unique aspects that can be found within a diverse environment. These are skills needed for the future that are not always addressed in racially-isolated urban or suburban school districts.

The METCO Program serves as a model for school districts which want to lawfully work toward achieving the compelling interest of deliberately providing diversity within schools, both in the staff and student populations. Desegregation programs such as METCO should be expanded in Massachusetts and replicated throughout the nation by a preference in federal funding.

Sincerely,

Dr. Jean McGuire
Executive Director - METCO, Inc.

Dr. Kahris McLaughlin
Board President - METCO, Inc.

The PACER Center appreciates the opportunity to provide comments on the Race to the Top District competition (RTTT-D). Our comments focus on the need to strengthen parental engagement as part of the competition and ensure that students with disabilities benefit.

Parent and community Input on RTTT-D Applications
We appreciate that applications will be judged on how well stakeholder engagement and support is conducted. However, parent and community engagement has no specified time period for comment as is required for states and cities/towns. The time period required for comments on a district’s application for by states and towns will require specific processes to be established. The RTTT-D document does not list out any criteria around the duration and quality of engagement with parents and community stakeholders. We request that the document provide a specific time period for public comment through multiple opportunities (both in person meetings and electronic communications) for parental engagement.

Ongoing Parental and Community Engagement
As with the lack of specificity on parental engagement during the development of the application, the RTTT-D competition should require ongoing parental engagement during the implementation of the RTTT-D imitative in the district or districts of the grantee. We request that the document make clear that districts hold multiple opportunities for parents to engage on the implementation of the program throughout its period of implementation (both in person and through electronic means).

Eligibility
The receipt of RTTT-D funds should be contingent upon a school district having earned a “Meets Requirements” rating from its state on its latest Annual Performance Report for implementation of IDEA. As one of the goals of the Race to the Top grant program is to improve the achievement and graduation rate of all students, including students with disabilities, those LEAs not currently able to meet the most basic compliance requirements of IDEA should not be eligible to receive funds under RTTT-D. We request that only school districts with a “Meets Requirements” rating on their latest Annual Performance Report be eligible for RTTT-D funding.

Personalized learning plan
While RTTT-D makes no reference to IDEA, the competition should make clear that IEPs are not substitutes for personalized learning plans required under the RTTT-D competition.

My name is Dan McKee. I am Mayor of the town of Cumberland, RI, and Chairman of the Board of Rhode Island Mayoral Academies (RIMA). RIMA works with mayors throughout Rhode Island to open and support highly autonomous, socio-economically diverse, high-performing, regional public schools known as Mayoral Academies.

I have several comments I'd like to make related to the Race to the Top District competition. First, I'll make some big picture comments; then I have some questions on the technical side with the guidance as it's been presented.

First of all, please do not overlook smaller districts. While attention is often focused on our largest urban districts, smaller urban ring districts can implement important, relevant and transferable reforms in policy and practice that dramatically improve the lives of all students. Also, do not overlook consortia of districts that are committed to working together -- especially in cases where collaboration can lead to regional solutions to some of our most vexing problems, like persistent gaps in academic achievement and racially/socioeconomically isolated schools. Mayoral academies, charter schools and districts in our Blackstone Valley region of Rhode Island are working together to prepare all of our students for college and careers -- by trusting data, driving accountability, finding efficiencies and increasing opportunities. It would be meaningful to know that these unique efforts are valued at the federal level. Please ensure that the size of each grant provides the funding required for the funded LEA(s) to realize their plans.

I am highly supportive of USDE's requirement for LEAs to personalize learning and focus on college and career readiness for all students. I support the requirement for evidence of evaluation at all levels, including principal evaluations, superintendent evaluations, and school board evaluations. I support the push for intra-district fiscal transparency, because districts should implement sensible local spending mechanisms that get dollars where they are needed most. I appreciate USDE's requirement for comment from mayors/town administrators on the application; the overall health of our communities directly depends on the quality of our education system. On this last point, I caution USDE’s requirement of signoff from 100% of stakeholders, because sometimes requiring 100% unanimous support can result in 0% change.

Some specific items in the guidance:
Please clarify whether charter schools may apply as a standalone LEA (assuming all other requirements are met) and/or as part of a consortium
Please clarify eligibility for those LEAs that are implementing statewide reforms that are still in development. For example, if the state is building a new data system, and the LEA has committed to utilizing that system once it is ready, would that commitment suffice for the RTT-D requirements?
Is the competition limited to LEAs who have already made measurable/ demonstrable progress over the past four years, as described in B-1(a through c), or rather for LEAs on track to make such progress, or LEAs aspiring to make such reforms in the near future?

Thank you for the opportunity.

For forty-seven years, the METCO program has served to reduce racial isolation in Massachusetts by sending thousands of urban students from Boston and Springfield to suburban school districts. As urban students gain access to a quality education, resident students gain an integrated school experience and racial isolation is decreased. The METCO experience demonstrates that although integrated housing is difficult to achieve, both within the city and throughout the suburbs, schools can serve
successfully as agents of diversity and positive change.

Through the METCO Program, both urban and resident students are able to have authentic relationships which ultimately prepare them for the 21st century and the diversity they will encounter in their careers and later in life. Further schools have been a place of safety where both staff and students have been able to learn a more equitable process of sharing the unique aspects that can be found within a diverse environment. These are skills needed for the future that are not always addressed in racially-isolated urban or suburban school districts.

The METCO Program serves as a model for school districts which want to lawfully work toward achieving the compelling interest of deliberately providing diversity within schools, both in the staff and student populations. Desegregation programs such as METCO should be expanded in Massachusetts and replicated throughout the nation by a preference in federal funding.

Dr. Jean McGuire
Executive Director, METCO, Inc.

Dr. Kahris McLaughlin
Board President, METCO, Inc.

Comments and Questions on RTT-District
From the Washoe County School District, Nevada

Questions - further clarification requested:
1. “A school board evaluation.” Question to US DOE: For those LEAs with elected boards, would the fact of being elected suffice as evidence of evaluation?

2. “…the ability to match level P-12 and higher education data.” Question to DOE: When does the data system have to be in place?

3. Please provide clarification on requirements around personalized plans.

4. Why “four” years of a track record of improvement? Will districts that have made substantive gains in three years be “penalized” vs. four years of improvement? Rapid improvement turnaround style vs. a modicum of change over four or more years.

5. Section Criteria Section C Point 4. Performance Management: how will local measures be assured to be as rigorous from district to district and state to state. Please provide a clear definition on “rigorous, relevant, and actionable performance measures.”

6. Can a RTTT State/District partner with a district in a non-RTTT state?

Comments:
1. Flexibility is requested for the 21st century learning infrastructure.

2. Performance Management: Clear metrics are needed around performance management.

3. MOU/MOA sign offs from associations, city and local groups will leave some districts out of applying. Consider making these requirements a Competitive Priority.

4. A significant barrier on this application is matching data sets to students and teachers PK through higher education.

5. Funding Structure: Suggest removal of F. Optional Budget Supplement and add funds to overall “pot” of monies available. The funding scale does not provide any incentive to serve larger number of students. The intent of the grant is to serve the largest amount of students and so the funding scale needs to be more reflective of that. There is only a $5 million difference if we serve 40,000 students (eligible for $20-$25 million) vs. if we serve 5,000 students (eligible for $15-$20 million).

6. Of particular interest:
a. The lack of significant emphasis on technology within the document may limit the number of grants for personalization initiatives with significant technology components.
b. The relatively onerous requirements and very ambitious timelines around establishing and implementing evaluations for all levels of a district’s educational system may eliminate a number of potential applicants.
c. The threshold data requirements, which involve student identifiers and matching capabilities, may cut out entire states.
d. The requirements regarding districts disclosing financial data, including personnel salaries, may prevent districts from being able to gain support for their applications from teachers, something that the application also mandates.

I am pleased to submit these comments/recommendations related to the 'Race to the Top' – District competition on behalf of The International Association for K-12 Online Learning (iNACOL) and its more than 4,200 members.

It is good to see the Department direct its focus to educational innovation through personalized learning in this latest proposed round of the 'Race to the Top' initiative.

While a positive step at its core, the guidelines for the district-level competition suffer from the same vague language that plagued earlier aspects of RTT. Namely, there remains too much wiggle room for LEAs to make promises that can be blocked from effective implementation by policies and legislation beyond their control.

As we have witnessed for decades with existing legislation in place governing our public schools, a lack of precise language can result in an unintended relaxation of execution.

It is in this spirit that I outline here some specific items with the aim to strengthen the very positive intentions of the competition.

ABSOLUTE PRIORITIES:

Absolute Priority 1, Personalized Learning Environment(s):
A truly personalized learning environment is one that utilizes competency education or mastery-based learning practices to ensure no student progresses in their academic journey without first showing mastery of a concept. This was showcased during your RTT-D kickoff event, but would benefit from including the defining work of CompetencyWorks (www.competencyworks.org). To further this, I outline here five key elements of any personalized, competency-based learning program:
1. Students advance upon mastery.
2. Competencies include explicit, measurable, transferable learning objectives that empower students.
3. Assessment is meaningful and a positive learning experience for students.
4. Students receive timely, differentiated support based on their individual learning needs.
5. Learning outcomes emphasize competencies that include application and creation of knowledge, along with the development of important skills and dispositions.

Absolute Priority 2, LEAs in Race to the Top States: An LEA or a consortium of LEAs where more than 50 percent of participating students (as defined in this document) are in LEAs in States that received awards under the Race to the Top Phase 1, Phase 2, or Phase 3 competitions.

Absolute Priority 3, Rural LEAs in Race to the Top States: An LEA or a consortium of LEAs where more than 50 percent of participating students are in rural LEAs (as defined in the document) in States that received awards under the Race to the Top Phase 1, Phase 2, or Phase 3 competitions.

Absolute Priority 4, LEAs in non-Race to the Top States: An LEA or a consortium of LEAs
where more than 50 percent of participating students are in LEAs in States that did not receive awards under the Race to the Top Phase 1, Phase 2, or Phase 3 competitions.

Absolute Priority 5, Rural LEAs in non-Race to the Top States: An LEA or a consortium of
LEAs where more than 50 percent of participating students are in rural LEAs (as defined in the document) in States that did not receive awards under the Race to the Top Phase 1, Phase 2, or Phase 3.

Comments on Absolute Priorities 2-4: There are some states that are further ahead in innovating on personalized learning, such as New Hampshire and Maine, where districts and schools from the ground up are focused on competency education. Districts pioneering online learning, blended learning and competency education (in some respects already “out innovating” the LEAs in States that received awards in prior competitions) should be eligible and rewarded for embarking on innovative practices -- and preferences should be given to them to support scaling and resources to grow and lead further innovation in the field. These may include districts implementing blended learning, personalized learning with customized, competency education or virtual schools that are LEAs.

Focus on Online and Blended Learning:

Blended and online learning should be highlighted and included as a strategy for personalization and accelerating student learning The definition of blended learning is: a formal education program in which a student learns at least in part through online delivery of content and instruction with at least some element of student control over time, place, path and/or pace; and, at least in part in a supervised brick and mortar location away from home (Horn and Staker, 2012).

DEFINITIONS:

Digital learning content:
The Department's definition of “digital learning content” barely moves beyond a PDF. iNACOL would like to push for a more innovative definition of digital content under the “if learning cannot be gauged, learning cannot be claimed” mantra. True digital content is not a conversion, but created natively for the medium with built in formative assessment to ensure mastery, and data collection to inform teachers of progress and/or need. There should be a focus on outcomes data to measure performance in next generation digital content.

Learning materials, professional development resources and other educational resources made possible with these grants and developed with public dollars should be given a priority for open licensing for sharing, collaborating across schools and districts and accessibility.

Definition of mastery: In Policy and Infrastructure there is reference to mastery, specifically, the extent to which LEA’s enable personalized learning through the opportunity for students to progress and earn credit based on demonstrated mastery; and, the opportunity for students to demonstrate mastery of standards at multiple times and in multiple comparable ways.
Mastery needs to be included in the section on definitions emphasizing explicit and measurable competencies.

Personalized learning plan:
The Department's definition portrays a fixed document outlining a student's trajectory. A personalized learning plan should allow student agency to choose content, applications or learning environments to show mastery along trajectories –consistent with state standards frameworks for college and career ready skills, knowledge and dispositions. A personalized learning plan supports multiple “systems of assessments” including adaptive assessments to highlight mastery, e-portfolios, performance-based assessments, formative assessments, moderating assessments that validate assessments from the ground “up”. A true personalized learning plan is a flexible plan that allows a student some choice in how they learn, what pace they learn and that adapts to a student's progress as they master content – with assessment for validating and demonstrating learning.

Student attendance:
The section on student attendance is inputs focused, and a relic of the factory model of batching students, rather than student learning outcomes focused for next generation models of learning. This section is problematic as it validates old models of relying on seat time as a measure or form of progress. Student progress should be measured on proficient learning and demonstrating mastery, not time.

Graduation rate:
This section on graduation rates focuses on an arbitrary measurement based on time, not mastery or accomplishment.

On a final note, to see that blended, digital and online learning practices are defined throughout the initial guidelines without being explicitly identified in association with those terms, indicates a missed opportunity. For years, innovative districts from California to Kentucky have implemented inspired online and blended learning programs and competency education models that break the one-size-fits-all mentality and harness the individual learning needs and speeds of their students regardless of background. At their core, they are redefining traditional terms such as “teacher”, “classroom”, “progress”, and “school” for millions of children (and adults). These new learning models should be held up as examples of what a district (or school) can accomplish when a student-centered approach initiates a student-focused process and outcome. Only then will our schools be able to say that they are preparing each and every child for college and/or a career.

Susan Patrick
President & CEO
iNACOL (International Association for K-12 Online Learning)

My name is Dan McKee. I am Mayor of the town of Cumberland, RI, and Chairman of the Board of Rhode Island Mayoral Academies (RIMA). RIMA works with mayors throughout Rhode Island to open and support highly autonomous, socio-economically diverse, high-performing, regional public schools known as Mayoral Academies.

I have several comments I'd like to make related to the Race to the Top District competition. First, I'll make some big picture comments; then I have some questions on the technical side with the guidance as it's been presented.

First of all, please do not overlook smaller districts. While attention is often focused on our largest urban districts, smaller urban ring districts can implement important, relevant and transferable reforms in policy and practice that dramatically improve the lives of all students. Also, do not overlook consortia of districts that are committed to working together -- especially in cases where collaboration can lead to regional solutions to some of our most vexing problems, like persistent gaps in academic achievement and racially/socioeconomically isolated schools. Mayoral academies, charter schools and districts in our Blackstone Valley region of Rhode Island are working together to prepare all of our students for college and careers -- by trusting data, driving accountability, finding efficiencies and increasing opportunities. It would be meaningful to know that these unique efforts are valued at the federal level. Please ensure that the size of each grant provides the funding required for the funded LEA(s) to realize their plans.

I am highly supportive of USDE's requirement for LEAs to personalize learning and focus on college and career readiness for all students. I support the requirement for evidence of evaluation at all levels, including principal evaluations, superintendent evaluations, and school board evaluations. I support the push for intra-district fiscal transparency, because districts should implement sensible local spending mechanisms that get dollars where they are needed most. I appreciate USDE's requirement for comment from mayors/town administrators on the application; the overall health of our communities directly depends on the quality of our education system. On this last point, I caution USDE’s requirement of signoff from 100% of stakeholders, because sometimes requiring 100% unanimous support can result in 0% change.

Some specific items in the guidance:
Please clarify whether charter schools may apply as a standalone LEA (assuming all other requirements are met) and/or as part of a consortium
Please clarify eligibility for those LEAs that are implementing statewide reforms that are still in development. For example, if the state is building a new data system, and the LEA has committed to utilizing that system once it is ready, would that commitment suffice for the RTT-D requirements?
Is the competition limited to LEAs who have already made measurable/ demonstrable progress over the past four years, as described in B-1(a through c), or rather for LEAs on track to make such progress, or LEAs aspiring to make such reforms in the near future?

Thank you for this opportunity.

Dear Department of Education,

Every morning when I wake up, I thank the good Lord for blessing me with a new day.

When I was overweight, it was so easy to give in to my temptations to eat whatever I wanted, whenever I wanted. It was so easy to not even think about exercise, let alone taking the time to actually do some exercise. Easy, yes. But, for my health, it was costly, too!

So today, what motivates me to exercise? I like the self-confidence those daily workouts give me. I like going in for my annual physical and getting a five-star report from my doctor about what great shape I'm in.

Good health, high self-esteem, and the energy and focus to do our best.......come from being fit and living healthy.

My dream, and mission is for EVERY AMERICAN SCHOOL AGED CHILD to have the chance to learn about how to achieve those very qualities.

Until PE, Health and Physical Activity are a part of the regular curriculum, please consider including them in the Race to the Top District criteria.

Respectfully,
Richard Simmons, Los Angeles, California

My name is Dan McKee. I am Mayor of the town of Cumberland, RI, and Chairman of the Board of Rhode Island Mayoral Academies (RIMA). RIMA works with mayors throughout Rhode Island to open and support highly autonomous, socio-economically diverse, high-performing, regional public schools known as Mayoral Academies.

I have several comments I'd like to make related to the Race to the Top District competition. First, I'll make some big picture comments; then I have some questions on the technical side with the guidance as it's been presented.

First of all, please do not overlook smaller districts. While attention is often focused on our largest urban districts, smaller urban ring districts can implement important, relevant and transferable reforms in policy and practice that dramatically improve the lives of all students. Also, do not overlook consortia of districts that are committed to working together -- especially in cases where collaboration can lead to regional solutions to some of our most vexing problems, like persistent gaps in academic achievement and racially/socioeconomically isolated schools. Mayoral academies, charter schools and districts in our Blackstone Valley region of Rhode Island are working together to prepare all of our students for college and careers -- by trusting data, driving accountability, finding efficiencies and increasing opportunities. It would be meaningful to know that these unique efforts are valued at the federal level. Please ensure that the size of each grant provides the funding required for the funded LEA(s) to realize their plans.

I am highly supportive of USDE's requirement for LEAs to personalize learning and focus on college and career readiness for all students. I support the requirement for evidence of evaluation at all levels, including principal evaluations, superintendent evaluations, and school board evaluations. I support the push for intra-district fiscal transparency, because districts should implement sensible local spending mechanisms that get dollars where they are needed most. I appreciate USDE's requirement for comment from mayors/town administrators on the application; the overall health of our communities directly depends on the quality of our education system. On this last point, I caution USDE’s requirement of signoff from 100% of stakeholders, because sometimes requiring 100% unanimous support can result in 0% change.

Some specific items in the guidance:
Please clarify whether charter schools may apply as a standalone LEA (assuming all other requirements are met) and/or as part of a consortium
Please clarify eligibility for those LEAs that are implementing statewide reforms that are still in development. For example, if the state is building a new data system, and the LEA has committed to utilizing that system once it is ready, would that commitment suffice for the RTT-D requirements?
Is the competition limited to LEAs who have already made measurable/ demonstrable progress over the past four years, as described in B-1(a through c), or rather for LEAs on track to make such progress, or LEAs aspiring to make such reforms in the near future?
Thank you for the opportunity.

From: Nemours
To: U.S. Department of Education
Re: Race to the Top – District (RTT-D) Competition
Date: June 8, 2012

Nemours would like to thank you for this opportunity to comment on the RTT-D Competition. We also commend you for announcing that a new round of the Race to the Top – Early Learning Challenge (RTT-ELC) is forthcoming. As one of the nation’s leading child health systems, Nemours is dedicated to achieving higher standards in children’s health by offering a spectrum of clinical treatment, research, advocacy, education, and community-based prevention initiatives extending to families in the communities it serves.

In seeking to improve the health of our nation’s children, Nemours recognizes the importance of taking an integrative approach – which includes, but is not limited to, increased access to quality early learning programs and healthy eating and physical activity. Both go hand-and-hand in the healthy development of our nation’s children.

As the Department works to finalize the competition’s design, we recommend the following:

• Early Learning:

o We commend the Department for recognizing the role of early learning programs by referencing partnerships with early learning programs as a factor that the Department will consider when awarding preference points. Nemours highly encourages the Department to require that all applicants include an early learning component. Alternatively, we encourage the Department to give preference to all applicants that include partnerships with early learning programs. These partnerships should include investments in evidence-based early learning programs, as well as investments in strengthening training and technical assistance for child care educators and teachers to better promote health and wellness The early years are critical to a child’s development, and the improvements that the RTT-D competition will help spur in elementary and secondary schools must build upon a strong foundation in the early learning environment. The transition from early learning to kindergarten is formative in the development of a child, and a comprehensive, holistic approach to learning, from birth through grade 12, is critical.

o In addition, we ask that the Department give preference to proposals that address early literacy. Reading ability is the strongest individual predictor of adult health status. Currently, reading failure affects 30 percent or more of our nation’s children, making it a major child health issue that RTT-D could help address.

•Addressing the needs of diverse learners:

o In section C, “Preparing Students for College and Careers,”#2 a ii (page 7), in line 2 strike “and,” and after “students;” add “and the characteristics and needs of diverse, at-risk learners;” Teachers sometimes make erroneous assumptions that students with diverse learning needs cannot learn in the mainstream classroom, and do not see themselves as capable of effectively teaching them. When these needs are specifically addressed through training, teachers can change their belief systems about diverse learners and themselves, which is critical to effective instruction for all children. This teacher development provision in Section C, #2 should go beyond the college-and career-ready graduation requirement (as defined in the document) and include an early learning component since cognitive development starts before kindergarten.

• Health, including Healthy Eating and Physical Activity:

o We commend the Department for referencing health and social-emotional competencies in the competitive preference priority section. However, we are concerned that the emphasis on a child’s overall healthy development is not integrated throughout the entire funding announcement. Healthy eating and physical activity are critical to a child’s healthy development, and schools are an important setting for promoting healthy habits. RTT-D should encourage applicants to include professional development, parental engagement strategies and innovative curricula focusing on health, physical activity and physical education, plus social-emotional supports. Our specific suggestions for incorporating a stronger focus on health include the following:

 Since student health is tied so closely to student academic performance and behavior, we recommend including “student health standards and assessments” in the four core educational assurance areas (pg. 15-16) that are the basis for Absolute Priority #1. Additionally, we recommend revising the core educational assurance area regarding building data systems by adding “health” as one of the dimensions measured. Ultimately, we believe that in order to turn around a school with complex issues, we need to develop complex solutions – especially holistic approaches that include parental engagement and recognize the connection between academics and health. We commend Secretary Duncan for recognizing this link, as referenced in a May 16th Education Week article where he stated that there is compelling academic research making the connection between academic achievement and students’ well-being.

 In Section B, “District Capacity and Success Factors,” #3 b (page 5), add public health and health care providers to the suggestions listed for letters of support to encourage applicants to work with health partners when developing their applications.

 In Section C, “Preparing Students for College and Careers,” (page 6), specify that applicants’ plans should enable all students to graduate college-and career-ready and healthy.

 In Section C, #2 b “Teaching”(page 8), in part ii, after “that are aligned with college- and career-ready standards (as defined in the document)” add “and are designed to improve health, including healthy eating and physical activity”. Also, add a new part iv, which states the following, “High-quality professional development, learning resources and parental engagement strategies focusing on optimizing students’ healthy development, including strategies and curricula focusing on healthy eating and physical activity.”

 Nemours believes that healthy development should be infused in the plan to support Absolute Priority #1 and specifically addressed in the sections described above. Alternatively, at the very least, the “Competitive Preference Priority” section on page 12 should include a stronger focus on optimizing healthy development, including through addressing social-emotional competencies and through specifically addressing healthy eating and physical activity. Our suggestions include: give preference to all applicants that include strategies to improve overall health, including healthy eating and social-emotional competencies, as well as the socio-economic needs and program support focused on the comprehensive health and mental health needs of children.

 Give preference to applicants that incorporate a strong focus on physical activity and physical education. Nemours worked with the Delaware Department of Education on a study that shows a clear and consistent relationship between fitness and academic achievement as well as fitness and student behavior, regardless of a student’s gender, race, family income, or school district. The study, which analyzed records of more than 80,064 students in Delaware, indicates that students who are more physically fit perform significantly better in both reading and math, and the difference in school days missed between least fit and most fit is 30 days. Further, students who are less physically fit exhibit significantly lower scores in these subjects and also have more suspension days and absenteeism. These findings are consistent with a number of research studies suggesting a link between physical activity, student behavior, and academic achievement. Studies have shown that physical activity is linked to better concentration, reduced disruptive behaviors, and higher test scores in reading, math, and writing. With this in mind, RTT-D should include a stronger focus on physical activity.

 Give preference to plans that incorporate health education skill building around improving health literacy and skill building for healthy living as referenced in IOM’s May 8th report titled, Accelerating Progress in Obesity Prevention: Solving the Weight of the Nation. Programs that focus on increased training for teachers and staff in nutrition and physical activity should be strongly support by the Department.

• Parental engagement:

o We recommend that the Department give preference to proposals including parental engagement strategies. Parental involvement is crucial to healthy child development, and detailed parental engagement strategies should be included in application components addressing the early learning, primary and secondary school environments.

• Coordinated efforts, including data integration:

o We applaud the Department for including a reference to interoperable data systems as a sub-component of the Policy and Infrastructure section on page 9. We suggest that the Department provide preference to applicants that work to share data across systems in different sectors. For example, in Delaware, Nemours developed a multi-disciplinary team that designed an authorization form to obtain consent from parents/caregivers to allow school nurses to view the medical records of students under their care and to reinforce that school nurses are a part of the care team. A contract between the school district and Nemours will soon allow school nurses to have access to the medical records of students seen by Nemours providers. The project is in the pilot phase and will be expanded. RTT-D could help expand these types of innovative partnerships between schools, early learning providers, health systems and other relevant sectors.

o We commend the Department for providing preference for plans that include a “coherent and sustainable partnership.” On sub-section 1 of page 12, we ask that the Department give preference to applicants that include a specific coordinated effort between DOE, Public Health, child health providers, and Services for Children, Youth and their Families that begin from cradle to graduation – that is both integrated with the community and primary care environments for every child.

We encourage the Department to make every attempt to emphasize the importance of incorporating strategies to address health and early learning into RTT-D applications. By integrating a focus on health into the early learning and school settings, we support healthy environments for students to learn, grow and thrive. Thank you again for the opportunity to provide comments. If you have any questions on our comments, please contact Daniella Gratale, Manager of Advocacy, at dgratale@nemours.org.

Sincerely,

Debbie I. Chang, MPH, Vice President, Nemours, Policy and Prevention

Laura Bailet, PH.D., Executive Director, Nemours BrightStart!

Mary Kate Mouser, MEd, Executive Director, Nemours Health & Prevention Services

Thank you for this opportunity to comment on proposed criteria for the Race to the Top District (RTT-D) competition. We appreciate that the proposed criteria emphasize personalized, individualized learning experiences. We also appreciate that the proposed criteria acknowledge the importance of strong early childhood experiences for young children by addressing early care and education programs that help children enter school ready to succeed. In addition, it is heartening to see that the proposed criteria call for the engagement of key community stakeholders, including families and early childhood providers, who are so essential to children’s success.

Given the particular needs of young children in both the preschool and the early elementary years, we would recommend that the RTT-D competition criteria be very clear to differentiate the preschool and early grades from later grades in order to ensure appropriate teaching practices and appropriate evaluation and assessment strategies for young children. Districts and schools applying for RTT-D funds should be asked to provide assurances that their child assessments for children in third grade and younger will conform with the recommendations of the National Academies of Sciences report on child assessment and will be used to improve teaching practices and tailor curricula for children and not for high-stakes personnel decisions. In addition, districts and schools should be required to use a comprehensive curriculum for children in third grade and younger that addresses the children’s cognitive development, social and emotional development, physical development, and approaches to learning.

While we appreciate that the proposed RTT-D criteria encourage districts to involve community partners, we recommend several revisions to the criteria that would foster stronger outreach to these key stakeholders, including early learning providers. We recommend that the criteria clarify that parents and neighborhood groups should not only be involved in the development of the district’s proposal under Absolute Priorities, but also in the public-private partnership described in the Competitive Preference Priority. In addition, we recommend that the partnership be asked to demonstrate how it will enable the integration of services for participating students as well as for their families (Competitive Preference Priority (3)). Finally, we recommend that the partnership be asked to demonstrate how it will build the capacity of staff in both participating schools and community stakeholders (Competitive Preference Priority (4)).

Thank you once again. We greatly appreciate your efforts to address early learning as part of education reform through the RTT-Early Learning Challenge and as an optional strategy through this new competition.

Sincerely,
Helen Blank and Karen Schulman
National Women’s Law Center

The Stupski Foundation is pleased to have the opportunity to provide input on the Education Department’s Race to the Top competition for districts (RTT-D). We applaud the focus on creating personalized learning environments that equip and empower all students to take ownership of their education and graduate high school ready for success in college and career. We also support the emphasis on building professional communities that can craft these learning opportunities and engage in rigorous continuous improvement, as well as the supplemental opportunity for districts to develop public / private partnerships to support students’ social-emotional development and general health and well-being.

We would like to provide substantive feedback and suggestions for the Department’s consideration in its upcoming revision of the guidelines. Specifically, we suggest the Department:

Clarify key concepts

  1. Personalized learning: Provide additional detail on what the Department means by “personalized learning environments”, examples of what this looks like in schools and classrooms, measurable indicators of personalization, and how personalization leads to the desired outcomes. Personalization is a means to an end of great outcomes for students. Districts should be expected to describe the concrete steps they would take to support teachers in collaboratively creating personalized learning plans and effectively planning and delivering differentiated instruction for each student that takes into account their needs, interests, preferences, and goals. It may be that LEAs and consortia need a certain period of planning time to do work that is truly transformative. We also believe that the guidelines should call out a critical teaching practice that mediates the impact of personalized learning: the practice of communicating to each student high expectations and personal assurances that they have the capacity to succeed, coupled with the provision of rigorous, actionable feedback. This will “make or break” the impact of personalization.
  2. Student-centered learning environments: Provide greater clarity about what the Department considers the features of “student-centered learning environments” and their relationship to the “personalization of strategies, tools, and supports for teachers and students”. Our experience suggests that personalized learning opportunities are not always student-centered and we should be certain that they take into account both academic and social and emotional supports.

Encourage districts to truly transform the roles of students and teachers

  1. While the guidelines indicate that selection criteria consider the extent to which “families, teachers, and principals” have been engaged in the development and revision of the proposal, we strongly suggest including students as part of the core proposal development team to ensure their unique expertise and experience is reflected in the design of the project. Students and teachers should also be involved on district-wide committees designed to monitor progress and course-correct during the implementation of the grant.
  2. In section (a) under “Learning” on page 6, we recommend including an element about students being supported to exercise increasing, developmentally appropriate choice and autonomy in directing and taking responsibility for their learning. This has been shown to increase motivation and engagement in learning activities.

Request greater detail on plans for continuous improvement

  1. We think it may be useful to ask districts to identify a specific methodology (e.g., the “Model for Improvement” used in healthcare and a growing number of education settings) that they would employ in professional learning communities to promote continuous improvement. Schools and districts are generally not accustomed to processes of continuous improvement. They often have had the experience of trying something new, often serially trying new things, and not having a way to understand whether or not it led to the outcomes sought. They also rarely have the time or support to collect, analyze, and interpret data that would allow for continuous improvement in classrooms, schools, and districts. Given this situation, the applicants should also specify how they plan to build the capacity of educators, many of whom have not been trained in data collection, analysis, or interpretation, to engage in robust continuous improvement.

Make the equity elements of the guidelines more robust

  1. In addition to looking at district-wide disparities in discipline rates according to the CRDC, we recommend exploring whether individual schools that would be participating in the RTT-D activities have high discipline rates overall, since schools that are racially segregated would not reveal racial/ethnic disparities, but may still have excessively high rates of disciplinary action.
  2. We believe districts should be required to provide an explanation of how they will avoid defaulting into a tracked system under a personalized model that emphasizes mastery and students “studying and advancing at their own pace.”
  3. We think the Department should ensure that the attendance data include chronic absenteeism, i.e., being absent 10% or more days out of the academic year, in addition to overall attendance rates.

Change the funding structure to put small and large LEAs and consortia on an equal footing

  1. The size of the grants can be disproportionately skewed toward small districts and at the same time exclude extremely small and rural places from consideration. We encourage the Department to consider granting consistent funding per student and weighting this per-student funding to address student needs in the district.

Thank you for the opportunity to provide input on this very exciting opportunity for districts and schools to provide every child with the education they deserve.

Innovative and bold programming needs to include some skill development in how to engage in dialogue around social and cultural difference. Dialogue in our country is shaped by social and political agendas. Future active citizens will need to learn how to critically analyze and discern the underlying messages sent by those agendas. These citizens need to be able to engage in dialogue with those who think differently from them. To make our democracy work, elementary and secondary education programs need to teach students how to think and manage vastly different opinions so that they might be able to consider views outside of their own or the ones that they are hearing most often---and to be able to distinguish black/white views presented in 30 second news stories and already digested information spit back out at them by news pundits.

Innovative and bold programming along these lines will require that teachers have training that helps them to nurture the capacity to engage in difficult dialogues. And most importantly, they will need to know how to dissect the packaged material they receive in curriculums that provides standard information that perpetuates stereotypes and other messages traditionally heard around difference as it relates to how power and privilege plays out within a society.

Avoiding directly addressing diversity as a way of being in the world is limiting our students and inhibiting the ways we might move forward as a society. You may not just assume that diversity matters are going to be addressed because ‘everybody’s work is really nobody’s work’. In other words, if the Department of Education does not directly ask for this as a criterion, then the message that it is not a priority will be received and schools will continue on a path that does not serve students well. I teach undergraduate students in courses that raise their social and political consciousness and teach them how to critically analyze and effectively engage in discussions around difference. Many of them express regrets and frustration that these courses are of the first opportunities they have had to engage in this way around diversity. These college students have expressed anger toward their elementary and secondary educational experiences because they were not taught this earlier and they feel blindsided. Innovative and bold programming must include a direct call to action around diversity and how to engage in dialogue around difference.

June 8, 2012

Honorable Arne Duncan
Secretary of Education
U.S. Department of Education
Washington, D.C. 20201

Re: Comments on Race to the Top-District draft executive summary

Dear Secretary Duncan:

We, a collection of innovative and entrepreneurial education organizations with an interest in personalized learning, enthusiastically offer our support for the latest Race to the Top-District competition. The following comments are offered in hopes of improving on this critical effort to foster approaches to personalize learning and tailor instruction to the academic needs, interests, and learning styles of students – particularly those from low-income communities – to prepare them for success in college and careers.

While we applaud the Department for urging school districts to foster personalized learning environments, we worry that the competition as currently conceived may not maximize return on our $400 million federal investment. Our collective concern is that the competition is designed to reward districts that draft comprehensive personalized learning applications that may prove extraordinarily difficult to implement. We therefore focus our comments on four main areas where we feel the competition can be made more flexible, precise and effective:

  • Add an outcomes-based “toolbox” option to the competition that will allow educators to experiment and prototype personalized learning services and tools
  • Ensure LEAs and consortiums of LEAs can partner with nonprofit organizations to provide critical capacity to implement and scale personalized learning solutions
  • Place greater emphasis on applicants partnering with effective educator-training programs that can prepare school leaders and teachers to serve in personalized learning environments
  • Clarify the eligibility requirements specific to public charter schools, charter management organizations, and recovery districts

We conclude with a series of additional suggestions and comments related to other aspects of the RTT-D competition.

Add a flexible, outcomes-based “toolbox” option to the competition that will allow educators in the classroom to experiment and prototype different personalized learning services and tools

We strongly support RTT-D’s emphasis on providing LEAs and consortiums with great flexibility in designing personalized learning environments, whether across schools, grade levels, or subject areas. And yet, we believe that this flexibility should be taken even further to ensure the organic growth of digital technology services and tools that we believe hold unique promise for creating and fostering true personalized learning environments.

To that end, we urge a simplified yet rigorous competition designed to create personalized learning “toolboxes” that would be made available by districts (and consortiums) to educators via a common platform. Educators within such districts would then decide for themselves whether to personalize instruction in their school or classroom. Under this toolbox approach:

  1. The LEA or consortium first selects a set of personalized learning products and negotiates provisional contracts with vendors on a sliding, “as used” basis. The vendors will receive only partial payment upfront; the bulk of the contract funding is released if, and only if, the tools selected (a) are widely adopted by educators, and (b) are shown to significantly improve student achievement.
  2. The personalized learning toolbox is made available to school leaders and teachers through a central, interoperable data platform that will be managed by the district or consortium lead.
  3. School leaders and educators may then voluntarily select tools from the toolbox and use according to their needs. Importantly, because of the “as used” performance-based contracts, personalized learning providers will have the incentive to improve their products to meet the actual preferences of the end user (i.e., teachers, students, and parents). The typical arms-length, single-point-of-sale contract is thus replaced with an ongoing, collaborative relationship between user and supplier that is the hallmark of true innovation.
  4. At the end of the grant period, the consortium or LEA will release remaining funds to those providers who have gained real traction in adoption and improved student learning. The Department in turn can compare effectiveness across grant recipients and evaluate which tools and services, based on the data, are high-quality.

The advantages of this approach are significant:

  • The Department would evaluate an applicant’s plan for (a) creating a common and open platform; (b) selecting tools for the toolbox; and (c) designing promising performance-based contracts. On this latter point in particular, applicants could be judged based on their creativity creating challenges, prizes and milestone-based “pay for success” payment structures, aligning the competition with two recent OMB memos on prizes and challenges.
  • Personalized learning strategies and tools will be implemented voluntarily and from the ground up, thus ensuring critical educator buy-in (and alleviating the need for institutional stakeholder support).
  • This option would be uniquely favorable to rural districts that may not have the central office capacity to design comprehensive personalized learning plans, but could form a consortium to support a single personalized-learning provider platform.
  • Personalized learning providers will have powerful incentive to ensure that actual needs of educators, as revealed through on-the-ground implementation, are consistently assessed and met – and, if those needs aren’t being satisfied, to revise and improve their services and products.
  • For consortiums, this flexible approach eliminates the need for massive, complex coordination among the central offices of multiple LEAs.
  • Teachers will be empowered to make and revise choices about the use of personalized learning tools in the classroom, fostering a true culture of innovation within the public school system.

In our view, awarding (at a minimum) 20% of the RTT-D competition funds in this manner will yield truly transformative innovations and provide a powerful social return on investment.

Expand opportunity for LEAs and consortiums of LEAs to partner with nonprofit organizations to provide critical capacity to scale high-quality personalized learning solutions

We believe personalized learning is a particularly promising strategy for consortiums of school districts, especially those in rural areas. Among other things, consortiums can create of common data platforms, provide a single entry point for procurement, and promote collaboration across districts of varying size and student demographics. At the same time, the task of requiring districts both to develop a personalized learning plan while also crafting a new governance model is extremely daunting. To achieve the latter, we believe it is critical that LEAs and consortiums can partner with outside entities to provide the capacity needed to govern and implement personalized learning. We specifically urge that:

  • LEAs and consortiums may partner with nonprofit organizations, including intermediary organizations, to assist in implementing an applicant’s plan to create personalized learning environments.
  • Partnership organizations may use grant funds for purposes of seeding new personalized learning solutions, scaling capacity of existing high-quality personalized learning solutions, and coordinating and developing a comprehensive personalized learning strategy across member districts.
  • The competitive preference priority identifies “nonprofit intermediaries” in the list of organizations that applicants may partner with.

Barring adoption of these suggestions, we urge that nonprofits and intermediary organizations be explicitly made eligible to receive subgrants from winning RTT-D applicants.

Place greater emphasis on LEAs and consortium of LEAs partnering with performance-based educator-training programs to train teachers and school leaders on strategies, tools and supports to personalize learning

We believe the teacher and leader training component of the RTT-D competition is underdeveloped. Although the draft rules outline the type of training that educators should undergo to successfully transition to personalized learning for students, there is no specific guidance or priority for preservice training or partnerships that school districts (and consortiums) might form with institutions of higher education or alternative-certification providers.

We therefore urge you to consider prioritizing RTT-D applicants who agree to partner with and support performance-based educator training programs, such as (for example) Relay Graduate School of Education, the Urban Teacher Center, and the teacher residency models typified by members of the Urban Teacher Residency United. By “performance based” we mean programs that explicitly condition graduation, certification or licensure upon a teacher or leader candidate successfully demonstrating the ability to improve student achievement. These types of programs are particularly well-suited to train educators for personalized learning environments because they are highly data driven, and frequently measure student progress toward meeting learning goals.

Clarify the eligibility requirements specific to public charter schools, charter management organizations (CMOs), and recovery districts

We are particularly enthusiastic that, for the first time, charter schools and CMOs will be eligible to directly apply for Race to the Top funds. We have four suggestions to help ensure the Department receives high-quality applications from the charter sector.

First, CMOs should be explicitly eligible to apply either as LEAs (in cases where there is one charter and multiple campuses) or as a consortium (in cases where a CMOs has contracts to manage multiple legally distinct charter schools). Consistent with our comment above, charter districts and CMOs should be eligible to partner with nonprofit third-party operators to provide additional capacity and manage governance issues.

Second, it is unclear as to what would constitute evidence of 70% teacher support for an application from an LEA with no collective bargaining agreement. We suggest making the evidentiary threshold lower and easy to satisfy (e.g., through use of a simple online survey administered by the LEA).

Third, to the extent high-performing CMOs and charter school consortia are eligible, we suggest an alternative to the requirement (and core educational assurance) regarding turnaround strategies, since by definition high-performing charter applicants should not be operating such schools. Instead, we suggest prioritizing charter and CMO applicants that can demonstrate growth in districts with large numbers of low-performing schools or those that agree to take over (restart) low-performing schools currently run by school districts or other charter operators.

Finally, and relatedly, state-run takeover districts (e.g., Louisiana’s Recovery School District, Tennessee’s Achievement School District, Connecticut’s Commissioner’s Network, and the Detroit Recovery District) should be explicitly included as eligible applicants.

Other Recommendations

  • Given the challenges of developing robust data systems with teacher-student matches (to say nothing of connecting P-12 with higher education data systems), we encourage the Department to be flexible in interpreting this requirement and recognize creative solutions that address it.
  • It would be helpful to clarify how the Department will calculate “participating students” from “participating schools,” given that the competition allows districts and schools to choose to focus on specific grade spans or subject areas.
  • In our view, defining “personalized learning plan” as a “formal document” that sets forth a comprehensive set of goals and sequences to achieve those goals runs the risk of creating another layer of bureaucracy for educators to navigate. A more fluid definition that allows for greater flexibility is more likely to foster innovation.
  • For applicants that plan to use technology to support personalized learning, we urge the Department to prioritize schools that already have, or plan to install, the proper bandwidth and technology infrastructure. In our experience schools need 50-100Mbps of Internet capability to implement blended, personalized instruction models.
  • We believe the competition should contain incentives to create personalized learning environments that make data open and available to parents and students in standardized, easy-to-understand formats, thereby enabling them to make informed decision about their personalized learning plans.
  • The Department should prioritize applicants that have well-thought out plans for ensuring school facilities can accommodate personalized learning environments.

On behalf of the education innovation and entrepreneurial community, we thank you for your attention to these comments.

NewSchools Venture Fund
Alliance for College-Ready Public Schools
Digital Promise
Education Elements
eSpark
Goalbook
LearnZillion
Mastery Connect
Matchbook Learning
National Alliance for Public Charter Schools
National Center for Alternative Certification
National Center for Education Information
Presence Learning
Scholars Academies
Silicon Schools Fund
Tom Vander Ark
Unlocking Potential

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.

KnowledgeWorks 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 KnowledgeWorks, we are dedicated to the creation of regional systems of reform, collaborating with district leaders to scale the successful teaching and learning strategies transforming our schools 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:

• The Absolute Priority for Personalization – The emphasis on personalized learning will help the classrooms of today transition to the dynamic, customizable learning experiences that students deserve. Personalization not only helps students master college and career ready standards, but prepares them with the competencies to become lifelong learners in the workforce and beyond.

• 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, KnowledgeWorks 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.

• Increase Transparency of non-Teaching and Learning Expenditures – While we commend the Department for trying to increase transparency of teaching and learning expenditures, improvements to productivity will require a comprehensive view of district finances. The Department should encourage districts to also disclose the non-teaching and learning expenditures and to demonstrate how it will use this information to maximize effectiveness of programs.

• 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 add "community, and region" to 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.)

• Professional Development for Superintendents and School Board Members – While we do not have an official position on teacher, principal, superintendent, and school board evaluation systems, we believe districts should provide comparable professional development opportunities for superintendents and school board members tied to any new evaluation system. Relevant opportunities could include increased time and resources to participate in national professional development programs, participation in residency programs, or travel to high performing districts to experience best practices firsthand. The Department can accomplish this by adding “Superintendent and School Board” to the teacher and principal professional development language in C.2.a.vi.

• 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,

Brian Ross
President and Chief Executive Officer
KnowledgeWorks

About KnowledgeWorks
As an educational operating foundation, KnowledgeWorks has more than a decade of experience scaling and sustaining innovative educational strategies that transform the way educators think about teaching and learning. Our commitment to dynamic learning for all students stems from our ongoing work in nearly 150 secondary schools nationwide and more than sixty communities.

The Association for Career and Technical Education (ACTE) and the National Association of State Directors of Career Technical Education Consortium (NASDCTEc) submit the following comments in response to the Race to the Top District (RTT-D) program announced on May 22, 2012.

ACTE is the nation’s largest not-for-profit education association dedicated to the advancement of education that prepares youth and adults for successful careers, with more than 27,000 members including teachers, counselors and administrators at the middle school, high school and postsecondary levels. The National Association of State Directors of Career Technical Education Consortium represents the state and territory agency heads responsible for secondary, postsecondary and adult career technical education (CTE).

While we do support the goal of the program, to enable all students to graduate college- and career-ready, ACTE and NASDCTEc believe that college- and career-readiness involves more than preparation for high school graduation and college enrollment. It also must include student attainment of employability and technical skills, and the ability to apply academic skills to authentic, real-world situations. These skills are essential for students’ future success in high-skill, high-wage, high-demand career areas.

Please consider the following proposed changes to the selection criteria and definitions stated in the draft of Race to the Top District.

Selection Criteria:

Achievable Annual Goals
Setting annual achievement goals is an important step in making progress in a program. It’s especially important to ensure that the goals you set will accomplish the purpose of the program. While assessment scores, graduation rates and college enrollment numbers show college readiness, they do not accurately show that a student possesses all of the necessary skills required for career success.

In addition to traditional academic assessments and graduation rates, measures of career-readiness skills are essential. For example, technical assessments leading to industry-recognized certifications provide an appropriate measure of a student’s technical aptitude and success in CTE programs. Many states have begun to recognize this and incorporate career readiness measures into their state accountability systems. A goal to increase the number of students working toward and attaining recognized industry certifications or other measures of career readiness should be explicitly included as a goal for student performance.

Suggested change:

Add under section A, subsection 2:
g) Student achievement on career readiness measures, such as the attainment of recognized industry certifications.

Educator Coordination
For some students, making the connection between classroom lessons and the real world can be challenging. While allowing educators to capture student data and measure student progress may help students improve in one class, these strategies alone do not help students make connections between classes. It is important for educators to have the time and resources to integrate lessons between traditional academic courses and CTE courses to increase student engagement and academic relevance. Doing so can allow students the opportunity to put their academic lessons to work in real-life scenarios.

Suggested change:

Add under section C, subsection 2, sub subsection (a):
vii. Coordinate to integrate content from academic and CTE courses to allow students to connect academic knowledge to real-world scenarios.

Accountability Through Industry Certifications
To ensure students are prepared for both college and career after high school, strong accountability systems are needed to ensure states are properly preparing their students to be college- and career-ready. Currently, this program takes into account graduation rates, student progress and local standards of college- and career-readiness; however, to ensure our students are fully prepared we must ensure they have the full range of skills necessary to attain high-skill, high-wage, high-demand careers.

Adding an accountability measure to focus on career readiness skills, particularly the attainment of industry certifications, would help to ensure that all students participating in RTT-D are truly college- and career-ready.

Suggested change:

Add under “Selection Criteria,” section C, subsection 4:
h) The number and percentage of participating students who achieve career readiness skills, such as through the attainment of recognized industry certifications.


Definitions:

Core Educational Assurance Areas
CTE courses are the backbone of career readiness. To be college- and career-ready requires a cooperation and balance between traditional academic courses and CTE courses. The proposed definition of “core educational assurance areas” includes adopting standards and assessments for preparing students to be successful in college and the workplace, but it is important to include in this definition the need for those standards in both academic and technical courses.

Suggested changes:

Under “Definitions,” amend the first bullet in the definition of “core educational assurance areas” to read:
• Adopting standards and assessments for rigorous academic and CTE coursework that prepare students to succeed in college and the workplace and to compete in the global economy.

With more attention paid to the importance of integration of academic and CTE coursework and to measuring career readiness skills, we can ensure that all of our students graduating from high school will be prepared for their futures.

We appreciate the opportunity to make these comments, and we look forward to continued partnership and dialogue concerning CTE and college- and career-readiness. If you have any questions or need additional information, please contact Alisha Hyslop, ACTE’s assistant director of public policy, at ahyslop@acteonline.org or 703-683-9331; or Nancy Conneely, NASDCTEc’s public policy manager, at 301-588-9630 or nconneely@careertech.org.

Sincerely,

Janet B. Bray, CAE
ACTE Executive Director

Kimberly A. Green
NASDCTEc Executive Director

For your convenience, we have posted a .pdf version of our comments online

As Superintendent of LAUSD, I am pleased to submit these comments on the Race To The Top District Competition Draft.

The Los Angeles Unified School District (LAUSD) is the nation’s second largest school district, serving over 664,000 students in grades K-12. We operate 1,235 schools and education centers, with a 2011-12 general fund budget of $6.5 billion.

Our student population is very diverse. Latino students compose 73.4 percent of our enrollment, with African Americans at 10 percent, Whites at 8.8 percent, and the remainder being Asian, Pacific Islander and Native American.

LAUSD serves students not only from the City of Los Angeles, but also from 28 cities either entirely or partially within our 710-square mile boundary.

LAUSD is a leader in education reform in such areas as teacher evaluations, turning around low-performing schools, public school choice and school-based decision making.

We are pleased to submit these comments on the Department of Education’s Race to the Top District Competition Draft.

While we are in broad agreement with the goals of the competition and fully intend to apply for a grant, we do have several questions and concerns.

BUDGET REQUIREMENTS

Our most serious concern is with the proposed budget requirements. The draft establishes three tiers of funding, with the top tier being for grantees serving 10,000 or more students. We believe these tiers unfairly penalize large school districts such as LAUSD, which serves over 60 times that number.

In the first tier, if a district or consortia of districts serving the minimum 2,500 students receives the minimum grant of $10 million, it would receive $4,000 per student served. On the other hand, a district serving 10,000 students receiving the largest grant of $25 million would receive only $2,500 per student; or only 62.5 percent of the per student level of the smallest grantee.

In LAUSD, 10,000 students are only 1.5 percent of our student population. Serving such a small percent of our students would severely limit the impact of the reforms that would be funded by a district RTTT grant. If, on the other hand, we proposed to serve 10 percent of our students, or 65,000, that would reduce the per-student level of the grant down to only $384, an amount that simply would not provide sufficient funds to enact long-term meaningful reforms.

Thus, we urge that an additional tier be created for districts proposing to serve 50,000 or more students, and that such grants range from $40-50 million.

ABSOLUTE PRIORITIES

LAUSD is also concerned with the “absolute priorities” that allow school districts in states that have received state level RTTT grants to also compete for these district-level grants. Since the overall pool of funds for this competition is rather limited, and many, if not most, districts in RTTT states are receiving funding through their state’s RTTT grant, we believe that the bulk of the district level competition should be reserved for districts in states that were not RTTT grantees. To do otherwise would be to essentially allow districts in RTTT states to “double dip” and receive funds from two RTTT competitions, while disadvantaging districts in states, such as California, that have not received any RTTT funding. Thus, we propose that two-thirds of the funds be reserved for Absolute Priorities 4 and 5.

SCHOOL BOARD EVALUATION

We have both questions and concerns with Eligibility Criteria 4.a.iv.—school board evaluation. In LAUD, as in the majority of school districts in the country, our school board members are elected by the voters and are accountable to the public through such elections. In addition, since school board members serve staggered terms, at different points in time there will be a mix of newly elected members and those who have served several years. Thus, we are not clear on how we would meet this requirement as spelled out in the definitions section. We urge the Department to eliminate this specific requirement. The required evaluations of teachers, principals and the superintendent are sufficient to ensure that those involved in the daily instruction of students and the leadership of schools are held accountable for their performance.

REQUIRED SIGNATURES

While LAUSD is committed to working collaboratively with our teacher union and our other employee unions, we share the concerns expressed by the Council of Great City Schools about the requirement in paragraph 5 of the Eligibility Criteria that requires a signature from the local union on the grant application. We support the Council’s suggestion that this union signature requirement be deleted and instead recommend 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.

We also request that at a minimum, the meaning of “union” be clarified. At LAUSD, in addition to our teachers’ union, we have contracts with seven additional unions, including those representing school administrators; teacher assistants and instructional aides; classified employee supervisors; technical, professional and clerical employees and others. Thus, we recommend that the term “union” be clarified to mean the union representing teachers, to avoid any potential interpretation that we would otherwise be required to obtain signatures from all of or employee unions.

DATA SYSTEMS

We have concerns and questions about the requirement set forth in paragraph 4.b.ii. that requires the LEA to have “a robust data system” that has the “ability to match student level P-12 and higher education data.”

While some states have P-16 data systems that track individual students through their transition from high school to postsecondary education, the state of California does not yet have such a system in place. At the district level, LAUSD simply does not have access to data that tracks whether an individual student is enrolled in an institution of postsecondary education within 16 months of graduation. Even in states that have robust P-16 data systems, there is often an inability to track students who enroll in institutions of postsecondary education out of state.

Thus, the only mechanism we are aware of that would provide us with such data is the National Student Clearinghouse. We ask that the Department clarify that an applicant’s intent to contract with the Clearinghouse would meet the criteria in paragraph 4.b.ii that the LEA already have such a robust data system. Second, we ask that the Department clarify that a grantee may use a portion of its district RTTT funds for the purchase of such data.

APPLICATION REQUIREMENTS

Paragraph 2 of this section mandates that each “LEA included in an application must provide its Mayor or other comparable official five business days to comment on the LEA's application and submit as part of its application package” the “City or Town's comments.” As stated in our introductory comments, LAUSD serves not just the students of the City of Los Angeles, but also those from more than two dozen other jurisdictions. In addition, within LAUSD’s boundaries are cities or towns with only a few parcels of land that generate no enrollment

We have both questions and concerns with this requirement. Would we be required to submit our application to the mayor each jurisdiction, including those that generate no enrollment? We suggest that this provision be revised to only require that the application be submitted for comment to the mayor of the largest city or town within the jurisdiction of the school district. Otherwise, this represents an unnecessarily burdensome requirement.

PROGRAM REQUIREMENTS

We seek clarification of paragraph 4, “Districts where minority students or students with disabilities are overly-represented in discipline and expulsion rates (according to data submitted through the Civil Rights Data Collection) must undergo a district assessment of the root cause and develop a plan over the grant period to address root causes.”

In October 2011, LAUSD entered into a Voluntary Resolution Agreement with the Department's Office for Civil Rights under which we committed to take steps to report disparate discipline rates, and eliminate inequitable and disproportionate discipline practices for African American students. Thus, we suggest that this section be revised to make clear that a district must either undergo such an assessment or be in the process of implementing a plan to address this issue.

Districts are critical to the success of the four policy priorities at the heart of Race to the Top (RTTT): raising standards, building better data systems, evaluating and supporting teachers and leaders, and dramatically transforming the lowest performing schools. We support the U.S. Department of Education’s efforts to provide support to those districts willing to move forward in these areas.

We agree that raising achievement and closing gaps requires a focus on meeting the targeted needs of every student. However, we are concerned that, on its own, the Department’s proposed focus on personalization could unintentionally undermine our shared hopes for RTTT.

Uniform, well-defined expectations for what it means to graduate from high school ready for college and the workplace can open access to rigorous, rich learning experiences for all students. Yet the proposal’s extensive requirements around personalization are not tightly connected to the outcome of college- and career-ready graduation. Without this link, the emphasis on personalization could diminish the power of common expectations and could result in growing achievement gaps. Additionally, the singular focus on personalization could divert district attention from other critical levers for improvement.

Our comments recommend ways the Department can promote the RTTT policy priorities at the district level, and better ensure that districts raise achievement and close gaps. Specifically, our recommendations are aimed at:

  1. Significantly tightening — to promote focus — the personalized learning criteria and more closely aligning those requirements with college- and career-ready outcomes, and;
  2. Identifying and prompting action on key district levers that can improve both equity and student achievement.

Absolute Priority 1: Personalized Learning Environments
We recommend replacing Section C: Preparing Students for College and Careers (p. 6-10) with the following language:

C: Preparing Students for College and Careers

High-Quality Plan: The extent to which the applicant* has a high-quality plan for ensuring that all students receive the personalized instruction and learning supports they need to graduate college- and career-ready, and that all teachers and leaders receive the personalized professional support, real-time student performance data, and resources they need to provide such instruction and learning supports. At a minimum, the applicant must have a plan for:

  1. Developing and disseminating to all teachers high-quality, comprehensive instructional materials aligned with college- and career-ready expectations. Such resources should include course materials, lesson plans, and model assignments that are rich in real-world problems and tailored to a range of student interests; as well as scoring rubrics and exemplars of student work that meet the expectations set by the rubrics.
  2. Providing effective school leaders with sufficient flexibility and autonomy to meet demonstrated school needs and student interest. These leaders should have flexibility over such factors as schedules and calendars, personnel decisions, roles and responsibilities for educators and non-educators, and school-level budgets.
  3. Using the results of evaluation systems to provide all teachers and leaders with the personalized feedback and supports they need, and to inform LEA staffing decisions, in order to provide all students with effective instruction aligned with college- and career-ready expectations.
  4. Systematically identifying students who are farthest off-track to graduate college- and career-ready, and providing those students with the additional, personalized supports they need to get back on track.

Performance Measures: The extent to which the applicant has established ambitious yet achievable annual targets for:

  1. Increasing student performance, overall and by subgroup, on statewide summative assessments;
  2. Decreasing achievement gaps between subgroups;
  3. Increasing graduation rates, overall and by subgroup;
  4. Increasing college enrollment rates, overall and by subgroup;
  5. Increasing performance on college- and career-ready indicators such as ACT, SAT, or the percentage of students participating in, and successfully completing, a college- and career-ready course of study, overall and by subgroup;
  6. Decreasing the number and percentage of students, overall and by subgroup, who miss 10 percent or more of school days; and
  7. Decreasing the number and percentage of teachers who miss 10 or more days when they would otherwise be expected to be teaching in assigned classes.

For each of the performance measures above, the LEA shall explain how its established goals align with or exceed goals set for it by the SEA.

Absolute Priority 2: Equity
We recommend that the Department add an Absolute Priority aimed at promoting equity within LEAs. Language for this new Absolute Priority follows.

Selection Criteria for Absolute Priority 2: Equity

High-Quality Plan: To meet this priority, the applicant must include an analysis of current performance in the following areas, using the measures described below:

  1. Equitable school funding;
  2. Equitable access to effective teachers;
  3. Equitable discipline practices; and
  4. Equitable participation in a college- and career-ready course of study.

The applicant must select at least two areas where the measures show systematic differences in opportunity for different subgroups of students, set ambitious but achievable annual goals — based on the measures analyzed — for reducing these differences over the next three years, and present a plan for how it will achieve these goals.

Required Analyses and Measures:

  1. Equitable School Funding
    1. LEAs with more than one school in any grade span must measure:
      • For any grade span where an LEA has both Title I and non-Title I schools, the number and percentage of Title I schools not equitably funded, as defined in this document.
      • For any grade span where an LEA has only Title I schools, the number and percentage of higher poverty schools not equitably funded, as defined in this document.
  2. Equitable Access to Effective Teachers
    1. LEAs that have already implemented new teacher evaluation systems must measure:
      • The number and percentage of students, by subgroup and grade span, assigned to one or more ineffective teachers.
      • Of the students assigned to ineffective teachers, the percentage that belongs to each subgroup, by grade span, and how these percentages compare with the percentages of all students in the grade span that belong to each respective subgroup.
    2. LEAs that are still establishing teacher evaluation systems must measure:
      • The number and percentage of students, by subgroup and grade span, assigned to one or more: 1) first-year teachers; 2) teachers that, in the previous year, received the lowest rating on the district’s teacher evaluation system; and 3) secondary-level teachers possessing neither certification nor academic major in their assigned subject.
      • Of the students assigned to each category of teachers, the percentage that belongs to each subgroup, by grade span, as compared with the percentage of all students in the grade span that belong to each respective subgroup. For example, xx percent of high school students assigned to first-year teachers are low income, while yy percent of all high school students are low income.
  3. Equitable Discipline Practices
    1. LEAs must measure:
      • Of the students committing a disciplinary offense, the percentage that receive 1) an in-school suspension; 2) an out-of-school suspension; and 3) an expulsion, by offense type, subgroup, and grade span.
  4. Equitable Access to a College- and Career-Ready Course of Study
    1. LEAs with one or more high schools must measure:
      • The number and percentage of high school students, by subgroup, enrolled in a course of study aligned with college- and career-ready expectations.
      • Of all students enrolled in a course of study aligned to college- and career-ready expectations, the percentage belonging to each subgroup, and how those percentages compare with the percentages of all students in the grade span that belong to each respective subgroup.

Definitions:

Equitably funded: Where an LEA has both Title I and non-Title I schools in a grade span, to be equitably funded, a Title I school must receive an amount of state and local funds per student (including actual teacher salaries) that is equal to or greater than 97 percent of the amount of state and local funds received by an average non-Title I school in the LEA. Where an LEA has only Title I schools within the same grade span, to be equitably funded, a higher poverty school must receive an amount of state and local funds per student (including actual teacher salaries) that is equal to or greater than 97 percent of the amount of state and local funds received by an average lower poverty school in the LEA.

Grade span: Range of grades served by the school. LEAs may divide their schools into up to three grade span categories, such as elementary, middle, and high school.

Eligibility Criteria

Educator Evaluation Systems, Criteria 4(a)
Although we strongly support meaningful educator evaluation systems, the current language could preclude from eligibility districts without fully designed systems at the time of application. We recommend the Department clarify that districts must commit to designing and implementing new evaluation systems by 2014-15. In addition, LEAs should explain how their teacher and principal evaluation systems will align with those being developed by the state in cases where the SEA is designing, or developing guidelines for, such systems.

Proposed Additional Criteria: College- and Career-Ready Standards
The current eligibility criteria assume that all districts will be located in states that have adopted college- and career-ready standards. This, however, may not be the case. We recommend adding the following eligibility criteria:

  1. To be eligible for RTTT-D funds, an LEA must either: 1) certify that its state has adopted college- and career-ready standards; or 2) describe how the LEA will measure student progress and performance against college- and career-ready expectations.

Definitions:

College- and Career-Ready Expectations: For districts in states that have adopted college- and career-ready standards, as defined in this document, those standards shall be considered college- and career-ready expectations. For districts in states that have not adopted college- and career-ready standards, college- and career-ready expectations are defined as the criteria students need to meet by the time they graduate high school to satisfy the requirements for admission into credit-bearing courses most commonly required by the state’s public four-year institutions.

Data Systems
We agree with and fully support the comments submitted by the Data Quality Campaign with regard to the data system components of the RTTT-D application. In particular, we recommend that the Department maintain the teacher/student link requirement, but eliminate the requirement for a link to higher education.

Program Requirements

Budget Requirements
The $25 million limit on the size of an award granted to a district or consortia of districts with more than 10,000 students serves as a disincentive for larger districts to cooperate with one another. To ensure that large districts have an incentive to participate in the RTTT-D competition, and to collaborate, we recommend the following:

  • Capping the category for 10,000+ students at 29,999, and setting the budget range at $20-$25 million.
  • Creating an additional category for districts with 30,000+ students, and setting the budget range at $23-$30 million.
  • In a situation where a consortium of districts is comprised of LEAs that all have 30,000+ students, allowing the consortium to apply for an amount of funds equal to $25 million multiplied by the number of districts participating in the consortium.

*Wherever “applicant” appears in any of the sections of this document, including within Absolute Priority 1 and Absolute Priority 2, it refers to both single LEA and consortia applicants. Where the applicant is a consortium, each requisite item to be addressed must be addressed for each LEA within the consortium.

The Education Trust, The Education Trust-Midwest, and The Education Trust-West

For a permalink to these comments, click here.

United Way Worldwide's Comments for Race to the Top-District (RTT-D) Competition

Thank you for your leadership to provide school districts with the opportunity to raise standards, increase high school graduation rates, close achievement gaps and dramatically transform their lowest-performing schools. We appreciate the opportunity to submit comments on the proposed priorities and requirements outlined in the draft regulations.

As an organization that often serves as a backbone for strong and healthy communities, we applaud the Department’s recognition of the importance of community partnerships that support student learning, as evidenced by language in the competitive priority. Catalytic, anchor organizations are critically importance to ensure disciplined, high-performing community partnerships.

Therefore we recommend that the competitive priority rewarding extra points for proposals that include a “coherent and sustainable partnership with public and private organizations” include incentives for partnerships to establish such a backbone organization. This backbone institution provides the overall strategic direction; gathers, analyzes and shares data; ensures a shared community vision; drives alignment around critical education priorities; coordinates multi stakeholder engagement; and mobilizes funding. Community coalitions partnering with LEAs to create student learning centered environments are much more likely to be sustainable and aligned for success if that anchor role is filled.

In addition, we submit, for careful consideration, recommendations to ensure that school districts undertake reforms that effectively tailor instruction to the needs of individual students. We recommend that the Department consider including the following in the regulations:

1. Developmental and Social-Emotional Supports: School districts should not only strengthen academic supports for students, but also developmental and social-emotional supports. We recommend modifying the Absolute Priority 1 to include these areas:
“…to create student centered learning environment(s) that are designed to: significantly improve teaching and learning through the personalization of strategies, tools, and academic, developmental and social-emotional supports for teachers and students that are aligned with college- and career-ready standards….”

2. Use of Early Warning and Response Systems: To meet the “Personalized Learning Environments” priority, school districts should consider using data, such as early warning systems, to track the academic and behavioral needs of students, identify students who require intensive, specialized education services and programs and provide customized learning and wraparound supports.

3. Measures of School Readiness: The RTT-D should provide incentives to encourage districts to use a population-based measure of school readiness that includes physical health and well-being, social competence, emotional maturity, language and literacy and general knowledge and communication. A population-based measure of school readiness will provide critical data about the percentage of children who are vulnerable and thriving by community, facilitating deeper and broader public engagement on the importance of early childhood while informing planning and decision-making.

4. Linkages from Birth to Five to K-12: School districts should demonstrate linkages of early education services with curriculum and assessment in schools and school districts to ensure that young children are able to seamlessly transition to the K-12 system. They should further demonstrate linkages of a data system supporting early learning with the K-12 longitudinal data system.

5. Preventing Summer Learning Loss: Research demonstrates that students lose up to two months of instruction during the summer months when school is out. Summer learning loss is greatest for low-income students of color and serves to exacerbate achievement gaps. Educators lose precious time at the beginning of the subsequent school year re-teaching content. We encourage the explicit inclusion of high-quality summer learning opportunities that are aligned to the school year as one important support in creating personalized learning environments. We also encourage the explicit inclusion of summer learning opportunities as one delivery method for addressing the academic, social-emotional, developmental and behavioral supports in the competitive priority.

6. Effective Grade and School Level Transitions: Supporting effective transitions is one way to better ensure that students get the supports they need before they get off track.
We urge the explicit inclusion and emphasis on supporting effective grade and school level transitions as a strategy within the competitive priority to ensure that student supports are effectively aligned at critical junctures in a student’s academic career. This includes the transition into kindergarten, 3rd to 4th grade, elementary to middle grades, and from 8th to 9th grade.

7. Community Stakeholder Engagement: As part of the application requirements, eligible applicants should not only be required to provide a comment period for local elected officials, but should also be required to solicit input from community stakeholders, including families, student organizations, business leaders, community-based organizations, higher education institutions and other stakeholder groups.

8. Family Engagement: School districts should not only be required to include input from parents and families, but should also demonstrate a plan to build staff capacity to engage families in the school system. This may include professional development courses for administrators and teachers focused on strengthening family and school partnerships to support student success.

United Ways have served as backbone organizations supporting education partnerships across the country. They have also invested significant resources of their own and provided volunteer support and advocacy to improve education outcomes at the state and local level. The Race to the Top-District Competition provides an opportunity for United Ways to work with schools and mobilize community stakeholders to create more effective and innovative models that focus on personalized learning environments for young people. We ask that you consider the aforementioned recommendations and reward the role that community-based organizations can play in creating sustained and coherent partnerships with schools.

Thank you for the opportunity to comment on the Race to the Top District draft executive summary.

Innosight Institute is a not-for-profit, non-partisan think tank whose mission is to apply Harvard Business School Professor Clayton M. Christensen’s theories of disruptive innovation to develop and promote solutions to the most vexing problems in the social sector. In education, we seek to transform the country’s education system into a student-centric one where each child can realize his or her fullest human potential.

We applaud the Department’s desire to inspire innovation at the district level. We believe that the emphasis on students’ personal learning needs is a bold and important step forward. Encouraging a move toward competency-based learning models is critical for the success of our nation’s education system.

We hope that Race to the Top District competition encourages substantive student-centered reform, and in order to ensure this clear purpose we have a few suggested revisions:

• Emphasize learning over teaching
• Do not use attendance as a metric for success
• Leave room for innovation; avoid prescribing specific inputs and focus instead on desired outcomes

Emphasize learning over teaching
The phrase “teaching and learning” appears nine times throughout the proposal. If the competition is to spur truly student-centered learning, however, then this must be captured in both semantics and spirit. Learning should come before teaching. In “Absolute Priority 1, Personalized Learning Environment(s)” the first design principle listed after the colon is to “significantly improve teaching and learning through the personalization of strategies, tools and support for teachers and students.” It is problematic to prioritize teacher improvement over the improvement of a learner’s experience. This first design principle also potentially falls short of encouraging true transformation by implying that the personalization through “strategies, tools and support” be in support of current learning environments rather than expanding the personalization to encompass a student’s entire learning experience. We suggest the following language to more closely align the content with the Priority’s heading:

“create student-centered learning environments that are designed to: personalize student learning; significantly improve learning outcomes by moving toward a competency-based system relying on student growth metrics; allow for student creativity; decrease the achievement gap across student groups; and increase the rates at which students graduate from high school prepared for college and careers.”

We encourage the Department to read the summary with an eye to the places in which teachers’ experience and improvement is seemingly prioritized over that of students. Great teachers are essential to all student success and professional development is necessary and important. Teacher development ought to be a means toward accomplishing bold student growth goals, not the goal itself.

Do not use attendance as a metric for success
Seat-time and student attendance are the incorrect measures of success in a world in which learning can happen anywhere and at any time and are at odds with other good language and goals in the executive summary (see Sec. C.3.a.ii for example). Including student attendance as a goal precludes districts from thinking about new and innovative ways to serve students outside of the four walls of a traditional brick and mortar school. It is clear that time spent sitting in a seat does not mean time spent truly learning; the metrics should reflect that although attendance may be correlated with achievement in traditional schooling models, it is not causal per se. If, in improving student learning, a school must focus directly on improving student attendance because it is relevant to the program it is creating, then of course that is good, and it should be reflected in the individual proposal to demonstrate a coherent and well-conceived program. This input metric, however, should not be prescribed as a goal of the competition. The competition ought to instead encourage districts to look away from seat time toward actual student learning; schools should be rewarded equally if this is accomplished through providing online course opportunities accessible from anywhere or through real-world learning. The first rounds of Race to the Top showed true potential to fuel legislative change at the state level. Even with a competition geared toward districts and consortia of LEAs, there still exists that opportunity. Race to the Top District, in emphasizing student experience and results over student attendance, has the potential to motivate states to do away with seat-time requirements, an important first step to allow districts to flourish and innovate. We believe this is an opportunity not to be missed.

Leave room for innovation; avoid prescribing specific inputs and focus instead on desired outcomes
The ultimate goals in this competition should be around bolstering all students’ learning. We are pleased to see the summary state that school leaders ought to have: “Sufficient flexibility and autonomy over such factors as school schedules and calendars, school staffing models, roles and responsibilities for educators and noneducators, and school-level budgets.” This leaves the door open for innovative leaders to take charge toward this end. We worry, however, that language elsewhere restricts this proposed autonomy and instead encourages a variety of traditional models of schooling and an emphasis on compliance instead of student learning growth.

One such traditional model that the rules seem to encourage is that of one teacher in a confined classroom. For example, the idea that the success of LEAs will be determined based on: “the number and percentage of participating students by subgroup who have daily access to effective and highly effective teachers” is problematic in the way that it potentially limits the innovative staffing models possible to serve students if educator is defined as one being co-located with the student. With the advent of widely available online curriculum and delivery models, all students can learn from the world’s most effective educators regardless of location.

In innovative student-centric environments, there is a high likelihood that students will interact with a range of adults who impact their learning and have differentiated teaching roles. Some educators may be content experts; others may be those best at one-on-one student coaching, designing project-based learning, or creating well-matched small groups, for example. The competition’s current emphasis on teacher evaluation obfuscates this important point. The provision that an LEA must have a data system that has an individual teacher identifier with a teacher-student match may be too limiting as an eligibility requirement. As students gain access to curricula and teaching from multiple sources, having an individual teacher identifier with a teacher-student match will likely restrict needed innovation in teaching models. Given where the technology stands at this moment, this seems an overly prescriptive and not inherently useful requirement—and focuses on the wrong end. Similarly, that the LEA must design its own teacher evaluation system is too prescriptive, as it implies a one-size-fits-all evaluation system for all of the schools and programs in its domain. Different schooling models may find that different evaluation systems make sense for their purposes. If mandating this type of input remains important, more appropriate language might require that participating entities implement evaluation systems appropriate for their specific programs.

Furthermore, language that suggests that all participating educators must participate in the same type of training is misguided; instead the emphasis should be on insuring that all educators can receive the training that is relevant for their specific job given the model in which they are working. This section also seems to imply that teachers will always lead assessments, when in fact automated assessment and data engines may help significantly in these areas.

Beyond teaching structure, the definition of “personalized learning plans” is too specific. The executive summary prescribes a formal document. This input requirement implies a flat document. Loosening the definition would allow for a dynamic and changing personalized learning plan embedded in a digital platform. Thanks to adaptive technology, a learning plan could be something students access daily to view their goals and playlists of lessons and exercises for the day. To this end, the input-based metric of weekly student access to the learning plan ought to be removed, not because it is bad per se, but because it is more likely to encourage compliance-driven plans rather than thoughtful ones based on a coherent program. If this is something the Department deems important in and of itself, however, then better language might be that a personal learning plan must be updated at least weekly based on a student’s progress so that it is an active and useful tool, not a check-the-box criterion that merely encourages compliance for its own sake. Most sound would be language that suggests this as one possible element of a strong and coherent plan but does not require it and therefore force an incoherent plan where it might not make sense.

We suggest that the Department consider revising those parts of the summary that make specific reference to classroom structure, teacher responsibilities, and technology specifics.

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Overall, we are pleased to see the Department encouraging student-centered and personalized learning and are pleased to see that the Department has created a possibility for additional funding for LEAs that target areas of nonconsumption (Sec. F.1.), which are ripe for disruptive innovation. We applaud the Department for its ongoing hard work and commitment to educational innovation.

The Association for Career and Technical Education (ACTE) and the National Association of State Directors of Career Technical Education Consortium (NASDCTEc) submit the following comments in response to the Race to the Top District (RTT-D) program announced on May 22, 2012.

ACTE is the nation’s largest not-for-profit education association dedicated to the advancement of education that prepares youth and adults for successful careers, with more than 27,000 members including teachers, counselors and administrators at the middle school, high school and postsecondary levels. The National Association of State Directors of Career Technical Education Consortium represents the state and territory agency heads responsible for secondary, postsecondary and adult career technical education (CTE).

While we do support the goal of the program, to enable all students to graduate college- and career-ready, ACTE and NASDCTEc believe that college- and career-readiness involves more than preparation for high school graduation and college enrollment. It also must include student attainment of employability and technical skills, and the ability to apply academic skills to authentic, real-world situations. These skills are essential for students’ future success in high-skill, high-wage, high-demand career areas.

Please consider the following proposed changes to the selection criteria and definitions stated in the draft of Race to the Top District.

Selection Criteria:

Achievable Annual Goals
Setting annual achievement goals is an important step in making progress in a program. It’s especially important to ensure that the goals you set will accomplish the purpose of the program. While assessment scores, graduation rates and college enrollment numbers show college readiness, they do not accurately show that a student possesses all of the necessary skills required for career success.

In addition to traditional academic assessments and graduation rates, measures of career-readiness skills are essential. For example, technical assessments leading to industry-recognized certifications provide an appropriate measure of a student’s technical aptitude and success in CTE programs. Many states have begun to recognize this and incorporate career readiness measures into their state accountability systems. A goal to increase the number of students working toward and attaining recognized industry certifications or other measures of career readiness should be explicitly included as a goal for student performance.

Suggested change:
Add under section A, subsection 2:
g) Student achievement on career readiness measures, such as the attainment of recognized industry certifications.

Educator Coordination
For some students, making the connection between classroom lessons and the real world can be challenging. While allowing educators to capture student data and measure student progress may help students improve in one class, these strategies alone do not help students make connections between classes. It is important for educators to have the time and resources to integrate lessons between traditional academic courses and CTE courses to increase student engagement and academic relevance. Doing so can allow students the opportunity to put their academic lessons to work in real-life scenarios.

Suggested change:
Add under section C, subsection 2, sub subsection (a):
vii. Coordinate to integrate content from academic and CTE courses to allow students to connect academic knowledge to real-world scenarios.

Accountability Through Industry Certifications
To ensure students are prepared for both college and career after high school, strong accountability systems are needed to ensure states are properly preparing their students to be college- and career-ready. Currently, this program takes into account graduation rates, student progress and local standards of college- and career-readiness; however, to ensure our students are fully prepared we must ensure they have the full range of skills necessary to attain high-skill, high-wage, high-demand careers.

Adding an accountability measure to focus on career readiness skills, particularly the attainment of industry certifications, would help to ensure that all students participating in RTT-D are truly college- and career-ready.

Suggested change:
Add under “Selection Criteria,” section C, subsection 4:
h) The number and percentage of participating students who achieve career readiness skills, such as through the attainment of recognized industry certifications.


Definitions:

Core Educational Assurance Areas
CTE courses are the backbone of career readiness. To be college- and career-ready requires a cooperation and balance between traditional academic courses and CTE courses. The proposed definition of “core educational assurance areas” includes adopting standards and assessments for preparing students to be successful in college and the workplace, but it is important to include in this definition the need for those standards in both academic and technical courses.

Suggested changes:
Under “Definitions,” amend the first bullet in the definition of “core educational assurance areas” to read:
• Adopting standards and assessments for rigorous academic and CTE coursework that prepare students to succeed in college and the workplace and to compete in the global economy.

With more attention paid to the importance of integration of academic and CTE coursework and to measuring career readiness skills, we can ensure that all of our students graduating from high school will be prepared for their futures.

We appreciate the opportunity to make these comments, and we look forward to continued partnership and dialogue concerning CTE and college- and career-readiness. If you have any questions or need additional information, please contact Alisha Hyslop, ACTE’s assistant director of public policy, at ahyslop@acteonline.org or 703-683-9331; or Nancy Conneely, NASDCTEc’s public policy manager, at 301-588-9630 or nconneely@careertech.org.

Sincerely,

Janet B. Bray, CAE
ACTE Executive Director

Kimberly A. Green
NASDCTEc Executive Director

For a .pdf version of these comments please use this link:
https://www.acteonline.org/uploadedFiles/Blogs/CTE_Policy_Watch_Blog/ACT...

The Collaborative for Building After-School Systems (CBASS) is a coalition of intermediary organizations in eight jurisdictions nationwide dedicated to increasing the availability of quality after-school programming by building citywide after-school systems. We 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.

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.

CBASS partners include: The After-School Corporation (New York City), The After-School Institute (Baltimore), After School Matters (Chicago), Baltimore's Safe and Sound Campaign, Boston After School and Beyond, Chicago Allies for Youth Success, Partnership for Children and Youth (Bay Area, CA), Prime Time Palm Beach County, Providence After School Alliance

I am disappointed not see this grant opportunity available for Early Intervention. Cradle to Career indicates this component would encompass children birth to age three. Are there plans to extend a grant opportunity in this area?

From: Center for American Progress
To: U.S. Department of Education
Re: Race to the Top District Competition Draft
Date: June 8, 2012

The Center for American Progress appreciates the opportunity to comment on the Race to the Top District Competition draft. The Center for American Progress, or CAP, is an independent nonpartisan educational institute dedicated to improving the lives of Americans through progressive ideas and action.

We commend the Administration and Congress for the continued investment in competitive education programs to drive innovation and reform. Federal resources are limited, thus it is wise to focus them on districts that possess the greatest commitment to and potential for improving student outcomes. The state-level Race to the Top program has stimulated significant, widespread policy change among states, and we anticipate the same for districts.

Strengths of the Draft Competition

We would like to draw attention to the following overall strengths of the draft competition—

Data systems. We commend the Department of Education, or ED, for a continued focus on enhancing data systems in order to drive improvement in policy and practice. We particularly value the focus on building data systems to capture student growth and outcomes beyond high school, the linking of individual student progress data to interventions and supports, and the push to ensure data systems are interoperable, as outlined in the Selection Criteria (C)(3)(b)(iv).

Evaluations. We commend ED for a continued focus on leveraging educator evaluations to improve teacher and principal effectiveness and for aligning requirements with those found in the state RTT program and ESEA Flexibility. We note with interest the proposal to evaluate superintendents and school boards. We agree that student and school performance are a shared responsibility, and reform and school improvement can hinge on effective school governance. Whether school board evaluations are indeed effective tools for improving school governance is debatable, but we hope this competition spurs some thoughtful discussion on the critical role of school governance.

Personalized learning. We commend ED for using federal funds to move teaching and learning toward greater individualized student success and personalization of learning, while requiring better tools to deliver differentiated instruction. This approach captures many of the efforts that have been more prominent in alternative education programs, in the use of online and blended learning, and in more experimental charter schools. The RTT-D program would incentivize schools to get away from the lock step approach to teaching and learning, focusing districts on a “rigorous course of study,” to let students “move at their own pace”, “pursue areas of personal passion”, “demonstrate mastery in critical areas.” In the context of college- and career-readiness, RTT-D would be unique in federal policy, and would helpfully link to and enhance other federal initiatives such as state RTT and ESEA Flexibility.

Rural access. We commend ED for taking several steps to ensure rural districts, or LEAs, have access to this competitive fund, including two absolute priorities for rural LEAs. We appreciate the lowering of the required number of students served so that it is more attainable for rural districts and the ability to form consortia (including consortia across states). That said, we note that some very rural states face extra challenges in forming consortia across large geographic distances, as well as states, and hope that ED will keep this in mind when evaluating this aspect of applications.

Teacher collaboration. We commend ED for ensuring LEAs allow for teacher collaboration and teams or professional learning communities to meet the requirements and expectations of the grant, namely in Selection Criteria (C)(2). This is a way of elevating collaborative, job-embedded professional development around the solution of a local school problem. And it is a way of empowering teachers in line with the objectives of the RESPECT initiative.

Transition plan. We appreciate the detailed requirements under Selection Criteria for describing a transition plan. This is vitally important since school districts, or LEAs, will be doing a significant amount of work in a short period of time.

Transparency. We appreciate the focus on increasing transparency in district processes, practices, and investments, namely around school-level expenditures under Selection Criteria (B)(2). This is important because few districts report or operate using actual expenditure data at the school level. Such practice impairs transparency, creates an obstacle to budgeting in strategic ways, and contributes to the grossly inequitable ways in which our schools are funded.

Recommendations

CAP would like to draw specific attention to the following items in the proposed Race to the Top District (RTT-D) draft—

Eligibility criteria. We appreciate that ED requires at least 40 percent of students across all participating schools to be from low-income families, as a way to target federal funds to high-need students and schools. We wonder, however, if the threshold is high enough to ensure that low-income schools and students are sufficiently served. For example, we commend ED for requiring LEAs to increase student access to effective teachers and principals, especially in hard to staff subjects and schools (Transition Plan and Performance Measurements). But with the threshold of 40 percent, it is unclear if this would sufficiently capture hard-to-staff schools or adequate numbers of low-income students to improve access to effective educators. We urge the ED to make special efforts to ensure that the schools and student populations that could most benefit from the expanded approaches to personalized learning include the students that need these approaches the most.

Absolute priorities. We commend ED for requiring LEAs to make significant changes to current practice, which should include new staffing patterns, smarter use of technology, and better uses of time and resources to support multiple ways of learning. Given such changes require significant reform, we urge ED to avoid awarding grants to LEAs that do not make broader systemic changes, and to require LEAs to sufficiently demonstrate that they are willing and able to make such changes.

Competitive preference priority: Wraparound services. We appreciate that ED would award a competitive preference to districts that integrate public and private resources to augment schools' core resources by providing additional student and family supports, or wraparound services and school-community partnerships. There is a clear and important emphasis on creating indicators of progress, tracking data on those indicators, and improving results over time. We recommend that ED go a step further and require that LEAs applying under this priority also partner with an organization with research capacity, such as an institution of higher education, to drill down on one variable of their choice that has the potential to impact student achievement through wraparound services. For example, researchers recently partnered with the MATCH Charter Public Schools to study the impact of teacher-parent communication through phone calls and text/written messages on homework completion rates and student time on-task (http://www.startinganedschool.org/2011/07/19/parent-phone-calls-the-evid...). With few existing rigorous studies on the causal relationship between wraparound services and partnerships, the RTT-D competition has the potential to drive not only innovation, but also research.

Selection criteria: Teaching. We appreciate the focus on implementing optimal learning approaches such as project-based learning and use of manipulatives, and the desire for teachers to accelerate student progress. This, of course, assumes LEAs have the capacity to train teachers. We recommend that ED consider this when evaluating applications or ask LEAs to specify a capacity building plan that includes teacher development.

Selection criteria: Policy and infrastructure. The requirements would significantly change current practice for many LEAs. The particular requirement to provide students the opportunity to progress and earn credit based on mastery, rather than seat time, is an admirable but heavy lift. It may require change in state policy (e.g., with respect to how graduation requirements are determined) or new arrangements with postsecondary institutions around admission requirements. Some LEAs will be disadvantaged if they are located in states lacking such policies. We encourage ED to consider this in evaluating applications and to consider how aligned the state policy environment and data systems are.

Selection criteria: Performance measurements. We appreciate the use of student and teacher surveys as indicators of school performance. It is unclear to us, however, what the goal is for the use of (f) survey on teacher working conditions and (g) student survey. ED only requires LEAs to monitor how well the surveys are completed, but not to make progress on the indicators within the survey. ED should clarify its goal here and provide parameters for measuring the impact of reform efforts on students and teachers, as measured through surveys.

Selection criteria: Optional budget supplement. We appreciate the desire to fund supplemental activities that would support the goals of Absolute Priority 1. We recognize the examples of supplemental activities center on technological or instructional materials or programs. But we also see this as an opportunity for a consortium of rural LEAs to attend to the special challenges of working across agencies

On behalf of the National Association of School Psychologists (NASP), we appreciate the opportunity to provide comments on the design of the 2012 Race to the Top District (RTT-D) grant competition. NASP represents more than 24,000 school psychologists who work with students, educators, and families to support the academic achievement, positive behavior, and mental wellness of all students, especially those who struggle with barriers to learning. School psychologists work with parents and educators to help shape individual and system wide supports that provide the necessary prevention and intervention services to ensure that students all have access to the mental health, social-emotional, behavioral, and academic supports they need to be successful at school. We commend you for providing further opportunities for local school districts to improve upon their efforts to ensure that all students will graduate from high school ready for college career. As the Department finalizes the RTT-D competition design and makes final award decisions, we urge you to take the following comments into consideration.

Eligible LEA’s

We appreciate your attempt to ensure that that LEAs of all sizes and in all localities will be eligible, either alone or in a consortium, to apply for a RTT-D grant. However, as you consider the final application design, we ask that you create an additional Absolute Priority for applications that represent a singular district, or a consortium of districts, that serve children and families in the military. Approximately 2 million children have at least one parent in the military, representing nearly 4% of the school-age population. These students are at increased risk for experiencing mental health concerns, behavior problems, school mobility and drop-out, and reduced academic performance. These risks extend to all military students, including those without currently deployed parents. The potential for deployment at any time can lead to a chronic state of stress and anxiety, and post-deployment can create transition difficulties, particularly when the returning parent experiences post-traumatic stress. Having adequate support staff in school to address the needs of military students at all stages of deployment is critical, as well as having methods to help identify those students. Only a small fraction of military students attend Department of Defense Education Activity (DoDEA) schools, meaning the remaining students attend local public schools throughout the country. Military students attending public schools off of military bases may need additional support as they may feel isolated. By creating an additional funding category for LEAs who serve children and families in the military, it will help ensure that the needs of this particularly vulnerable population are met and increase their chances of graduating high school college and career ready.

Learning Supports

We appreciate the Department’s recognition of the importance of addressing family supports and students’ social-emotional and behavioral needs in education reform. However, we believe that district plans outlining how these supports will be delivered should be an Absolute Priority, instead of a Competitive Preference Priority, as is currently stated. Rigorous curriculum, high quality instruction and effective administrators are fundamental and critical aspects of education; however, recent research out of the National Center for Mental Health in Schools at UCLA has identified a third essential component: learning supports that address barriers to learning. Their research is clear; true progress in education reform and increased student achievement will only be met without a balanced focus on addressing barriers to learning and re-engaging students who have become disconnected from school. Creating positive conditions for learning and school climates that safe, supportive, and free of bullying, harassment and discrimination. Having effective teachers and effective principals that attend to the instructional, curricular and organizational needs of a school are necessary but not sufficient for maximizing student success. Schools must also prioritize identifying and responding to the social, emotional, and behavioral needs of students and provide access to qualified school employed mental health professionals like school psychologists, school social workers, and school counselors who support these students in school and connect these students and their families to additional community resources that are needed. These supports are most effective when delivered as part of a data based, problem solving motel utilizing multi-tiered systems of support. We urge the Department to require that every application for a RTT-D grant includes plans to address student supports and positive conditions for learning as an Absolute Priority.

For further information please see
http://www.nasponline.org/advocacy/news/2011/November/Briefing_Key_Messa...
http://smhp.psych.ucla.edu/pdfdocs/enhancingtheblueprint.pdf

School and Community Partnerships

NASP recognizes that school and community partnerships can play an integral role in improving student outcomes. Given the increased difficulty in meeting growing student needs, it has become evident that school-employed professionals cannot meet this demand alone; nor can professionals within the community. As a result, several systems have attempted to create collaborative school-community partnerships with the intent of sharing resources and providing comprehensive services to meet students’ academic and mental health needs. At present, however, existing models have little empirical research support, and often take on the ineffective practice of “co-location of services” (e.g., providing services in the same building without coordination among the various providers) rather than a true collaboration. We urge the Department to require districts applying for the RTT-D grant competition to explicitly outline how they will utilize school employed mental health professionals such as school psychologists, school social workers, and school counselors as part of collaborative effort with community partners to address student mental health needs. These school employed professionals have specialized training in addressing students’ behavioral, emotional, social, and mental health needs within the context of education and with the goal of re-engaging students so that they can perform to their highest potential. It is crucial that these school employed professionals be intricately involved in the coordination of school and community services and the facilitation of true collaboration among school and community based service providers. School and community partnerships that simply bring in services and providers without fully integrating into the culture of the school and the school staff will not result in the most positive outcomes for students.

Personalized Learning Environments

We appreciate the Department making the creation of personalized learning environments an Absolute Priority in this grant competition. This type of learning environment often results from the implementation of universal design for learning (UDL) strategies. The UDL framework calls for creating a curriculum that utilizes multiple means of representation, expression, and engagement to give students various ways to acquire information, demonstrate what they know, and keep students challenged. We urge the Department to explicitly include implementation of Universal Design for Learning strategies as it relates to school wide improvement strategies, design of assessments, and professional development in Absolute Priority 1. Assessments that incorporate these principles can provide educators with more accurate reflections of student achievement and help to more effectively remediate academic concerns. In addition, we ask that you include specific language regarding high quality professional development in the use of UDL strategies and practices for all teachers. This will ensure that all teachers will be able to gain skills to incorporate these strategies into their teaching methods and ultimately increase student achievement.

We thank you for the opportunity to provide input on the 2012 RTT-D grant competition. If we can be of further assistance, please contact Kelly Vaillancourt, Director of Government Relations at kvaillancourt@naspweb.org.

Comments from the National Public Education Support Fund on the US Department of Education’s Draft Race to the Top-District Program

The following comments are submitted on behalf of the National Public Education Support Fund (NPESF) to help strengthen the draft Race to the Top-District (RTT-D) notice published by the U.S. Department of Education. NPESF is a 501(c)(3) public charity dedicated to promoting equitable, high-quality public education in America to prepare each and every child for life, work, and citizenship in the 21st Century. Among our core projects, the NPESF regularly convenes a forum of approximately 30 leading education foundations focused on public policy. These comments are submitted by NPESF based on specific and deep discussions of the RTT-D notice held this week at a meeting of the New Models of Learning Working Group, representing a specific subgroup of foundations that share a set of common values and priorities that are closely aligned to the draft RTT-D notice, as follows:

- High quality education is an essential public good – critical to economic advancement and the foundation of a healthy democracy. Our country must maintain an emphasis on the broader public purposes of the education system as we push to improve and reinvent it.

- Our nation’s education system is at a critical moment of opportunity in education reform anchored in the now shared goal of all students graduating college and career (and citizenship) ready – as reflected in efforts like the Common Core State Standards. This means that all students (regardless of zip code or demographic profile) must master core rigorous academic content and deeper skills, such as critical thinking and problem solving, communication, collaboration and self-directed learning. These are higher and more meaningful goals for the nation’s education system.

- Achieving these goals for all students will require transformative, comprehensive, integrated systems change – in school design as well as in policy, practice, and public will. The nation cannot settle for incremental improvements or efficiency measures that simply squeeze a little more impact out of the current education system. These new models of teaching and learning must be based on evidence – for there is much we know about the theory/science of learning – and aligned to particular context. They must build on the foundations of standards-based reform as well as emerging proof points and global models. They must include a big shift toward innovation, rapid-cycle evaluation, and continuous improvement over time. Key elements will include a shift to student-centered, personalized learning (rightly defined), as well as related focus on project/performance-based learning, comprehensive supports, etc. In this context, the goals of equity and excellence (our high expectations for each and every child) must relentlessly drive the system.

Based on these shared aspirations for education, as well as the, evidence-based practices that will achieve them, we are very encouraged and supportive of the Department’s draft RTT-D notice – and the focus on districts and consortia of districts as agents for school redesign within aligned state systems. This represents an impressive and important step to expand upon recent state policy changes and promote more effective, scalable approaches to teaching and learning.

However, there are many important changes – big and small – that should be made to the draft RTT-D notice to more clearly focus its intent and more effectively drive the kind of reform the country needs. The working group discussion of education foundations raised several key points in this regard:

1. Elevate the focus on college and career ready, deeper learning outcomes to make those ends the driver of RTT-D efforts, and contextualize the focus on personalization. It is fantastic that the draft notice expressly mentions core knowledge and skills of college and career readiness (including critical thinking, problem solving, communication, collaboration, globally aware, and self-directed learning). The absolute priority and vision should more squarely rest on those outcomes as the driver of school redesign. With this goal clearly established, districts will see the shift toward student-centered models as a core means to that end.

2. Strengthen and align performance measures to those college and career ready, deeper learning outcomes. This is a challenge based on limitations in present measures (particularly until the consortia assessments are on-line), but each applicant should be asked to identify such measures, including research-based design of school/classroom performance measures as part of the grant. Further, RTT-D could include an eligibility requirement that grantees agree to participate in some common measure, such as the emerging PISA for Schools assessment, and we believe that a group of foundations may be interested in partnering with the Department and/or those grantees to help make such a common measure available. (The Department could further signal flexibility by waving other assessment requirements and allowing these common measures to be used for accountability purposes in participating schools.) Common measures of deeper learning would afford the Department a means to assess whether some approaches are working better than others and provide over time a sizeable set of evidence-based proof points of school redesign and district innovation.

3. Then, focus on a culture shift toward new models of learning, anchored in a stronger definition of personalization and a more complete, authentic approach to drive real change. The draft RTT-D selection criteria list many good attributes of student-centered school redesign, but they read like an incomplete checklist, and risk being approached by applicants in that way. To drive more authentic, robust proposals and transformative action (and not just a long list of commitments or add-ons), RTT-D should establish a short list of high-level design principles (such as timely access to data; aligned, high-quality instructional tools; performance-based assessments; competency-based pathways; collective capacity of educators; thoughtful use of time; integrated uses of technology; etc.) that underlie high-performing, student-centered systems, and then have districts propose a coherent, systemic strategy. That strategy would be: consistent with those design principles; rooted in local context and engagement; tied to a clear, evidence-based theory of learning and youth development; drawn from national and international best practice; designed to achieve and accelerate college and career ready, deeper learning outcomes for all students; and able to be scaled over time. This could be done in two phases: The first would focus on general district design, and the second could allow more time for deeper design from participating schools post-award (longer than the 100 days proposed and permitting a competitive process to identify schools if desired). This would require the establishment of clear milestones to monitor progress tied to use of second stage funding.

Further, personalization is a useful frame to drive redesign, but the current definition is too narrow. RTT-D should include a more research-based definition that includes the centrality of relationships between each child and adults in the school, which is essential to customizing instruction and supports to ensure each student’s success. Further, there are some key elements missing from the design principles laid out in the selection criteria. This includes the need for an express focus on project/performance-based learning, which is essential to ensure that personalization yields the kind of deeper learning outcomes the nation requires. This also includes a focus on how districts/schools will employ expanded leaning time and opportunities as key foundations for student success. Finally, the competitive priority on student and family supports (and community engagement in that regard) seems too attenuated. It should be made part of the core design principles in the selection criteria, and applicants should address those essential strategies as part of a coherent strategy..

There are emerging proof-point schools that are beginning to connect these dots and accelerate student outcomes, and other high-performing nations manage to embed and scale these models through a culture of systems change and continuous improvement. RTT-D could help catalyze this in the US context.

4. Affirm and strengthen the focus on continuous improvement, with additional focus on scale. RTT-D has the opportunity to advance another culture shift toward innovation, evaluation, and continuous improvement as the drivers of reform – in practice and policy. The sections of the draft notice related to transition plans/continuous improvement and district capacity/success factors should be maintained and strengthened to require a set of routine institutional habits evidenced as core aspects of district operations and infrastructure that include: processes for continuous reflection and improvement of educational approaches rooted in data/outcomes; processes for review and revision/removal of policies that impede progress; and plans for scaling successful models throughout the district or consortia (beyond sustainability of initial sites). One mechanism for fostering scale and continuous improvement is for preference to be given to districts that endorse development and use of open educational resources, which can in turn be widely disseminated. Finally, RTT-D district plans will live within and build upon rapidly changing state and federal policy conditions – including Common Core standards, new assessments, new accountability systems, new systems of educator evaluation, ESEA Flexibility plans, etc. These contextual realities should be accounted for and leveraged to advance the best district redesign plans.

5. Set requirements, criteria, and funding in a manner that provides maximum leverage both for strongest districts/consortia and those able to leverage RTT-D to leap-frog forward. Some of the proposed eligibility requirements in terms of core signatories, P-20 data systems, etc., could be read as too restrictive. A more expansive list of signatories/stakeholders and underlying conditions make sense as selection criteria, rather than absolute bars. Further, there have been some discussions that the proposed budgets may be too small for larger districts or consortia yet more than is actually needed to leverage action in smaller districts. The issue of grant award size merits further reflection.

We appreciate the opportunity to share these thoughts from discussions of leading education foundations, and look forward to continuing discussions and partnership on RTT-D.

Dear Secretary Duncan:

We write to express our strong support for the Department’s willingness to address race- and disability-based disparities within the Program Requirements for the Race to the Top District Grant (RTT-D). We commend you and Assistant Secretary Russlynn Ali for your leadership on this issue, and for your ongoing efforts to promote common-sense school discipline and address disparities. We also write to provide some suggestions for making the RTT-D an even more effective tool to address these issues.

Advancement Project is a national civil rights organization that works extensively with organized groups of youth and parents from around the country to address the foremost structural barriers experienced by students, and especially students of color, in obtaining a high-quality education. For over a decade, we have worked to address the combination of overly harsh school policies and practices and the overly-expansive role of law enforcement in schools. We have done so because they have been the most urgent needs identified by our grassroots partners. This “School-to-Prison Pipeline,” in which out-of-school suspensions, expulsions, school-based arrests, and juvenile court referrals are increasingly used to deal with student misbehavior, has pushed huge numbers of youth out of school and into prisons and jails, transforming many schools from places of learning to dangerous gateways into the juvenile and criminal justice systems.

Over the last few years, the Department of Education has taken significant actions to address the School-to-Prison Pipeline, most notably its Supportive School Discipline Initiative and the Office for Civil Rights' compliance reviews focusing on school discipline. We believe Program Requirement #4 represents another significant step forward for federal education policy. By requiring grantees to develop a plan to address race- and disability-based disparities within school discipline, the Department’s efforts would substantially benefit the nationwide effort to achieve greater fairness in this area.

We respectfully suggest that the positive impact of the RTT-D could be strengthened further if these priorities were included within the Selection Criteria for RTT-D, in addition to the Program Requirements. While there are Selection Criteria within the guidelines – such as the consideration of attendance rates and graduation rates – that will likely produce some favorable disciplinary outcomes, those effects will be limited unless school discipline itself is prioritized directly, and at the same level as other departmental priorities. In other words, given the existing criteria, RTT-D grantees could meet the other departmental priorities but still rely excessively upon harsh disciplinary measures and justice-system interventions.

Therefore we suggest the following changes to strengthen RTT-D:
• Include the consideration of race- and disability based disparities in school discipline within the Selection Criteria, such as in subsections (A)(2) or (C)(4).
• In addition to disciplinary disparities, include within the Selection Criteria and Program Requirements consideration of: (a) overall disciplinary rates; (b) the use of alternatives to harsh disciplinary practices; and (c) the willingness to engage in collaborative efforts with other stakeholders – including law enforcement and the judicial system – to reduce the use of justice-system referrals.
• Specify that school-based arrests and justice-system referrals are to be included within all discipline-related criteria.
• Require that applicants have fulfilled all Civil Rights Data Collection reporting requirements because, as you know, many LEAs have failed to provide the requested information, especially the school discipline data.

Additionally, we recommend the following to clarify Program Requirement #4:
• Specify that grantees would be required to both develop and implement a plan.
• Further define the required “root causes” assessment to include: (a) review of district policies and practices that may be contributing to disparities; (b) extensive analysis of data disaggregated by race, gender, age, grade, school, disability, offense, and disciplinary outcome; and (c) student, parent, and community input . Otherwise, it is our experience that the resulting analyses and remedial actions will likely be inadequate to address the totality of the problem within the grantee districts.

Thank you for your attention to these matters, and for your continuing efforts to address the harsh and inequitable disciplinary practices that continue to harm so many young people, families, and communities. If there is any additional information we can provide, please do not hesitate to contact us.

Sincerely,

James Eichner
Managing Director, Programs
Advancement Project

Jim Freeman
Director, Ending the Schoolhouse to Jailhouse Track Project
Advancement Project

On behalf of Communities In Schools, the 1.25 million young people we serve and the 180 affiliates across the country, we thank you for the opportunity to comment on the proposed Race To The Top-District Competition. As the nation’s leading dropout prevention program we appreciate the opportunity for districts to have direct access to these resources. Thank you for your leadership. Our comments will focus on the broad aspects of the program with some proposed language included for the final guidelines.

We are pleased the guidelines enable schools from all over the country to participate, either individually or in a consortium. However, the minimum requirement of 2500 students as a condition for consideration is a significant obstruction to the participation of rural schools and school districts. It is also contrary to Rural Schools Absolute Priorities 3 and 5. Many rural schools do not have 2500 students. We strongly encourage the department to remove arbitrary student threshold number of 2500 and replace it with the Department of Education definition of Rural Schools included in the Small rural School Achievement Program (SRSA) and the Rural and Low Income School Program (RLIS).

We commend the department for the inclusion of personalized learning environments as Absolute Priority 1. This approach is the central element of our research-proven model of integrated student services. We know, first hand, how the simple personalization and management of individual student needs reveal the relatively easy services or changes that oftentimes spell the difference between disengagement or high-achievement. Between dropping out of school, or graduating. It is this approach that has made us the leading dropout prevention organization in the country.

As you know, our specific model has undergone a rigorous evaluation that spanned over five years and involved our work throughout schools and districts. The conclusions of the evaluation prove that we not only decrease dropout rates, but we increase on-time graduation rates. This is something no other evaluated program in the country can claim. But, more importantly, central to college entry and completion, is high school graduation. This evaluation also determined our model is effective regardless of geography, student demographics and grade level. Meaning we work in rural, urban or suburban areas. Over 85% of our students receive free and reduced priced lunch and we serve over 80% percent minorities, in some of the poorest school districts in this country. Finally, this CIS Model when implemented is proven to have positive benefits on student- and school-level dropout rates, graduation rates, attendance, and academic performance, among the indicators being proposed in this new competition.

Beyond this logical alignment of integrated student services and the goals and requirements of the Race To The Top District competition, is a broader consideration: the economic impact of educational success. Given the turbulent economic times, educational success is critical to economic success. To that end, Communities In Schools has undergone another rigorous external examination of our model to determine the economic impact, particularly the social benefit of our work. This approach examined only our high schools based on the economists’ assertion that high schools would yield the most reliable evidence of the value-add of the CIS Model. By using high schools it was possible to ascertain the positive effects of promotion and on time graduation directly attributable to the integration of student services provided by Communities In Schools. However for purposes of our calculation, we used the entire costs of our network. This ensures a very conservative estimation of our impact.
It should also be noted that the results and benefits are not returned to CIS, but a return to society. This study yielded the following results calculated to present value:

• For every dollar invested in CIS Model of integrated student services, an economic benefit of $11.60 is generated to society. This is a tremendous value.
• The net present value of our high school serving affiliates is $2.6 billion. $2.6 billion is returned to society in benefits from each cohort of students we serve who graduate.
• The average annual return to society is 18.4%. Imagine the popularity of a stock or mutual fund that produced that return annually.

Research shows that integrated student services can improve graduation rates, lower dropout rates, and improve academic performance, particularly among poor and minority children. This proven model can be replicated in urban, rural and suburban districts and generate substantial economic benefits to society as a whole, while also representing a sound investment of public resources. The proven outcomes of integrated student services is directly aligned to the priorities of the Race To The Top District Competition, therefore we strongly believe that the following language an essential part of the Eligibility Criteria.
Under “Eligibility Criteria” number 4, insert the following:

“d. The LEA has implemented an integrated student services plan with a designated coordinator to implement this plan.”
Under “Definitions” add the following:

Integrated Student Services is a coherent and sustainable program with a designated site coordinator to coordinate and oversee implementation of services for students (including non-academic services) that may obstruct learning. These services should be provided on a school-wide basis as well as personalized, particularly among those students deemed most at-risk. The integration plan must be an evidence-based strategy with a moderate level of evidence that the program will have a statistically significant effect on student outcomes, including more than one well-designed or well-implemented experimental or quasi-experimental study. The provider may be a designated school employee or a nonprofit.

We thank you for the opportunity to comment on this proposed program.

Both racial and socio-economic diversity within each school are critical to the success for all of our students. Research supporting this is legion, with emphasis on equity, teacher experience and teacher retention, and student achievement. Yet it would seem that RTTT has taken no position on this in the disposition of its grants. My district, WCPSS, has recently received RTTT monies, yet for the second year running has and IS CREATING high poverty schools. Among the most egregious examples are Walnut Creek ES, which opened for the 2011-12 school year and has an 83.8% FRL rate, and Richland Creek ES, scheduled to open in the 2012-13 year with 55.5% FRL.
Please introduce a diversity component in the RTTT qualifications to encourage our districts to keep our student bodies as diverse as possible!

As a group of researchers, practitioners, and leaders of national organizations focused on increasing and improving aligned high quality education opportunities for young children from pre-kindergarten through third grade (PreK-3rd), we are committed to meaningful reform of both the K-12 system and the birth-to-five system. For this reason, we commend the Administration for funding and launching state-level RTTT reform initiatives, focused on K-12, and the Early Learning Challenge, focused on birth-to-five early learning systems.

To realize the full potential of K-12 and birth-to-five reforms, and to maximize opportunities to eradicate achievement disparities, school districts need to take an integrated and coordinated approach to meshing early childhood and K-12 reforms. Local school districts and their communities are the place where the proverbial rubber hits the road – K-12 and birth-to-five reforms must be implemented simultaneously in order to achieve a seamless education experience for children. It is at the local level that state-level standards, assessments, data, workforce strategies, school turnaround, and QRIS initiatives meet as districts and their community partners implement change.

We see a unique and promising opportunity for this RTTT initiative, targeted to school districts, to address both agendas – K-12 and birth-to-five. The draft guidelines, however, primarily address levers for change within the K-12 system. To bolster the possibility that applicants will be visionary and bold in aligning K-12 and birth-to-five reform agendas, we recommend changes to the guidelines.

First, the design includes several features that we applaud:
• The emphasis on personalized learning is refreshing and has long been a core value of early childhood education; extending this into the K-12 years is smart. Personalized learning plans should not only encourage educators to recognize the individual circumstances of each student – one’s interests, strengths, and areas in need of focus – but should also draw attention to the developmental progression that all children and adolescents experience as they move toward cognitive and social milestones. Research shows that attention to these developmental trajectories is often missing in public school policies today.
• The ability for applicants to tailor their proposals to specific grade-level bands provides an opening for local education areas (LEAs) focusing on PreK-3rd grade reforms. A growing number of school districts around the country recognize that unless they start children on a strong path of school success in these formative years they will be forced to play catch-up through expensive and less-than-effective remediation and retention policies.
• The inclusion of principals, superintendents, and school boards in evaluation systems is valuable for acknowledging the multiple administrative and governing forces that impact the education environment. In the PreK-3rd grades, school leaders are critical to building and sustaining seamless experiences for children as they move between pre-kindergarten, kindergarten, first grade, second grade, and third grade.
• In order to impact the greatest number of children, private-public partnerships are necessary for creating seamless connections between programs that enroll children in the early years, such as community-based preschools and Head Start programs run by non-profit organizations, and elementary schools. We agree that LEAs showing such partnerships should be given an advantage in the competition.

To strengthen the competition and to elevate the importance of bringing together bold reforms in both K-12 and birth-to-five, we recommend several changes that will ensure that LEAs that want to focus on the PreK-3rd grade band (or particular grades within that span) will be rewarded for a high-quality approach.

Assessment of teachers using student-performance data

While we recognize that the competition is designed to ensure that measures of student progress are tied to evaluations of teacher’s individual performance, we urge the U.S. Department of Education to ensure that LEAs consider contextual information that may affect teacher effectiveness. In addition to the effectiveness of the lead teacher, performance reviews at all grade levels should take note of how teachers, paraprofessionals, librarians, and other school staff work in teams, as well as the contribution of reading and math specialists and other interventionists in improving children’s outcomes. In the early grades, PreK-3rd grade, reviews should also incorporate information on the classroom composition, such as the ratio of children to adults and the proportion of children who have been enrolled in a high quality early learning setting before arriving in those classrooms (e.g., pre-K and full-day kindergarten). We also suggest that LEAs be encouraged to consider student data across multiple domains (including social-emotional development in addition to academic development) to avoid a narrow focus on just one or two skills, such as letter identification or the memorization of sight words in early literacy assessments.

Rewarding LEAs for ensuring equitable access across the PreK-3rd grade span

For LEAs whose proposals include the early grades, we recommend a stronger emphasis on the importance of expanding access to high-quality pre-kindergarten and ensuring access to a free full school day of kindergarten for all children. While every school district in the country guarantees access to first through twelfth grades to all students, this guarantee does not exist at the crucial early years of the education system. Because of this, before they even start first grade, many children have at least a year and a half less time in learning-based programs than their peers. This creates an inequitable starting gate for many children and applicant LEAs should be encouraged to address disparities in access.

We see a few ways to do this within the application guidelines. For example, section B on District Capacity and Success Factors currently requires LEAs to put together a “high-quality plan” that includes ensuring that at least 40 percent of participating students are from low-income families. At a minimum, that section could be extended to say that, if a district is applying to improve the education that children receive within, across, or including the PreK-3rd grades, the district be required to ensure that it has a plan for expanding access to pre-kindergarten (which can be done by not only through the addition of pre-K classrooms but also through partnerships with high-quality pre-K programs run by community-based organizations) and is committed to providing a full-day of kindergarten, free of charge, to all eligible students. As kindergartners are being held to Common Core Standards and kindergarten teachers are required to teach to those standards, it is only fair that they are afforded the same full school day that is unquestioned for their 1st through 12th grade peers.

Another place for a reference to full-day kindergarten is in section C on Policy and Infrastructure. If LEAs are to show that they have “learning resources and instructional practices” that are “fully accessible,” then an LEA that wants to improve the early grades should ensure that free full-day kindergarten is available to all students.

Inclusiveness and Coherence of P-12 data systems

In the proposal’s eligibility criteria, LEAs are required to have a “robust” data system with “the ability to match student level P-12 data and higher education data.” We suggest that this section recognize two elements: 1) the extent to which districts are connecting and aligning these data systems to their own state’s longitudinal data systems, as well as to national recommendations about high-quality data systems; and 2) the progress that some districts are making in including a comprehensive definition of ‘P’ in their P-12 data collection efforts. In addition to data on district-run pre-k classrooms, districts that recognize the full complement of their partners in pre-school programs are taking steps to include data from community-based preschools, child care centers, family child care homes, and Head Start centers. They should be rewarded.

About the Competitive Preference Priority – Results, Resource Alignment, and Integrated Services

We agree with the Coalition for Community Schools’ suggestions regarding the following minor changes to the language of the Competitive Preference Priority. We see a need for more emphasis on engaging and supporting families as part of these partnerships. And, like the Coalition, we see the need to include key community stakeholders in the development and implementation of the strategies described in the priority to ensure that community groups, such as those that provide early childhood services, are included. Borrowing language from the Coalition for Community Schools, we suggest that the department add the italicized words to this section:

Add “parent and neighborhood groups” to the list of public and private organizations in (1). Parent and community buy-in and participation are essential to successful implementation.
“(3) How the partnership will enable…the integration of education and other services…for participating students and their families”
“(4) How the partnership will build the capacity of staff in participating schools and staff of community stakeholders and partners… by providing them with tools and supports to”

We appreciate the paragraphs within the Competitive Priority section that explicitly mention “early learning programs.” To strengthen the possibility of partnerships with community-based organizations that run early learning programs, we suggest the following change to section (4) within the Competitive Priority (in italics):

(4) How the partnership will build the capacity of staff in participating schools (as defined in this document) and where applicable, participating early learning centers, by providing them with tools and supports to --

Suggestions for Section (4) on performance measurement

To respond to the department’s request for input on this section, here are some metrics that may indicate a “track record of success” for LEAs submitting applications focused on the early grades:
• indicators showing a reduced need for retention and remediation
• an improvement in the number of children reaching benchmarks for cognitive and social-emotional development in pre-K, kindergarten, first, second, third grade, and so on.

In closing, we reiterate our support for the Administration’s far-reaching efforts to influence bold reforms at both the state and district levels. We, though, strongly encourage the Department to use this Race to the Top – District competition to incentivize LEAs to better align K-12 and birth-to-five efforts. Aligning these two systems is crucial to closing achievement gaps. Failing to read at grade level by the end of third grade is a strong predictor of success throughout middle school, high school, and beyond. The vast majority of children (73%) who leave 3rd grade behind never catch up. To close achievement gaps, increase high school graduation rates, and ensure college success, we need to be sure that more children have a high quality start. This requires meaningful, strategic, and bold attention to both the K-12 and the birth-to-five systems. This RTT-D competition provides an exciting opportunity to recognize and reward the need for quality across the PreK-3rd grade years.

Sincerely,

The following members of the PreK-3rd Grade National Work Group (organizations listed for purpose of affiliation only):

Lisa Guernsey, director, Early Education Initiative, New America Foundation
Bridget Hamre, associate director and research associate professor, Center for the Advanced Study of Teaching and Learning, University of Virginia
Kristie Kauerz, program director of PreK-3rd education at the Harvard Graduate School of Education and the University of Washington
Chris Maxwell, director of the New Schools Project at Erikson Institute
Sharon Ritchie, director of FirstSchool and senior scientist at the FPG Institute at the University of North Carolina at Chapel Hill
Tonja Rucker, principal associate at the Institute for Youth and Families at the National League of Cities
Thomas Schultz, program director of Next Generation Learners at the Council of Chief State School Officers

To extend our response to the Department’s request for input on the section that addresses metrics that may indicate a “track record of success” (Section (4)), we suggest including indicators that will reflect district’s intentional and expanded efforts to prevent later school failure. For example:
• The number and percentage of participating children, by subgroup, who reach benchmarks for cognitive, social, emotional, and physical development in pre-K, kindergarten, first, second, and third grade.
• The number and percentage of participating educators who complete a survey that includes feedback on working conditions, support provided to them to differentiate instruction for diverse learners and to work together in teams (with other teachers in the PreK-3rd grade band, principals, and families).
• The number and percentage of participating children, by subgroup, who have sequential annual access (year after year) to effective and highly effective educators.
• The number and percentage of participating children, by subgroup, who are retained in the early grades (K-3) – with the goal being a reduction of these numbers.
• The number and percentage of participating children, by subgroup, who require remediation – with the goal being a reduction of these numbers.

The Directors of Health Promotion and Education (www.DHPE.org) or DHPE is a national non-profit association dedicated to protecting the public’s health by strengthening public health capacity in policy and in systems change to improve the health of all and achieve health equity. Our leadership in state health agencies is comprised of state health promotion and education directors, their staff and their many state and local partners including those in school systems across the country. DHPE emphasizes prevention as a national priority and supports science-based policies, practices and programs in states, communities, and schools. We believe prevention is the best solution to the health care crisis in this country. Furthermore, we believe the best, formative place for learning how to be healthy begins at home and in schools.
DHPE agrees in principle with the goal of Race to the Top; however, DHPE offers the following principles as evidence of its support for inclusion of health education curricula as criteria for RTT awards. They are:
• An educated citizen is one who has the knowledge and skills needed to contribute to society, care for him or herself, and make informed decisions.
• A major societal issue is the escalating cost of health care in the U.S., which is consuming more and more of the nation’s resources. To control these costs, educated citizens need to be informed consumers of health services and products and they must take responsibility for protecting their own health as well as making the communities where they live healthy for all.
• Therefore, as Race to the Top strives to use competitive funding opportunities to encourage quality education, it must include in the criteria that schools prepare students to be educated citizens who are informed health consumers and who take responsibility for the health of themselves and others. A robust health education curriculum reinforced by infusing health topics and issues in other academic areas should, therefore, be criteria for RTT awards. The National Health Education Standards provide a grade-level guidance for what a robust health education curriculum would achieve.

Healthy Schools Campaign is honored to submit comments to the Department of Education for their Race to the Top District competition. We believe that this program is an excellent opportunity to promote reform and innovation and emphasize the integral connection between health and learning.

The link between health and learning is clear. Healthy, active, and well-nourished children are more likely to attend school, be engaged, and be ready to learn. However, the school setting often does not support health. Too many students spend their days in buildings with unhealthy air, limited opportunities for physical activity, and inadequate access to fresh water, nutritious food, or a school nurse. Many students come to school with one or more health problems that compromise their ability to learn. The prevalence of chronic diseases—including asthma, obesity, and diabetes — has doubled among children over the past several decades. This has implications not only for children’s long-term health but also for their opportunities to learn and succeed at school. This challenge is especially critical in light of the nation’s vast health disparities. Low-income and minority students are at increased risk of health problems that hinder learning and are more likely to attend schools with unhealthy environments. Unless we address these disparities in health status and school environments, efforts to close the education achievement gap will be compromised.

To truly support learning, schools must create the conditions for health. Given the strong connection between health and learning, schools must recognize health as central to their core mission of student learning. That means creating a healthier school environment, which supports students’ well-being and builds a foundation for learning. In this environment, good nutrition, physical activity, basic safety, clean air and water, access to care, and education about how to make healthy choices allow students to thrive. In a healthy school environment, students learn—through lessons and through example—to value their own health and wellness.

It is for this reason that Healthy Schools Campaign and Trust for America’s Health launched Health in Mind: Improving Education Through Wellness. This effort focuses on policy recommendations for immediate, practical changes at the federal level to help close the achievement gap and create a healthy future for all children. Healthy Schools Campaign and Trust for America’s Health engaged over 100 stakeholders in the development of these recommendations which were presented to Secretary of Education Arne Duncan and Secretary of Health and Human Services Kathleen Sebelius at a public event on May 9. We invite you to learn more about the initiative and recommendations here: http://www.healthyschoolscampaign.org/healthinmind.

Our comments below identify several important areas in the Race to the Top District competition where the connection between health and learning can be emphasized and align with the recommendations issued through Health in Mind.

1. Absolute Priority 1, Personalized Learning Environment: Including student health and wellness in Absolute Priority 1 will ensure that participating districts implement policies and practices in support of student health and wellness. We recommend updating the language to the following: “…create student centered learning environments that are designed to: address student health needs, significantly improve teaching and learning…”

2. Selection criteria: We recommend that health and wellness are integrated throughout the selection criteria in the following ways:
a. Include student health in the vision by adding “g. student health” under A.2.
b. Under C.1.a.v. change the language to “Develop skills such as goal-setting, teamwork, critical thinking, communication, creativity, problem-solving, and healthy lifestyles.”
c. Under C.2.b.i. change the language to “Actionable information that helps educators identify and respond to individual student academic, physical and emotional needs, optimal learning approaches, and interests.”
d. Under C.2.c. change the language to “All participating school leaders and school leadership teams have policies, tools, data and resources to structure schools as effective learning environments that meet individual student academic, physical and emotional needs…”
e. Under C.3.a. include an additional sub-point that says “The opportunity for students to lead healthy lives.”
f. Under C.3.b. include an additional sub-point that says “Ensuring that all participating students, parents, educators and other stakeholders have equitable and sustainable access to space that supports physical activity, healthy food, and school health services.”
g. Under C.4 include the following metrics:
i. The number and percentage of students with daily access to physical education.
ii. The number and percentage of students with daily access to a school meal that meets the HealthierUS School Challenge Gold criteria.

2. Competitive Preference Priority: We recommend including an additional competitive priority that awards applicants points based on the extent to which their proposal integrates health and wellness and supports the health and learning connection. Examples of projects that would meet this competitive priority include developing and implementing a professional development program that educates teachers about healthful classroom management strategies; increasing the number of school nurses in the district; and developing a recognition program to reward schools that implement policies and practices that promote healthier school environments.

3. Definitions:
a. The definitions for principal evaluation system, school board evaluation and teacher evaluation system should include an additional point that says “how principals/school boards/teachers support health and wellness.”
b. The definition of student survey should be changed to the following: “Measures students’ perspective on learning, teaching, opportunities to make healthy choices, and related supports in their schools…”

We thank you in advance for your consideration of our comments.

Healthy Schools Campaign

As a parent, as well as a professional involved in various aspects of children and familiy services, I support Race to the Top, and urge the inclusion of early chilldhood, including services for infants & toddlers, as a key target area. I feel strongly that priority in approving grants from the states should be given to programs that include early childhood education in their plan.
Thank you for your interest in receiving opinions and ideas from those of us who have a vested interest in the improvement of educational opportunities for all students in public education.

Please be sure to stress the importance of school climate plus social, emotional and character development (SECD). These have more influence on a child's success than test scores. We need to be raising good citizens!

Please extend the funding for early education.. If we don't consider the importance of the children and early intervention we've have alot of children slipping thur the cracks.

Define:
• Individualization
Does this mean that students are being taught one-on-one on a daily basis (as in with their own educational plan entirely)? Does this mean that teachers simply need to focus on addressing each student’s needs in a given class as much as possible?
• Rural
As the definition of rural is relative, this needs to be made clear so that districts know in what category they belong. Will subcategories (of district size) be considered?
• Move at your own pace
Can students skip grades or earn credits in more or less than a year? Does this mean that students can be pushed faster than others, but only within the given class (i.e. the faster students go through the entire Algebra book while others may only get through half)? As with the problem of individualization, is district funding considered with this issue? What if class size is twice that of other schools and individualization is less practical given the resources available?
Modify:
• The minimum size of the district
There is no need to exclude many districts because of size. The potential budget should not be tied to district size because it does not take into account student needs.
• The rules for small or rural districts, especially in extremely rural regions
Smaller districts can benefit from these programs but do not have the resources to meet all of the requirements of the application. Modifying the rules to allow smaller districts to apply with plans to meet some of the requirements (i.e. attendance, graduation rates, etc.) would open the competition up to many more districts.
• The requirements for community support
The application should take into account the size of communities; some areas do not have enough businesses or nearby colleges to provide students with support and/or outreach opportunities.
• Address the requirements and variations among state tests
This application does not take into account the differing requirements of state tests or the pressures on certain districts to raise test scores at the expense of all else. How can individualized student plans fit in with the requirements of passing state tests?

The vision of the selection criteria is to increase college enrollment rates for students graduating from a LEA. We would suggest including military enlistment, career, vocational, and technical schools to the graduation criterion (paragraph A 2d). In addition to expanding the college enrollment qualification, we also suggest expanding the teacher attendance requirement to include administrative and support staff (paragraph A 2f). The eligibility criterion includes training for teachers, administrators, and students. We suggest to including parent training and development into the criterion. “All parents have (training) access to and know how to use tools, data, and resources to accelerate student progress toward meeting college and career ready graduation requirements”. Under the budget section, we suggest removing minimal budget requirements. In addition, we suggest adding a district size of 500-2500 students with a cap of $12 million. Lastly, we would ask the committee to clarify if the consortium will allow for the development of private foundations?

Thanks for allowing us to comment on the Race to the Top District (RTT-D) program. We applaud the Department of Education (Department) highlighting the importance of high quality educational resources for students and teachers, prioritizing personalized learning environments, and championing data-driven education. Creative Commons is a 501(c)(3) nonprofit corporation that provides free licenses and legal tools to mark creative and educational work with the freedom the author wants it to carry. Creative Commons copyright licenses and legal tools are the global standard for sharing Open Educational Resources, or “OER.” OER are teaching and learning materials that reside in the public domain or are released under a copyright license that allow users to reuse, remix, repurpose, and redistribute high quality educational content. The Department has made OER a priority in its discretionary grantmaking, and Secretary Duncan has underlined various benefits of OER, saying “Open Educational Resources can not only accelerate and enrich learning; they can also substantially reduce costs for schools, families and students.”

Insofar as the RTT-D program will fund the creation of educational materials, we urge the Department to adopt a policy identical to that of the Department of Labor’s (DOL) Trade Adjustment Assistance Community College and Career Training grant program (TAACCCT). That initiative requires that educational content created from grant funds be licensed under a Creative Commons Attribution license (CC BY). The DOL policy says:

“In order to ensure that the Federal investment of these funds has as broad an impact as possible and to encourage innovation in the development of new learning materials, as a condition of the receipt of a TAACCCT grant, the grantee will be required to license to the public (not including the Federal Government) all work created with the support of the grant (Work) under a Creative Commons Attribution 3.0 (CC BY) license. Work that must be licensed under the CC BY includes both new content created with the grant funds and modifications made to pre-existing, grantee-owned content using grant funds...This license allows subsequent users to copy, distribute, transmit and adapt the copyrighted Work and requires such users to attribute the Work in the manner specified by the grantee.”

This is sound public policy. The $2 billion TAACCCT program’s CC BY open licensing requirement will help maximize the impact of the grant funds expended, and the $400 million Race to the Top District Program can realize similar benefits by adopting the same policy. In this way, other states, LEAs, and teachers and students will be granted broad access and reuse rights to the creative educational content that is created as a result of public tax dollars. Some other states have already been working to adopt open policies that leverage Creative Commons licenses. For example, California has moved a bill through the Senate that would spend $25 million to create the 50 highest enrolled college open textbooks and make them available under CC BY for students. Washington State passed legislation and provided $200,000 per year to support OER in K-12.

The RTT-D competition requires that applicants address personalized learning environments as an absolute priority. Openly licensed educational content (such as content licensed under CC BY) can be legally adapted and customized for individualized instruction. The CC BY license gives teachers and instructional designers permission in advance to repurpose educational content such as textbook chapters, lesson plans, multimedia materials, and interactive content. This simple fact can be a huge benefit to time-strapped teachers aiming to customize educational content for a student’s individual learning plan. Ensuring that educational resources created as a result of RTT-D funds are made broadly available for creative reuse under open licenses empowers educators, giving them the high-quality learning resources, processes and tools to accelerate student progress.

It should also be noted that the CC BY license grants the same rights to commercial publishers to take content that is created with taxpayer funds, add value around those materials, and sell them. If commercial publishers are able to create a superior product that schools and districts find valuable, then they will pay for those services from traditional publishers.

The Department’s request for input on the RTT-D program makes a special mention that successful grant applicants will be able to build personalized learning environments that contain “high-quality content aligned with college- and career-ready standards...frequently updated data about individual student progress, and intervention support options” (6). It should be noted that the adoption of Open Educational Resources does not prevent applicants from meeting this goal. In fact, currently there are OER producers, such as OER Commons, CK-12 Flexbooks, and Curriki that build and distribute Open Educational Resources that are pre-aligned with standards such as the Common Core State Standards.

Thank you again for providing this opportunity to provide feedback on the Department of Education Race to the Top District Program. We would be pleased to answer any follow up questions you may have.

The i3 grants were offered not only to districts but also to groups of schools organized into consortia of like-minded schools--schools that most often had a shared philosophy and approach to teaching and learning. We feel strongly that the targeted RTTD pool of applicants should be expanded to include such consortia of schools and predict the DOE would receive a much greater range of innovative and creative proposals if it did so.