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

At the 11th hour, I felt compelled to add my comments on the defining issue of our time in American culture in youth education - and, I am also responding to a comment from an individual (May 25th) who referred to Finland, my homeland. Bear in mind, that I am presenting a point of view as a mother of teen-age boys, who are currently in HS in Hartford County, CT. And, I am a humble painter and scenic designer, not a policy wonk, or an apparatchik of any education department anywhere, although, someone just Googled my letter that I wrote to the State of CT concerning funding for magnet schools several years ago. Lastly, my biggest concern is that the idea of racial/ethnic/socio-economic isolation is hardly discussed.

I will cover 3 things: Why thinking Finland and the Finnish ways, may not work for the educational endeavors of the USA; What positive ideas may work - from the point of view of a dual-national and a global traveler; and, lastly, What my own ideas are to try to constructively add to this complicated formula called Race to the Top. WHAT AN UNFORTUNATE NAME, folks, by the way! Why did someone think that this was a smart idea?...it immediately stirs up the notion I have acquired over the decades, that the USA is always about competition, striving against teams, sports, winners & losers? My husband is an espn director, and, I have been forced to endure a lot of the zeitgeist about the American phenomenon of sport in its culture, but, seriously? "Race to the Top," IS SO SAD; I feel like: Everest is too @$#^$&# high, and I know I am not in good enough shape to make it! ...it feels like a reality show where only the luckiest "team?" in the RACE TO THE TOP will win. Well, enough semantics!

Why do I think I can contribute to this intense dialogue?

1. I am an immigrant (1968) and arrived with NO English language skills into first grade in Roosevelt, LI, in New York; later, continuing in P.S. 104 (Bay Ridge, NY,) and, graduating from HS in NJ.

2. I live in CT, where we have the worst achievement gap in education. I read all articles about education and about this huge, continuing dilemma the USA faces, with regard to the achievement gap. I think about how to fix education constantly.

3. My son attended Hartford's flagship magnet school in the middle school years.

4. I tutored and worked with Upward Bound students in Middletown, CT during my college years.

5. I am a 7th-generation university-educated individual who speaks 4 languages. I have a Master's degree, and I am just about to send all 3 sons, one after another, to university, somewhere; simultaneously, trying to magically, pay for their educations.

6. my mother is a retired English & German teacher (in Finland) and, we talk about the state of education in USA all the time. My late father was an entrepreneur who years earlier, taught at MIT in early 60's (a visiting instructor.)

Let's start:
Why Finland's Success (highest PISA score for a Western country) may not work in the USA
_________________________________________________________________________

Children are considered a national resource in Finland (officially recognized as such after WWII) so, education is the #1 focus of the country...basically, happy, thriving families survive, contribute, and perpetuate a civil society. Part of this idea is inherent in the Arctic culture of survival against the elements. However, the amount of taxes that individuals and families pay in this social democracy, varies according to income & assets, and, many Americans would be loathe to pay as much as 50% of their earnings per annum to the state.

As my cousin, a social worker says, " everyone pays, everyone gets." Also, I know several millionaires and even some billionaires who continue to live in their homeland and pay their proportion of taxes in Finland, so, Finland, a "social democracy" is NOT socialist. It bothers me that so many Americans don't understand this distinction, or how each Northern European country has a slightly different system, numerous political parties, specific tax rules/systems.
So, Americans probably would not want to pay a higher proportion of their taxes to the govt, since the mood of the USA overall, is to cut taxes, continue to let dividends be taxed at 15% or less, accept substandard EVERYTHING. Let me tell you, Finland allows you to prosper, AND, you have cradle-to-grave health insurance, free education for trade schools, "community colleges" (it's a different title) and University. Companies do not have to have to worry about "benefits" to employees, so they can just get better and masterful (look at the profits of the German companies.) However, I don't think Americans will ever be able to stomach the idea of paying more taxes...especially, since EVERYONE who has a job, pays taxes in Finland. But, Finland has awesome and attractive infrastructure, UNBELIEVABLE technology & telecommunication, healthy/robust economy (incl, banking sector, ) beautiful homes and landscapes, fantastic arts, amazing, protected nature...if only it was not so cold 9 months a year!

Teachers are highly educated in Finland. They have Master's degrees, and, they were all in the top 10% of their HS. If you are not in the top 10% you must realistically analyze what you are good at by 16, to chart a path into either a vocation, or consider what education you need to have, or to go with your talents and aspirations. So, it is a lot crueler for young people, in some ways. However, I know so many people who did not go to any of the national universities in Finland or Sweden, and they have created all kinds of interesting businesses and successful entrepreneurships. Even hockey players go to their own special HS to go on to get a diploma first, than a job with the NHL...and keep their citizenship and become good tax payers to their beloved country even if they live in NY and play for the Rangers.

Finland has gotten a lot more diverse in the last 20 years, but that's another topic. But, I must mention that Finland has actively thrown a "welcome" mat down for all foreigners looking to get a PhD., Master's. There is a certain amount of merchants, and a smaller portion of refugees, that has brought a significant change...but the schools are just humming along regardless.

Every HS in Helsinki, for example, is a "magnet" school, in that one needs to apply to a school that has the curricula the student is interested in. There are STEM, Swedish language, 2 English language. liberal arts, performing arts, visual arts, communication arts, etc. HS's all through out the greater metropolitan area, and, students apply to them at the end of the traditional secondary school, 9th grade - the HS is 3 years. Most students are 19 when they graduate, as you MUST be 7 to start 1st grade, no exceptions.

So, overall, the taxes that are acceptable to Finns, would freak people out in the USA.

What could work:
______________

The idea of the Magnet Schools for the last 3 years (it's called a B.A. in Finland.) is something that is already working in the USA. Students should be identified by 15/16 by what kind of learner they are, and where are their talents and abilities most concentrated...Finland does this well, USA should follow this. It is, I guess, part of the idea of "personalizing" the learning style, pace, content, etc. I feel that a city like Hartford, should only have Magnet Schools & Charter schools...Similar to Stuyvesant & School, or Performing Arts in NYC. Increase the # of true magnet schools.

Gearing the learning to the cultural diversity in the classroom: As Finland has gained some diversity, they can no longer go on and on about their own national history in the primary grades; they have begun teaching history that is relevant to all the global areas their students come from. Developing a curricula that pinpoints the highlights of every students' cultural roots, excites students. Also, everyone learns something new.

All teachers in Finland must follow the same subject matter on the same week.....they just can develop their own style for that particular lesson. A friend of mine, a world history teacher, has jaw-dropping projects, re-enactments, lectures, etc. whenever the thought moves him, or when he thinks he can get the kids to "get it."

Finnish kids stay after school for their activities; they ride the regular city bus (free student ticket) home just about the time that mom comes home, exhausted from work. Homework is relatively light in Finland...another story.

What I think:
__________

Racial and socio-economic isolation will continue with the subsequent achievement gap, if kids continue to be segregated for these reasons. Something must be done nationally, that we are not a country of "good schools," and, what? - "bad Schools." Years ago, my mother learned that real estate agent 'speak' for "good school system," meant not so many poor people, minorities, etc.

i went to fully integrated primary schools, and, they were great. I went to a HS that was only 8% minority students, BUT, everyone of those students graduated, and went on to live fabulous lives....many my FB friends . I think that schools in this country need to rethink how they integrate the minority students and poorer students that are isolated because of housing, zoning laws, etc.

whoops, ran out of time!

to finish up my ideas:

I will use Hartford as an example:

- Continue with, and create true theme-based magnet schools to attract many area students.
- Use former school buildings as after-school academies for HW/Library time/activities/arts programs/tutoring/clubs
- Have surrounding University students conduct the academies and enlist more university students to be involved in the primary & secondary school process during their university education.
- Focus on each student's interests, abilities, and needs.
- provide a program, complete with dinner, until the student goes home in the early evening.
- get more private schools to accept the very gifted students; get more suburban HS' to accept more "choice" kids.
- create a school like Stuyvesant HS.

......running out of time.

The Data Quality Campaign (DQC) submits these comments in response to the US Department of Education’s (ED) draft requirements, priorities, selection criteria, and definitions for the Race to the Top District (RTT-D) competition.

DQC applauds ED for including the following components of the proposal:

  • Data is acknowledged throughout the proposal as a critical tool for students, parents, and educators to use to inform student-centric teaching and learning.
  • Data is a means to an end, and too often federal policies ignore the data implications or demands of specific strategies. The proposed criteria appear to acknowledge the data implications of its requirements by requiring districts to put in place certain data systems capacities. [Our concerns about the specific approaches to the data requirements are discussed below.]
  • Data cannot be leveraged to inform decisionmaking if stakeholders lack access to timely, actionable information and the training to use it effectively. The proposed language calls for providing leadership teams, educator teams, parents, and students with data, acknowledging that all of these stakeholders need training and support to ensure they have the data literacy skills to understand and use available tools and resources.
  • Local education agencies (LEAs) and schools need support implementing best practices to comply with federal and state privacy and security policies and protect student information. The RTT-D language acknowledges that critical need by requiring applicants to work with ED to put in place deliberate implementation plans that address those issues.
  • Culture change is the most difficult part of any continuous improvement process. The RTT-D language acknowledges that putting in place tools is not the same thing as creating a culture that embraces the effective and appropriate use of data to inform decisionmaking. As such, it asks applicants to indicate how the implementation plan will translate into meaningful reform and support districtwide change. It will be difficult for grantees to demonstrate and the federal government to monitor these kinds of outcomes.

Specific comments and recommendations to strengthen the proposed language:

Federal policy should seek to make education policies more coherent and streamlined, reinforce state and district alignment, and reduce burden where possible. Throughout the application, the RTT-D language can be strengthened to ensure LEAs are aligning with and leveraging state efforts where possible.

1. Aligning with and leveraging existing state policies and efforts.
Federal policymakers, through legislation and administrative action, have already embraced a theory of action (through the America COMPETES Act, the American Recovery and Reinvestment Act, and the Statewide Longitudinal Data Systems Grant Program) supporting state education agencies (SEAs) to build specific data capacity and advance statewide data practices to ensure consistency, quality, and efficiency. While the RTT D language pays significant attention to the data capacity needed to implement some of its requirements, the language also may unnecessarily require or encourage LEAs to re-create data capacity that is already in place at the state level or that LEAs, particularly smaller and rural LEAs, may not be well positioned to create. This could unintentionally encourage districts to replicate or circumvent current state efforts, create unnecessary burden, or unnecessarily take LEAs out of the running for the program.

ED’S PROPOSED LANGUAGE
As a part of selection Criteria, (B) District Capacity and Success Factors, applicants must describe the state context in which the applicants will be lawfully implementing the proposal.

DQC OBSERVATION OR RECOMMENDATION
Given the extent of the data implications, ED should include in this section a requirement that applicants describe how they are leveraging existing state data systems and tools to support implementation of their plans, if applicable.

2. Educator evaluation systems and related data capacity.

DQC does not take a position regarding the implementation of teacher and principal evaluation systems, the consequences for individual educators as a result of those policies, or the federal role in leveraging them. However, DQC does encourage policymakers and education leaders at all levels to ensure that when such evaluation systems include student performance data as a factor, steps are taken to ensure that indicators used are comparable across systems and that the data and the teacher-student data link are accepted as high quality, reliable, and fair by critical stakeholders—particularly teachers.

ED’S PROPOSED LANGUAGE
ED’s proposal includes among the eligibility requirements that the LEA has designed and committed to implement no later than the 2014-15 school year:

  • Teacher and principal evaluation systems that use student growth as a significant factor
  • A robust data system that has an individual teacher identifier with a teacher-student match

DQC OBSERVATION OR RECOMMENDATION
ED has already embraced a theory of action through the America COMPETES Act, the American Recovery and Reinvestment Act, and the Statewide Longitudinal Data Systems Grant Program that state education agencies should implement statewide practices for a unique educator ID and a robust teacher-student data link (TSDL). As states have worked to implement a robust TSDL, a set of promising practices have emerged to develop a statewide teacher of record definition, ensure the ability to link multiple teachers to students per course, and ensure accurate and up-to-date data through a roster verification process and multiple data collection periods.

LEA applicants should be required to align with existing statewide practices where they exist. For example, all states have implemented a unique educator ID, and 25 states have implemented a statewide teacher of record definition. If their state does not already have in place a teacher evaluation system or statewide TSDL practices, LEA applicants should be encouraged to address similar emerging practices and to engage stakeholders in the process of developing the data policies and practices related to these evaluation systems to ensure quality and buy-in.

The desire for implementation of principal evaluations based on student performance data is an emerging area; applicants should keep in mind the sequencing of the availability of student data from state assessments and personnel decisions.

Recommendations:
The RTT-D language should ensure that applicants, where possible, align with and leverage work already happening at the state level:

  • Require LEA applicants to use statewide unique educator ID (if available).
  • If the state has provided statewide parameters around TSDL practices, require LEA applicants to demonstrate they are complying with those practices.
  • If the state has not implemented statewide parameters around TSDL promising practices, require LEA applicants to address those practices as part of their plans.

3. Matching K–12 and postsecondary data and performance metrics.

DQC does not take a position regarding which performance metrics or performance targets should be required as part of a given program. However, DQC believes public transparency around performance metrics is an important component of any policy effort. Moreover, performance metrics should be carefully selected and designed to measure the intended outcomes of the effort, and they should be comparable across systems. Federal and state policymakers should take steps to ensure critical performance metrics are commonly defined, made transparent and accessible to the public, and designed and collected in a manner that limits collection and reporting burden.

Matching K–12 and Postsecondary Data

ED’S PROPOSED LANGUAGE
Eligibility requirements: That the LEA has designed and committed to implement no later than the 2014-15 school year, robust data systems with the ability to match student level P-12 and higher education data.

Selection criteria, vision: The extent to which the applicant's vision will translate into increased improved student performance and equity as demonstrated by ambitious yet achievable annual goals on specific indicators, including college enrollment rates.

DQC OBSERVATION OR RECOMMENDATION
We assume that the proposed RTT-D eligibility requirement related to P–12 data linkages is included for the sole reason of ensuring that that LEAs have the data capacity to produce college enrollment rates for demonstrating progress toward the ambitious and achievable annual goals.

ED has already embraced a theory of action through the America COMPETES Act, the American Recovery and Reinvestment Act, and the Statewide Longitudinal Data Systems Grant Program that state education agencies should link P–12 and higher education data. In fact, states are already required to report college enrollment rates by high school and LEA under the State Fiscal Stabilization Fund program (this applies to all 50 states and DC) and the 2012 ESEA flexibility for those states that have received them.

It is inefficient and duplicative to require districts to develop independent data systems’ capacity to collect, match, analyze, and report this data. While some large urban school districts have worked with local college systems to develop data sharing agreements, most LEAs have limited capacity to address the political, legal, and technical barriers to securing higher education data themselves, particularly for long-distance, out-of-state, and private institutions that their graduates may enroll in. Even if LEAs work with a third-party vendor (such as the National Student Clearinghouse) to secure this data, it is a different strategy than the proposed language’s mandate to implement an LEA data system with the ability to match student-level P–12 and higher education data itself.

Recommendations:
The RTT-D language should ensure that applicants, where possible, align with and leverage existing state-level efforts:

  • Eliminate the eligibility requirement for LEAs to implement a data system with the ability to match student-level P–12 and higher education data.
  • ED should clarify how it can make use of existing state reporting requirements and federal collections to support efficient production of college enrollment rates.
  • If the requirement for LEAs to report this information themselves is maintained, require LEAs to indicate if they are not currently receiving this data from the state, and if so, describe their alternative method to secure the data.

Performance Metrics

ED’S PROPOSED LANGUAGE
Under Selection Criteria, Vision (A), paragraph (2), the proposal indicates the applicants vision must demonstrate how it will translate into progress towards annual goals for improving performance on summative assessments, decreasing student achievement gaps, graduation rates, college enrollment rates, student attendance, and teacher attendance.

Under Selection Criteria, Preparing Students for College and Careers (C), Performance Metrics (4), the proposal lists a different set of indicators for which the applicant is to establish annual goals including rates of access to highly effective educators; on-track to college- and career-readiness rates; rates of accessing personalized learning plans; graduation rates; teacher survey completion rates; and students survey completion rates.

DQC OBSERVATION OR RECOMMENDATION
Recommendations:

ED should:

  • Clarify the relationship between the indicators listed in the Vision section and those in the Performance Metrics section.
  • Clarify if and how grantees will be required to report—to ED and to the public—the final performance metric.
  • Describe how it will reduce reporting burden by utilizing existing state reporting requirements and federal data collections to streamline the collection and reporting of the final performance metrics.
  • Consider if grantees can receive relief from any existing data collections as a benefit to participating in this program.

A version of these comments can be found on the DQC website at http://www.dataqualitycampaign.org/resources/details/1603.

From the Executive Summary: The Department is particularly interested in seeking public input and suggestions on rigorous, relevant,
and actionable performance measures that will assist grantees and the Department in managing both leading indicators of implementation success and outcome measures of performance."

Instructional quality is readily measurable through precise classroom observation and large-scale collections of completed student work.

Academic engagement time (the percentage of time that students appear academically engaged) can be measured to reasonable precision and accuracy using technology featuring sophisticated timing controls (See PDF article #ED519030 in the ERIC database). The use of research-based teaching strategies (e.g., cognitive strategies, scaffolding, modeling) can also be measured by digitally recording the appearance of such strategies in live classroom sessions. The combined results from all such data points can generate a productivity index that specifially targets only in-class behaviors. (ERIC #ED516290)

Student work collections can be analyzed for alignment to state/Common Core standards and cognitive rigor (ERIC #ED517804). Furthermore, the ability of a taught curriculum to sufficiently sample the topics in pacing guides and state assessments can be measured quantitatively (#ED516362). As with classroom observations, such results can generate an overall productivity index that specifically targets the quality of the enacted curriculum.

One could even combine the curriculum and instruction indices to generate an overall index. The measures needed to improve the overall index are clearly defined, align to potential professional development, and within every teacher's direct control.

Dear Secretary Duncan:

We appreciate your invitation to submit comments in response to the Department’s proposed criteria for the FY12 Race to the Top district (RTT-D) Competition. We applaud your leadership in launching RTT-D and strongly support this initiative. In California, districts are leading innovation in the key areas which RTT-D promotes, and we expect that the proposed competition will drive the acceleration and scaling of this work. To optimize the impact of RTT-D, we offer several suggested revisions.

The proposed design would require that a State’s college- and career-ready content standards be either (1) common to a significant number of states or (2) approved by a State’s network of higher education institutions. While this may be an appropriate minimum baseline for applicants, the selection criteria should seek to leverage much more robust outcomes that make true readiness for both college and career (and not one or the other) a reality for all students. As you know, the Common Core State Standards (CCSS) emphasize ELA and math as the benchmarks of readiness, but postsecondary institutions look at a variety of academic subjects in determining college readiness, and even ELA and math expectations for postsecondary institutions are not yet fully articulated with the CCSS standards. Applicants that extend college readiness beyond CCSS and will articulate directly with postsecondary institutions should have competitive priority.

Secondly, both college- and career-ready definitions (CCSS and approval by a network of postsecondary institutions) address academic competencies and do not explicitly reflect career readiness. RTT-D standards for career readiness should be expanded in order to reflect the skills, competencies and dispositions which are vital to success in the workforce. Career-ready content standards vary greatly among states and districts, and RTT-D should encourage and reward more meaningful approaches to (and measures of) career readiness, especially when integrated with college readiness.

This approach would be more consistent with achieving the objectives of the President’s initiatives for Career Academies and for College Pathways & Accelerated Learning, the principles of which are not reflected in the current draft RTT-D proposal.

This is ambitious but achievable for districts many of which are already moving forward with performance outcome measures which would support the evaluation of RTT-D implementation success in the career-readiness dimension, such as:

• Industry certification or licensure, or prequalification for post-secondary/industry training programs. These are pre-requisites for employment eligibility in many skilled sectors, thus they serve as a good indicator of career readiness in industries which utilize these processes.

• Assessments of applied, career-relevant competencies (such as ACT’s WorkKeys assessments or state-developed occupational assessments). Such assessment tools not only test academic competency but also assess technical skills, workplace skills, and one’s ability to think critically in workplace-relevant situations.

• Work-based or project-based learning which addresses the mastery of career-technical content standards established in collaboration between the SEA and representatives of industry sectors. Applied learning experiences, if developed around content expectations which are aligned to both classroom and workplace needs, are excellent measures of content and skill mastery.

• Industry-aligned career-technical pathways, with curricular content standards developed through collaboration of the SEA and industry representatives. Because they are developed to be academically and technically rigorous, and focus on industry sectors, they provide an excellent foundation for both college and career readiness.

Several California districts are leading the nation in preparing students for college and careers with an approach called Linked Learning, which integrates rigorous college-preparatory and career pathways in both curriculum and pedagogy, along with personalized learning support services. In addition to grade bands, subject areas, and other bases on which districts and consortia may focus their applications, we encourage you to explicitly acknowledge that the Linked Learning approach may be used for this scoping. Similarly, Linked Learning ought to be included as an example of a rationale an applicant may use for an Optional Budget Supplement application.

Thank you for the opportunity to share our perspectives and suggestions for strengthening the proposed Race to the Top—District program. We look forward to the release of the final program application next month, and to continuing to work with you to deliver a quality education for every child.

Sincerely,

Christopher Cabaldon
Executive Director
Linked Learning Alliance

Strongly consider including as a competitive priority or an invitational priority military-connected students. We must do more to overtly address the unique educational needs of military-connected students. Some basic facts to consider. Over one million school-age, military connected students are in pre-K through grade twelve. At least two-thirds of Active Duty military families live in civilian communities. At least one million of Active Duty military children attend schools in civilian communities...every school district in the country has military-connected children and youth. Years of research show that service member's involvement in combat operations can adversely impact children and families for many years. The challenges of being a military child have been exacerbated by this decade-long conflict, with frequent, lengthy, and repeated family separations, as well as the threat of harm to a parent. These stresses have impacted the life experiences and social/emotional well-being of military children and families (e.g., Chartrand, Frank, White, & Shope, 2009; Flake, Davis, Johnson, & Middleton, 2009;).

Frequent moves present significant and unique educational challenges to military-connected children. Frequent moves often result in educational discontinuities: differences in curriculum, academic rigor, graduation requirements, and so on among various school districts throughout the country. Military-connected students must adjust their expectations and academic programs to fit each new educational system. The differences across states, districts and schools are likely to be even more challenging for children with special needs, as there are often disruptions in the educational services they receive. States have different criteria for qualifying students for special education. As military-connected students transfer from one school to another, this often leads to a breakdown in the quality and types of services they receive. Initiatives such as the Interstate Compact on Educational Opportunity for Military Children is designed to address these obstacles by promoting school policies that ease transition problems, but geographic moves continue to make optimal educational experiences and academic attainment difficult for many military-connected children.

The Education Law Center of Pennsylvania (ELC) ELC submits the following comments in response to the Department of Education proposed criteria for the FY12 Race to the Top District Competitions.

Since 1975, ELC the has worked to ensure access to quality public education for Pennsylvania’s most vulnerable children – poor children, children of color, children with disabilities, English language learners, children in foster homes and institutions, and others. These very populations are quite often disproportionately harmed by exclusionary discipline policies and unhealthy school climate.

For this reason, ELC is pleased that standards to improve school climate and decrease inequities in school discipline have been embedded into the draft RTTT-D guidance and hope the following comments will help the Department to strengthen this emphasis even more.

We support focusing assistance on barriers to positive school climate and creating a competitive preference for districts addressing the social-emotional, behavioral, and other needs of students. These needs are crucial to learning.

In March of 2012, The Department of Education’s Office for Civil Rights released data collected by the Civil Rights Data Collection (CRDC) on key education and civil rights issues. In 2009-2010 African-American students represented 18% of students in the CRDC sample, but 35% of students suspended once, 46% of those suspended more than once, and 39% of students expelled. Over 70% of students involved in school-related arrests or referred to law enforcement are Hispanic or African American. Additionally, students covered under IDEA are more than twice as likely to receive one or more out-of school suspensions. The Department of Education bears a responsibility to influence states in eliminating this disproportionate impact of exclusionary discipline.

ELC applauds the requirement that districts with disciplinary disparities be required to undergo a district assessment of the root causes and develop a plan to address it. We urge that this requirement be made not only of grantees, but also of all applicants. Such a plan should set annual benchmarks to reduce disciplinary rates and disparities. Failure to meet these benchmarks should trigger a requirement that a percentage of grant funds be dedicated to implementation of practices to meet these goals.

Finally, we were pleased to see that the draft regulations for the RTTT-D competition included student attendance as a key outcome measure, but disappointed that the definition of student attendance in the regulations does not count in-school suspensions against student attendance. ELC urges the Department to count in-school suspensions against student attendance, to better reflect the time students are out of class and not benefiting from instruction.

ELC also supports the comments offered by the Dignity in Schools campaign available at
http://www.ed.gov/race-top/district-competition#comment-1411.

Secretary Arne Duncan has said, “the undeniable truth is that the everyday educational experience for many students violates the principle of equity at the heart of the American Promise. It is our collective duty to change that.” The Department’s inclusion of school climate criteria in the FY12 Race to the Top District Competitions is one recognition of an important need for change.

We thank you for the opportunity to comment.

Sincerely,

The Education Law Center of Pennsylvania

Race to the Top is an excellent opportunity for our children. I was a little surprised that Early Childhood was not mentioned. I feel that it is crucial to include Infant/Toddler and Preschool education in Race to the Top. We are constantly raising standards in schools around the Nation. Just look at all the Arkansas Preschool Frameworks and Kindergarten Readiness Benchmarks! Unfortunately, we seem to be forgetting that children need earlier educational experiences in order to to meet these rising standards. How can we continue to demand so much of our youngest learners if we are not willing to invest in their earliest learning experiences?

Thank you for the opportunity to submit comments on the Department’s Race to the Top District (RTTT-D) competition guidelines. Building on more than a decade of ensuring that children have access to learning opportunities through school-community partnerships, The After-School Corporation (TASC) is currently expanding the learning day in a network of public schools in New York City, Baltimore, and New Orleans. ExpandED Schools provide approximately three more learning hours per day than the typical public school. We provide students an individualized, balanced and relevant education—the kind that all parents seek—and a chance to succeed no matter where they begin.

We respectfully offer the following recommendations regarding the final RTTT-D guidelines.

Eligibility Criteria; 5a
Eligible applicants should be required to obtain signatures from representatives from partnering non-profit organizations (in addition to those already required) to ensure buy-in from all key stakeholders and to enhance the strength of these partnerships. Recommended language in bold:

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

Absolute Priority 1, Personalized Learning Environment(s)
To help ensure that personalized learning environments are effective, this section should be revised to include expanded learning opportunities (including before-school, after-school, summer learning, and/or expanded learning time) as a way to significantly improve teaching and learning through the personalization of strategies, tools, and supports for teachers and students. Recommended language in bold:

(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 initiatives;

Preparing Students for College and Careers; 1) Learning a) and b)
In order to consistently emphasize the value that community partners bring in terms of developing students’ college and career readiness skills, we suggest that staff from partnering organizations be added to those responsible for learning in this section. Recommended language in bold:

With the support of parents, teachers, other educational support specialists and personnel, and staff from partnering community organizations, students…

Preparing Students for College and Careers; 2) Teaching c) i
We support giving school leaders and leadership teams flexibility and autonomy over school schedules, calendars, and school staffing models (including roles for educators and non-educators). We believe this gives schools and community partners the ability to use innovative methods for enhancing teaching and student learning. We suggest revising the definition of “school leadership team” to include community partners. Recommended language in bold:

School Leadership team: A team that is composed of the principal or other head of a school, teachers and other educators, representatives from partnering community organizations and, as applicable, other school employees, parents, students, other community members…

Competitive Preference Priority—Results, Resource Alignment, and Integrated Services
This section specifies “after-school” as a possible partner organization, but does not mention other expanded learning partners that can effectively enhance core school resources, including intermediaries as well as before-school, after-school, summer learning, and/or expanded learning time. We recommend a revision that acknowledges the full range of expanded learning opportunities and also allows applicants that commit to forming these partnerships to be eligible to apply. Recommended language in bold:

(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 program providers for public health, before-school, after-school, summer learning, and/or expanded learning time, and social service; 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…

Competitive Preference Priority—Results, Resource Alignment, and Integrated Services
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 with staff from partnering organizations. Recommended language in bold:

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

Program Requirements
We believe that school-community partnerships are strengthened when schools are able to share FERPA-compliant student-level data with community partners, allowing both school and community staff to differentiate instruction during after-school and expanded learning time hours. We recommend the following revision:

5. Work with the Department to develop a FERPA-compliant strategy to make all implementation and student-level data (FERPA compliant) available to the Department or its designated monitors, technical assistance providers, research partners, and partnering community organizations.

I support Race to the Top, Early Childhood Education is one of the most important things that could happen to are children
I am living witness of the advantages that the children in the rural area were I am living get by having ECE. I live in Hope Arkansas

I have been encouraged by Secretary Duncan’s repeated claims that indicators related to conditions for learning – such as levels of student safety, engagement and support -- are ‘leading indicators of school success’ and that test scores were ‘lagging indicators.’ Unfortunately, the proposed RTTT-D executive summary does not reflect the Secretary’s convictions and misses an opportunity to highlight and reinforce the importance of ensuring that students are safe, engaged, and supported.

It is essential for schools to strengthen and expand proven programs that increase the number of students:
Who are safe and not victims of bullying or other violence
Who are mentally and physically healthy
Who are engaged in school and avoid truancy and dropping out
Who have strong social and emotional skills
Who report caring and supportive relationships with adults in their families, schools and the community

Efforts to measure and improve conditions for learning should be an absolute priority, for they are at the core of school success and student achievement. Every successful RTTT-D applicant should be required to effectively assess and measure conditions for learning and implement proven strategies to continuously improve the teaching and learning environment.

For information on how conditions for learning can be intentionally addressed in a learning community, please see our framework: the 11 Principles of Character Education (http://info.character.org/11-principles-download/). To see the impact of comprehensive character education program in schools, please watch this video of National Schools of Character. (http://youtu.be/6fodgeXsols)

Mark Hyatt
President & CEO
Character Education Partnership
http://www.character.org

To meet the Eligibility Criteria of "at least 40 percent of participating students across all participating schools must be students from low-income families," please consider allowing a projection of the number of low-income students in a middle or high school based on the average poverty rate of the elementary attendance areas that feed into the middle or high school. This recommendation is based on fewer applications for the federal free/reduced lunch program as students enter secondary schools, and the methodology was allowed in the FY 2011 Advanced Placement Incentive Program.

In the Selection Criteria, please consider extending the duration of a "clear track record of success in the past four years" to a longer period of time. Changes in statewide curriculum and student expectations make it difficult to meet the necessary demonstrated outcomes in a short period of time. Our recommendation would be to extend the track record of success to 10 years.

Recommendations to the Department of Education on Race to the Top District Grants
BELL (Building Educated Leaders for Life) is a national non-profit organization that exists to transform the academic achievements, self-confidence, and life trajectories of children living in under-resourced, urban communities. Through our summer and after school learning experiences, BELL helps children build solid foundations in literacy and math and develop positive attitudes towards academic success. Because we believe in the tremendous potential of all children to excel, we recognize them as scholars.
 
BELL advocates for policies at all levels that would improve the communities we serve. With 20 years of experience in providing after school and summer learning opportunities to scholars across the country, our evidence-based programs have provided the knowledge we use to work with policy-makers and thought-leaders to encourage effective and valuable policy making.
 
To help ensure successful outcomes for RTT-D grants, BELL believes 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, BELL asks the Department to consider the following recommendations:
 
Eligible Applicants – To ensure meaningful participation of partner organizations and to help facilitate the successful implementation of grants, eligible applicants should be expanded in a manner similar to i3 grants to include non-profit organizations in partnership with an LEA or consortia of LEAs.
 
Recommendation (new language in bold, language to be removed in italics)
 
Eligibility Criteria:
 
1. Eligible applicants include only individual local educational agencies (LEAs) (as defined in this document), and consortia of LEAs, and non-profit organizations in partnership with an LEA or consortia of LEAs.
 
a. An eligible applicant LEAs 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 LEAs 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 (new language in bold, language to be removed in italics)
 
Eligibility Criteria:
 
5. Required Signatures for the LEA or lead LEA in a consortium eligible applicant
 
a. Superintendent/CEO, local school board, and 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 (new language in bold, language to be removed in italics)
 
Absolute Priority 1, Personalized Learning Environment(s): To meet this priority, the LEA or consortium’s 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 (new language in bold, language to be removed in italics)
 
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 (new language in bold, language to be removed in italics)
 
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 (new language in bold, language to be removed in italics)
 
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.

First let me say that I am very supportive of this initiative. Education is the key to success and the weapon of choice to combat poverty in this country. I'm dismayed, however, that Early Childhood Education is not at the top of your target list. There is irrefutable data proving that programs that promote ECE provide the basic building blocks for all future learning.
Please consider adding funding for grant proposals submitted by organizations that provide educational services to organizations that provide services to children from birth to five.
Please give our children the best chance for success.
Thanks for taking the time to listen.

I am very supportive of the Race to the Top objectives. I do believe it is important to include early childhood education in the plan, as brain research has shown that the early years are critical to the academic success of children as they progress throughout their educational years. Please consider investing in programs which provide quality early childhood education as part of their program. Thanks for your consideration.

Dear Department of Education,

As part of the RTT District Competition guidelines, we urge you to encourage districts to blend, merge, align and integrate curriculum and professional development in literacy and STEM (science, technology, engineering and math), especially in the early years and early grades. We also suggest that content literacy shows promise as a strategy for this integration.

Regarding STEM professional development, the field currently lacks sufficient validated models, so we suggest that the guidelines support promising as well as proven STEM PD approaches that include teacher-driven professional development.

Your encouragement will enable districts to take advantage of opportunities created by the Common Core Standards and the draft Next Generation Science Standards, as well as momentum in the STEM movement.

Respectfully,

Ralph Smith, Senior Vice President, The Annie E. Casey Foundation; Managing Director, Campaign for Grade-Level Reading
Arron Jiron, Program Officer, S. D. Bechtel, Jr. Foundation
Muhammed Chaudhry, CEO, Silicon Valley Education Foundation

The provided definition of "achievement gap" is confusing. It does not make sense to compare the average performance of my local low performing subgroups to the average of the highest performing state subgroups. It would be more meaningful to compare my lowest performing local subgroups to my highest performing local subgroups. Please clarify this definition.

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

Dear Secretary Duncan:

We write to request that the Department of Education permit the insular areas of Guam, American Samoa, the Commonwealth of the Northern Mariana Islands, and the U.S. Virgin Islands to compete in the upcoming round of Race to the Top (RTT) grants and all future RTT grant competitions.

As part of the initial funding for the Race to the Top program, our districts received an initial set-aside of one-half of one percent under the State Fiscal Stabilization Fund portion of the American Recovery and Reinvestment Act. ED determined that our receipt of these funds disqualified our governments from receiving any additional funds under this program as we had already received money designed to cover the activities under RTT. We do not believe that this one-time set aside should permanently disqualify our districts from competing in RTT grant competitions and that legislation enacted after ARRA may provide ED with authority to include the territories in RTT grant competitions.

Section 308 of the Fiscal Year 2012 Consolidated Appropriations Act (P.L. 112-74) appropriated funds for another round of RTT grants and specified that funding may be awarded to “States or to local educational agencies, or both, in accordance with the applicable requirements of that section, as determined by the Secretary.” We believe that the extension of grant funding to LEAs directly would supersede ARRA’s initial prohibition for our districts to compete for RTT funding, as it expanded eligibility beyond state education agencies. Although our governments are not included in the statute’s definition of “state,” our governments deliver primary and secondary education as LEAs—similar to the education system in Hawaii—and this designation should permit our school systems to compete for RTT grants appropriated for in P.L. 112-74.

Further, we believe the statute’s “applicable requirements” clause does not prohibit LEAs in our districts from competing for these grants. The statute only expands the pool of eligible competitors while maintaining the Secretary’s discretion to award RTT grants from within this pool. We believe the Secretary’s discretion is appropriately applied to the requirements of the RTT program and not the program’s pool of eligible applicants.

The Race to the Top program offers a unique opportunity for states and school districts to promote and measure student growth, encourage innovation, and transform the nation’s low-performing schools. On January 25, 2010, we wrote to you and President Obama requesting that the insular areas be included in the Race to the Top program. We once again make this appeal. The opportunity for educational agencies in our districts to compete for these funds could have a significant impact on improving the quality of education for our students. We, therefore, request that you permit LEAs in Guam, American Samoa, the Commonwealth of the Northern Mariana Islands, and the U.S. Virgin Islands to compete in the upcoming round of RTT grant funding and provide us with an equal opportunity to access these funds.

We thank you in advance for your prompt attention to this matter and look forward to your favorable response.

Sincerely,

MADELEINE Z. BORDALLO
Member of Congress

GREGORIO KILILI CAMACHO SABLAN
Member of Congress

DONNA M. CHRISTENSEN
Member of Congress

ENI F. H. FALEOMAVAEGA
Member of Congress

Dear Secretary Duncan:

The National School Boards Association (NSBA), representing over 90,000 local school board members across the nation, is pleased to submit comments on draft criteria for the Race to the Top District competition. At a time when locally designed education improvement initiatives are important, NSBA appreciates the Department’s decision to issue RTT grants directly to local school districts.

The RTT-D program is a new source of support for a few local education agencies (LEAs), and a potential catalyst for more comprehensive reform. It is this larger impact that compels NSBA to comment. Several of the draft requirements for RTT-D threaten to diminish the program as an LEA grant in name only, including first-time requirements that represent alarming precedents for the future. Grants to LEAs should be precisely that – and should not entail unnecessary requirements that abrogate local school board responsibility and authority for education.

Although the Department should support local governance in its approach to requirements and criteria in the RTT-D program, key elements in the draft reflect a fundamental misunderstanding of the governance role of local school boards that must be corrected in the final document. NSBA’s comments are intended to strengthen the RTT-D program - the clear intent of which is to “support bold, locally directed improvements in teaching and learning.” The RTT-D grant criteria must reflect the primacy of LEAs and consortia in applying for and implementing reforms. NSBA recommends the following for the RTT-D competition:

1) Eliminate the evaluation requirement for school boards. First, the design, implementation and use of evaluations should be a matter of local decision-making, not subject to federal mandates or award preferences regarding the method used or the specific criteria and content that is included. Further, there are a number of fatal weaknesses in the “360 degree evaluations” proposed in the draft criteria approach.

Multi-rater or “360 evaluations” are a common tool used by employers to provide feedback to employees and used to inform personnel decisions such as compensation and promotion. School boards, as employers, could choose to use a multi-rater approach to evaluate employees. The purpose, uses and consequences of multi-rater evaluations would be irrelevant if applied to school boards, however. The vast majority of school boards are elected (95%) – and this accountability to voters is the most strenuous, direct and transparent evaluation process possible. It is increasingly commonplace for school boards, like other governing boards, to conduct self-evaluations, not just in the context of a specific grant, but in relation to the comprehensive operations of an entire school district. The ultimate evaluation of a public governing body is is by the voters

Finally, the one-size-fits-all evaluation model assumes that the role and function of each party in the education delivery system is the same or comparable, and therefore can be evaluated in a similar fashion. Nothing could be further from the truth. Each party designated in the model (school boards, superintendents, principals, and teachers) has distinct legal and professional roles and responsibilities. For example, a principle responsibility of school boards is to evaluate the superintendent, and superintendents evaluate principals, etc. The evaluation requirements in draft RTT-D document model appears to set up employees to evaluate their employers, ignoring the fundamental differences between the roles of school boards, superintendents, principals and teachers, and the unintended political consequences that would result, depending on how the evaluation is used.

NSBA supports an evaluation component for innovations funded by RTT-D grants, however, evaluations should be locally driven and school board evaluations should not be required.

2) Eliminate the State and Mayor, City, or Town Administrator (MCT) comment period on LEA grant applications. As discussed above, the RTT-D competition is intended to be led by school districts and consortia. The comment period requirements in the draft once again reflect a fundamental misunderstanding of local school district operations.

First, the basic geography of school districts and consortia eligible for RTT-D grants renders state and local comment periods unworkable and ineffective. Schools included in an LEA or consortia application could easily touch upon multiple municipalities, townships, counties and/or states. Requiring RTT-D applicants to identify all entities eligible for comment, provide their application to these entities, document all entities’ decision not to comment and/or incorporate comments into the final application – not to mention attempting to respond to comments prior to submitting the final application – creates an unprecedented and burdensome bureaucratic process for LEAs that undermines the purpose of the grant. It is not clear what LEAS are supposed to do to address or reconcile the comments received and whether the weight ED gives to doing so will lead to the approval or disapproval of the application.

In addition, the potential for contradictory and inconsistent feedback in comments from the multiple stakeholders identified in the draft is another difficulty in the application process. This will create chaos for federal reviewers attempting to evaluate the quality and reliability of comments from multiple sources.

With regard to the Mayor, City, or Town Administrator (MCT) comment period, there is a profound mismatch of expertise, experience, accountability, liability, and mission between LEAs and local governments. Leadership and management of most city and county government does not require or convey expertise in complex educational systems, any more than school board members or superintendents possess expertise on local infrastructure or municipal services.

In addition, depending on the education delivery system, county and township comments may be impractical or unavailable. In some states, a single county can contain 30 or more school districts. Even the most conscientious county executive would be challenged to comment with precision on a grant proposal for a single district – or specific schools within a district. While MCTs are extremely important stakeholders, there are adequate safeguards for stakeholder engagement already in the draft requirements. A mandatory comment period for MCTs is not justified.

With regard to the SEA comment period, NSBA has similar concerns. SEAs have formal and extensive educational expertise and missions, but they are not responsible for delivering educational services at the local level. Education is provided by local school districts, and LEA innovation should be supported by the RTT-D program. LEAs should have the freedom to identify and propose innovations that they feel best meet their needs, consistent with federal requirements and state law.

The impact of a comment period on local applications could have several unintended adverse effects. First, clarity is needed with regard to the weight of SEA comments in the federal application review process. A high weight to SEA comments could stifle innovation at the local level, and become tantamount to state oversight or “sign off” on an LEA application. Local innovation will not occur if comment and control from the top down is a requirement. Further, the comment period conflicts with section B (4) (c) of the Selection Criteria that requires LEAs to describe the state context and school autonomy within it. School autonomy is virtually nonexistent under the requirements described above.

In short, mandatory comment periods contradict the purpose of the RTT-D program and severely undermine what is intended to be locally-developed innovation and reform. NSBA supports requirements in the draft criteria for engagement of a wide range of stakeholders, including parents, educators, businesses, service providers and other community stakeholders, including other local government and state stakeholders. However, the challenges of forming consortia and collaborations with a variety of partners and providers within the proposed timeframe for preparing an application are extremely demanding. The Department should focus on supporting school districts during this process rather than imposing comment period requirements that could discourage LEAs from applying and have a chilling effect on the very innovations the program is intended to encourage. At its core, the comment period belies the very purpose of the RTT-D program and should be eliminated.

3) Clarify that preschool is an eligible, but not mandatory use of RTT-D funds. For example, Subject Area Bands including preschool through third grade are eligible. NSBA strongly supports the Department’s inclusion of preschool as an eligible use of funds in the RTT-D program. NSBA requests clarification, however, that preschool is not mandated in order for LEAs to receive RTT-D grants.

4) Clarify that the school board president’s signature is required on the RTT-D application in the Eligibility Criteria. NSBA supports the requirement that the RTT-D application be signed by the Local School Board President. However, the Eligibility Criteria in 5.a. on page 2, state that required signatures for the LEA or lead in a consortium include the local school board (not the school board president). NSBA recommends inserting the word “president” will make the Eligibility Criteria consistent with Application Requirements in 3. b. and 3. c. (iv) on p. 3. In addition, applications should be signed by the school district, and should not require multiple signatures from multiple parties as described in 3. B. 1. of the draft requirements. Memoranda of Understanding signed by multiple parties are sufficient to document broad support for the application.

5) Make several clarifications to Priority 1 – Personalized Learning. NSBA supports an approach to instruction that allows every student to succeed academically and in life. As a general observation, the description of personalized learning in the draft criteria is very consistent with principles of universal design for learning, which NSBA supports. NSBA recommends that the Department state this explicitly in Priority 1.

In addition, NSBA recommends that the Department affirm LEA authority to determine the instructional and operational parameters of establishing and updating Personalized Learning Plans (PLPs), including establishing goals and objectives, sequencing content and skill development, and ensuring that students graduate on time.

6) Affirm LEA authority to establish a threshold of support from stakeholders.

Requirements for LEAs to demonstrate meaningful stakeholder support must be reasonable and reflect the governance role and responsibility of school boards. For example, the requirement in B (3) (ii) that 70% of teachers from participating schools without collective bargaining agreements support the proposal is excessive. One third of states do not have collective bargaining, and in states that do, not all school districts participate. So the challenge to thousands of school districts to demonstrate such a high level of support without a process in place to ballot or otherwise determine the required level of support could create a bureaucratic obstacle. Depending on the substance of the application, creating a process to win 70% support would seemingly require putting in place a system comparable to collective bargaining – which these districts as a matter of policy or law don’t do. In addition, requiring such a high level of support from a stakeholder group for which the LEA has responsibility for evaluation does not reflect the local governance role of school boards.

7) Eliminate school level expenditure reporting requirements from the Selection Criteria.

Data collection and reporting in B. 2) of the Selection Criteria should be eliminated. There is no explanation or justification regarding how capacity to report this data constitutes “reform conditions,” for what purpose the data would be used, why the data is necessary to implement LEA-initiated innovations, and how the capacity of LEAs to collect this data strengthens an application. This is in addition to considerable privacy concerns of reporting actual personnel salaries for teachers and other instructional staff. The draft is not explicit as to whether the “transparency” granted by this data collection applies to the entire LEA or just participating schools, but either way it should be eliminated from the draft requirements and criteria.

8) Eliminate the absolute requirement for a 3-year post-grant budget. NSBA supports a requirement for applicants to describe how they plan to sustain innovations after the grant period. We urge the Department to grant flexibility for promising programs in districts where future resources and capacity are uncertain and LEAs cannot demonstrate capacity to sustain the grant as described in E (3), including budget assumptions, potential sources and uses of funds due to volatility of revenue.

9) Grant full recognition to public comments. In order to run a rigorous competition, NSBA urges the Department to treat organizational comments submitted on the blog with the same importance as though they were submitted through formal rulemaking. A program of the significance, magnitude and impact on school districts as the RTT-D merits the careful review of, and response to, comments that the Department gives to formal submissions, so that responders know and fully understand that their recommendations have been considered.

In conclusion, NSBA’s recommendations would ensure that local school districts are not overburdened with requirements that have little to do with the viability and effectiveness of the LEA proposals, while retaining the ambitious goals of the RTT-D competition. NSBA supports additional federal support for the education for all students, particularly those with the greatest need. As you have said on many occasions, innovation begins at the local level. The RTT-D program creates a new opportunity to support local school districts - many of which are struggling in the current economic climate - to achieve equity and excellence in education for all children. NSBA therefore strongly urges the Department to honor local authority in the RTT-D program and all grants directly administered to LEAs.

Thank you for the opportunity to comment. Questions concerning our comments may be directed to Lucy Gettman, director, federal programs, at 703-838-6763 or by e-mail at lgettman@nsba.org.

Sincerely,

Michael A. Resnick
Associate Executive Director

Great comments from NSBA

I am so glad Race to the Top has been organized to help our nation's schools provide the best education for our children. However, I am concerned that the early childhood age group is not included in the funding. Research has proven time and again that learning begins before birth and they skills and knowledge that children acquire before they enter Kindergarten have a huge impact on their success throughout their life. I believe that giving funding priority to programs that include early childhood should be implemented. Thank you for your consideration in this matter.

City Year has seen firsthand the innovative, ambitious strategies many districts are pioneering to improve student outcomes. As such, we applaud the Department of Education for motivating districts to accelerate these efforts through the Race to the Top District (RTT-D) competition.

We are particularly pleased that the Department of Education encourages districts to create personalized learning environments, use readily available data to ensure students’ individual needs are being met, and partner with external organizations to provide comprehensive supports to students. With that said, we have three suggestions for how the Department of Education could improve the RTT-D competition design.

1. Leveraging Community Resources and Expertise to Implement Proven Reforms: Applying districts ought to be required to lay out a clear plan for how they will leverage the expertise, capacity and person power that community-based organizations can bring to effectively and sustainably implement one or more of the school intervention models. Our experience and research show that our nation’s lowest performing schools require this additional support to meet each struggling student's unique needs and make substantive reforms in our nation’s lowest-performing schools.

2. Measure Chronic Absenteeism: In addition to measuring student attendance, it is critical that districts measure the number of students who are chronically absent - missing 10% or more of school days over the course of a year for any reason including excused and unexcused absences and suspensions.

3. Clarify On-Track Indicator: The “on-track indicator” definition should be clarified to ensure that districts are accurately measuring the number of students who are on track to college and career success and the number of students who have fallen off track and are at risk of not attaining this goal. Specifically, we suggest that the definition of “on-track indicator” be changed to: “A measure, available at a time sufficiently early to allow for intervention, of a composite of the three characteristics – attendance, behavior, and course performance - shown to most accurately predict whether a student is on track to on time high school graduation and post-secondary success. To be considered on-track a student must attend school 90% or more of school days over the course of a school year, have no suspensions over the course of a marking period, and perform on grade level in core academic courses.”

We thank you for giving districts the opportunity to secure the resources needed to implement proven reforms and improve teaching and learning.

- Jim Balfanz, President, City Year, Inc.
- AnnMaura Connolly, Chief Strategy Officer & Executive Vice President, City Year, Inc

$0 Cost to ABOLISH School Corporal Punishment akin to Hazing Bullying that Injures Studentss educator careers and taxpayer funds at risk of lawsuits see Shocking injuries on YouTube Video trailer for Documentary by Jared Abrams "The Board of Education" at http://www.youtube.com/watch?v=0vt4v7KsFi8 http://huff.to/KGAbhB

Students K-12 are paddled/injured by school teachers, coaches and administrators legally everyday in US Schools in 19 States known as School Corporal Punishment with no safety standards to protect students from excessive force injuries! See shocking injuries to students YouTube video Trailer for Documentary "The Board of Education" by Jared Abrams at http://www.youtube.com/watch?v=0vt4v7KsFi8 School employees are Immune from criminal/civil charges leaving no legal remedy! Some State Laws, including Florida and Tennessee, do Not require parental consent or notification to inflict Pain as Punishment in school, yet it is Illegal in Schools in Nashville and 31 U.S. States!

Spanking can be sexual abuse http://nospank.net/101.htm

Watch short YouTube Video of Montel Williams, 2007 Supreme Court of The United States complicit in child abuse/beatings of minor schoolchildren no legal remedy http://www.youtube.com/watch?v=xu20PSLcJIw

U.S. Organizations Opposed to Corporal Punishment in Schools http://www.stophitting.com/index.php?page=usorgs

School Spanking, known as Corporal Punishment, is discriminatorily applied to boys, minority, disabled and low-income students. http://www.hrw.org/reports/2009/08/11/impairing-education-0

Sign Petition to End School Corporal Punishment at http://www.change.org/petitions/support-h-r-3027-to-end-corporal-punishm...

Military students should also be considered as a category for Race to the Top grants. These children face tremendous challenges due to deployments and the effects of multiple moves on their social and academic lives. With extra support they do well. Schools with high populations of military students need funding to provide support services.

PE, physical activity, and academic performance

We at Active Living Research are encouraged by Secretary Duncan’s statements that indicators related to conditions for learning are “leading indicators of school success” and that test scores were “lagging indicators.” Unfortunately, the proposed RTTT-D executive summary misses an opportunity to highlight and reinforce the importance of engaging students in physical activity by making physical education (PE) and other opportunities for physical activity a part of an enhanced learning environment. The scientific literature (see links) demonstrates a consistent association between school-based physical activity and academic performance (e.g., grade point average and test scores) and academic behaviors (e.g., concentration, attentiveness, and time on task).
Active Education: PE and Academic Performance http://activelivingresearch.org/files/ALR_Brief_ActiveEducation_Summer20...

Furthermore, the childhood obesity epidemic is evidence that most youth are not meeting physical activity guidelines, and that there is an erosion of PE practices. A recent HBO documentary, Weight of the Nation, clearly demonstrates the crises our children face due to obesity and the urgent need for providing more physical activity to all children, which many get only through PE at school.

The connections are clear. Children in low-resource schools and communities of color are at higher risk for (a) poor academic performance, (b) obesity, and (c) lower quality and quantity of PE, and (d) fewer opportunities for physical activity at school and in their neighborhoods. Thus, PE and physical activity at school can be part of a comprehensive approach to improve academic performance in at-risk populations. This brief documents that students in low-resource schools are less active in their PE classes:
http://www.calendow.org/uploadedFiles/Publications/By_Topic/Disparities/...

PE is fundamental
Several studies document that highly-active PE is effective and is feasible for implementation in elementary, middle, and high schools. Evidence-based PE programs should be supported that:
• Use PE curricula and lessons focused on health-related physical activity and fitness;
• Keep students active in moderate to vigorous physical activity (MVPA) for at least 50% of class time;
• Engage all students, regardless of physical ability;
• Significantly contribute to students’ overall physical activity participation, thereby improving their health;
• Support credentialed PE teachers for all schools, whenever possible; and
• Include a well-designed professional development plan that can help all PE instructors increase the amount of time students spend in MVPA and decrease the amount of time spent on administrative and classroom management tasks.

There is a rationale for making PE a core subject so that every student benefits from the physical activity and skills development, but that is unlikely to occur at this time. PE and physical activity should be considered a means for improving conditions for learning, which is a major priority for the Department of Education. Thus, an alternative approach is to provide points/credit for implementing evidence-based strategies of providing more physical activity at school or evaluating innovative strategies for their effects on student physical activity. Encouraging all school districts to have an evidence-based physical activity plan would repair some of the damage done by No Child Left Behind. By providing no credit for PE or physical activity, NCLB led schools to drop these programs to make more class time for core academic subjects. Today, daily PE is rare nationwide: only 4% of elementary schools, 8% of middle schools, and 2% of high schools provide daily PE (Centers for Disease Control and Prevention. School Health Policies and Programs Study 2006 Fact Sheet: PE. 2007: http://www.cdc.gov/healthyyouth/shpps/2006/factsheets/pdf/FS_PhysicalEdu...).

The RTTT-D competition is an opportunity to begin to correct these low statistics.

Schools have many options for increasing student physical activity
Improving the quality and quantity of PE is the best place to start for getting children active and ready to learn, because it is the only program that can reach all students throughout the school year. However, there are other school-based strategies for increasing physical activity that also are evidence-based. The options are summarized in this report.
School Policies on PE and Physical Activity http://activelivingresearch.org/files/Synthesis_Ward_SchoolPolicies_Oct2...

In addition to PE, here are other strategies schools can implement to increase children's physical activity:
• Promoting walking and cycling to/from school. There is federal funding available through Safe Routes to Schools from US Department of Transportation.
• Recess, especially when supervisors are trained, play equipment is available, and playgrounds are painted with designs that stimulate active play.
Increasing Physical Activity Through Recess http://activelivingresearch.org/files/ALR_Brief_ActiveEducation_Summer20...
• Classroom activity breaks. Ten-minute activity breaks in classrooms also improve attentiveness. Breaks can be led by trained teachers or readily available DVDs and CDs.
• After-school programs can provide opportunities for physical activity that do not take any class time. It is important that after-school programs be designed to maximize activity and be open to all students, not just elite athletes.
• Joint-use agreements can open schools for community use while reducing liability and providing a way to handle maintenance costs.

Grants are needed to support school physical activity
The Carol M. White PEP Grants are the only source of funds to support school physical activity. They should continue to be targeted only to physical activity. If these funds are offered in a block grant to be used for any non-core subject, that will most likely end federal funding for school physical activity and PE.

However, PEP grants can and should be improved. We recommend two changes.
• Add criteria to ensure that either evidence-based PE or physical activity programs are used or innovative programs are systematically evaluated for their effects on physical activity and educationally-relevant outcomes.
• Give preference to schools serving primarily low-income or otherwise at-risk students. These schools have greater need for physical activity programs and can benefit more than better-off schools, but they have less ability to write effective grant proposals. Thus, evidence of school need should be part of the decision-making process.

We strongly encourage the Department to modify the RTTT-D summary and require all successful applicants to include a plan for increasing student physical activity through evidence-based strategies as a means of improving the conditions for learning. Please consult the reports linked throughout this comment and call on us for further information and assistance.

On behalf of the American Association of School Administrators, representing more than 13,000 school system leaders across the nation, we submit the following comments in response to the Department of Education (Department) proposed criteria for the FY12 Race to the Top District (RttT-D) Competition.

AASA applauds the Department’s efforts to make its Race to the Top competition accessible to districts. The proposal to allow districts to apply in consortia, including with Education Service Agencies, is a positive step toward making competitive grants more accessible to all schools. AASA supports the Department’s continued focus on and support of program that enhance college and career readiness for all students. Further, focusing assistance on non-school barriers, including social-emotional, behavioral and other needs, is crucial to learning. It is an important link in education the total child, and AASA applauds the Department’s preference for applications that integrate additional family and student supports. AASA also supports the Department’s efforts to submit proposed competition criteria to public comment. Our comments are offered as ways to improve the functionality of and opportunity for success for the RttT-D funds. Therefore, we submit the following comments in response to the Department’s proposed criteria:

General Comments
The Department asserts that innovation starts at the district level, and AASA hopes the Department will seriously consider our comments, intended to strengthen RttT-D by reinforcing local school district authority to implement reforms. That said, AASA remains committed to the belief that the best investment of limited federal education dollars remains in the flagship, formula programs that help level the playing field for disadvantaged students. The hundreds of millions of dollars that have been redirected to Race to the Top came at the direct expense of Title I of the Elementary and Secondary Education Act (ESEA) and the Individuals with Disabilities Act (IDEA) programs and undermine federal efforts to create a level playing field in our nation’s schools by reinforcing the positions of ‘winners’ and ‘losers’. AASA will continue to advocate for prioritizing additional federal monies into Title I and IDEA and only weighs in here because the FY12 funds for RttT are appropriated and, as the professional organization representing school district leaders, it is important we do what we can to ensure that the RttT-D competition and its funds are structured in such a way that the program can succeed.

AASA applauds the Department’s public release of proposed criteria for the RttT-D competition. We strongly urge the Department to not only review and consider comments and feedback from the field, but to ensure that the final criteria and competition reflect suggestions from education practitioners. School system leaders, principals, teachers and educators are the ones who are ultimately left with the work of implementing any education priority. They are the ones who will apply for and implement the grants, and are clearly best suited to provide meaningful insight on how the department’s proposed criteria either supports or undermines the department’s goals. If ever there were a time to ensure that their feedback is prioritized in structuring a program, it is the district-level round of Race to the Top. We hope the Department’s final criteria will support areas applauded by practitioners and reconsider areas that are noted as ‘of concern’ or ‘problematic’.

Specific Comments: Eligibility Criteria
• Ensure that education service agencies are eligible entities. While the executive summary and verbal discussions have indicated that education service agencies (ESAs) are entities eligible to apply as part of a consortium, the eligibility is not listed in the formal document. AASA applauds the Department position of supporting ESAs. The current articulation, as written in the Fast Facts summary of the criteria, lists ESAs as an eligible entity, writing ,
“…and education services agencies (ESA) that the State recognizes as LEAs and meets the ESEA definition of LEA.)”
Given that not all states include ESAs in their state definition of local education agency (LEA), we are concerned that certain ESAs will not be eligible to support consortia efforts. AASA recommends including the statement in the final criteria, with one modification: striking the phrase ‘the State recognizes as LEAs and’ as a way to ensure that all ESAs are eligible entities. Exclusion of ESAs in states where they are not included in the state definition of LEA severely limits the ability of rural districts to apply in consortia.
• Poverty Level: AASA seeks clarification about the nature of the 40 percent eligibility for free/reduced lunch for applicants. Specifically: Is the poverty threshold permanently fixed at the time of application, is it averaged over multiple years, or some other calculation? What happens if the poverty percentage changes (due to a change in local employment opportunities or family mobility)? A change (drop) in poverty is much more likely in smaller schools, where the exit/influx of just a handful of students could drop the LEA’s poverty level below 40 percent.
• Eliminate the enrollment threshold. While AASA understands the attempt to encourage smaller districts to apply in consortia, we do not support a hard and fast enrollment threshold. More than two-thirds of the nation’s school districts enroll less than 2,500 students and establishing this threshold means this is a RttT-Consortia competition. The flexibility to apply in consortia is an excellent addition to the competitive process, but it is undermined with a strict enrollment threshold. In theory, four separate rural school districts, all qualifying for the small/rural school program under the Rural Education Achievement Program could agree to work together given compatibility and geographic convenience. Given that they, by definition, each enroll less than 600 students, though, their collective 2,400 students do not meet the eligibility threshold. AASA recommends encouraging (not requiring) an enrollment target (preferably lower than 2,000).
• School Board Evaluation: The proposal to require evaluations of schools boards, administrators (principals and superintendents) and educators is to be applauded for its well-intended focus on increased/expanded accountability. There are a handful of weaknesses within the proposed evaluation component of the draft criteria. Nearly all (90%) of school boards are publically elected. These types of elections are the most transparent evaluation process available. The purpose of evaluation ought to be improvement, and it is unclear what the department is trying to accomplish or how their proposal will improve current evaluations (elections).

Specific Comments: Application Requirements
• Mayor, City or Town (MCT) Administrator Comment: The Department has been very clear and deliberate in establishing this round of the Race to the Top competition as one designed for school districts. Of the FY12 funding for RttT, $390 million is clearly intended for LEA use, and the final RttT-D criteria should reflect a laser-like focus on LEAs and consortia in applying for and implementing reforms. Requirements related to mayor, city or town administrator comments seem unnecessary in school districts where the LEAs operate as independent political jurisdictions. County-wide school districts may include multiple towns/cities; which mayor would need to sign? For those school districts located outside of city or town limits, whose signature should they seek? While AASA supports the criteria’s requirements related to engaging a wide range of stakeholders, including parents, educators, businesses, service providers and other community members, we are concerned that the required comment period for the MCT/SEA exceeds engagement, undermines the focus on district-led innovation and shifts control of the application process to the MCT/SEA level. AASA urges the department to reinforce the leadership role of LEAs and clarify the limited role of MCT/SEA in developing or significantly reshaping LEA applications for a district-level competition.

Specific Comments: Absolute Priorities
• Personalized Learning Plans: AASA seeks clarification as to what the department means by ‘personalized learning plan’ (PLP). How is a PLP similar to/different from differentiated learning, response to intervention, or individualized learning/instruction? The definition within the criteria is vague and not common in the school/educator community. Further, the definition implies certain areas of expertise, and AASA seeks clarification to the following questions:
o Who is responsible for developing, reviewing and updating PLPs, and at what interval?
o PLPs bear strong similarity to the Individualized Education Plan within the Individuals with Disabilities Education Act. What is the liability of LEAs for appeals/litigation related to PLPs?

Specific Comments: Competitive Priority
AASA applauds the Department for the competitive priority that responds to the ongoing movement in the field and the reality that districts face in seeking reform and large-scale school improvement. The integration of public and private resources to augment the schools’ core resources particularly those that provide additional student and family supports, such as addressing the social-emotional, behavioral, and other needs of the participating students is an excellent use of the competitive priority. It benefits districts and consortia able to leverage resources without penalizing smaller districts that may not have the same access to private investment/resources. AASA works with districts across the country to assist them in the development of coherent and sustainable partnerships 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 and is pleased that the Department is similarly encouraging districts and, in turn, communities to work together on behalf of children.

Specific Comments: District Capacity & Success Factors
• Reform Conditions: AASA has thoughts/concerns with several of the proposed reform conditions:
o Track Record of Success: Schools are just emerging from the greatest recession in our nation’s history. Years of fiscal constraint may have at best leveled off, if not negatively impacted, a school’s track record of success. The timeline requirement of four years coincides with the recessions, which came with cuts in programs, personnel and services. Further, if the point of RttT is to spur or support innovation, where better to support improvement than in a school that struggles to succeed?
o Publishing Salaries: AASA is concerned that requirements related to publishing salaries—while aggregated at the school level—pose serious privacy concerns, especially in smaller communities. The value of such information is dubious when it comes to determining the success of a school system.
o Focus on Grade Structure: While grade structure is not a requirement of the criteria, AASA is concerned about the continued focus on grade structure. The use of ‘on track’ evaluation, when tied to grade structure, is simply an extension of No Child Left Behind’s annual measurable objectives. The final criteria should encourage, support and incentivize new ways to benchmark student progress, focused on curriculum that personalizes learning instead of stagnant grade structures that simply group students.
o Stakeholder Support Requirement: AASA supports the call for stakeholder support for any RttT-D application. AASA urges the Department to modify the proposed criteria such that the final criteria are reasonable and consistent with the governance structure, role and responsibility of a school district and its superintendent and school board.

In closing, AASA supports continued federal investment in the nation’s public schools. The additional support of RttT-D is an opportunity to provide additional resources to students with the greatest need. RttT-D has the potential to be a catalyst for innovation, though AASA remains committed to the belief that the full benefit of competitive funds cannot be realized until the education playing field is level, meaning continued and increased investment in federal flagship formula programs like Title I and IDEA. Much of the content within the RttT-D criteria represent uncharted territory and are precedent setting. The success of this round of RttT will hinge largely on how much the Department adopts feedback from the field. RttT is a grant program, and a heavily prescriptive federal role in a district-level grant competition would undermine the programs intent and circumvents LEA authority and responsibility.

The mission of the California School Health Centers Association (CSHC) is to improve the health and academic success of children and youth by advancing health services in schools. We envision a day when all of California's children and youth are healthy and achieving at their full potential.

School-based health centers (SBHCs) bring health, mental health, oral health, and youth development services onto school campuses. They are most often the result of close partnerships between schools and community-based health care providers; that said, every SBHC is unique, reflecting the desires, strengths, and needs of the community in which it is located. SBHCs have been shown to improve attendance, behavior, and graduation rates, leading to overall gains in academic outcomes.

An SBHC is often an integral component of a community school, and many SBHCs provide services not only to students but also to siblings, families, and community members. CSHC works closely with the Coalition for Community Schools and other community schools advocates, and we were happy to see many of the principles of community schools reflected in the draft RTT-D guidance, particularly in the Competitive Preference Priority. We were also very pleased to see, in that Priority, an explicit focus on addressing students' socio-emotional and behavioral needs. However, given the significant and well-documented impact of other types of health problems on student success, we urge the Department to expand the Priority to reflect a broader definition of health (i.e., physical, behavioral/mental, and oral health).

Specifically, we urge the Department to make following capitalized revisions to the Competitive Preference Priority on p12-13 of the draft guidance:

A) "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-EMOTIONALl, BEHAVIORAL/MENTAL HEALTH, PHYSICAL HEALTH, ORAL HEALTH, AND OTHER NEEDS of the participating students..."

B) "In determining the extent to which the applicant meets this priority, the Department will consider -- (1) Whether the applicant has formed a coherent and sustainable partnership with public and private organizations, such as public health, HEALTH CARE, 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. ... (3) How the partnership will enable, within participating schools (as defined in this document), the integration of education and other services (e.g., services that address SOCIAL-EMOTIONAL, BEHAVIORAL/MENTAL HEALTH, PHYSICAL HEALTH, ORAL HEALTH, AND OTHER NEEDS) for participating students (as defined in this document)."

Finally, we believe that all schools improve their outcomes by partnering with community stakeholders to bring additional resources to their students, but that these collaborations are particularly beneficial and impactful at schools serving high percentages of low-income children and adolescents. We therefore urge the Department to make the Competitive Preference Priority an Absolute Priority, as we believe that doing so would strengthen district practices and benefit students across the United States.

Serena Clayton, PhD
Executive Director
California School Health Centers Association

As a nationwide coalition of over 50 organizations whose members include parents, students, educators, and advocates, the Dignity in Schools Campaign writes to offer comments on the U.S. Department of Education’s (ED) draft guidelines for Race to the Top - District (“RTT-D guidelines”).

The Dignity in Schools Campaign firmly believes that our nation’s “dropout crisis” is, in reality, a “pushout crisis.” The last two decades have seen a tremendous spike in the use of harsh and exclusionary discipline in schools. The excessive use of suspensions, expulsions and even arrests of students has become commonplace as a first response to behavior that can and should be handled within classrooms and schools. Research demonstrates that the improper use of exclusionary discipline undermines academic achievement and carries with it severe disparities along the lines of race, disability, sexual orientation and gender identity. For many students, it is safe to say that they did not “drop out” of school; instead, they were “pushed out.”

We believe that this pushout crisis will never be resolved, and “achievement gaps” cannot be closed, until states and school districts are called upon to address the policies and practices that disengage students from learning and unnecessarily remove them from school. To that end, we support ED’s efforts to:
• Address school climate and disciplinary disparities in these guidelines,
• Call for personalized learning environments, which we hope will serve to properly engage all students in challenging study, and
• Ensure community engagement in the development of district applications.

However, we are concerned by several provisions in the guidelines that may foster pushout. We are particularly concerned with the use of students’ standardized test scores as a “significant factor” in the evaluation of educators and the over-reliance on school closure as a first step towards school improvement. We strongly urge ED to address these to better serve all students intended to benefit from these funds.
We must also express our fundamental concern for the manner in which these funds are being distributed. Education is a human right and, as Secretary Duncan has expressed, “the civil rights issue of our generation.” Competing for education funding in an era of tremendous budget shortfalls ultimately means some students will “win” and others will “lose” significant educational opportunities. These funds should be offered, not as competitive grants, but as conditional incentives to all states and districts once they have met the goals described in this competition.

Please note that these comments focus on matters that impact school pushout and are not intended to offer an exhaustive list of the shared or individual priorities our multi-stakeholder membership may express in separate comment letters.

1. School Discipline and School Climate:

Program Requirements
We applaud and strongly support the requirement that grantee districts with racial or disability-related disciplinary disparities must undergo an assessment and develop a plan to address the root causes of these disparities. The Dignity in Schools Campaign is proud to be part of the growing chorus of voices calling for such a requirement. (See our April 16, 2009, letter on Race to the Top and the American Recovery and Reinvestment Act here: http://www.dignityinschools.org/files/DSC_ARRA_Signon_Letter_to_ED.pdf).

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

Selection Criteria
We support ED’s call for districts to address how they will improve student attendance through “ambitious yet achieveable annual goals.” In particular, we support ED’s proposed definition of student attendance: “Students should not be considered present for excused absences, unexcused absences, or any period of time that they are out of their regularly assigned classrooms due to discipline measures (i.e., in-school or out-of-school suspension).” We strongly agree that far too much valuable instructional time is lost when students are serving in-school or out-of-school suspension or are attending inadequate disciplinary alternative schools. We hope that ED’s definition would help to curb unnecessary reliance on these practices. However, we would not want time spent in in-school suspension, for example, to be counted against an individual student’s attendance record where it would make grade retention more likely. Therefore, we ,recommend that ED amend the definition to include the following italicized language: “For the purposes of a Race to the Top application, students should not be considered present for excused absences, unexcused absences, or any period of time that they are out of their regularly assigned classrooms due to discipline measures (i.e., in-school or out-of-school suspension.”

Competitive Preference Priority
We also support the competitive preference ED would offer school districts that use public and private resources to address social and emotional learning and behavior. There are great examples across the country of schools and districts that have improved student attendance and performance by creating more engaging and positive classroom environments for students and teachers alike. This practice should be encouraged. To that end, ED should add improved student attendance, as defined in these draft guidelines, to the list of “desired results” for the competitive preference.

2. Student Learning and Engagement:

Absolute Priority 1: Personalized Learning Environments
We are encouraged by the emphasis the proposed guidelines place on “personalized learning environments,” and by the call for personalized learning plans and approaches such as project-based learning. Far too many youth attend schools that have abandoned a number of more engaging and effective approaches to teaching and learning in order to “teach to the test.” This approach is pushing students out of school and teachers out of the profession, and we hope the focus on personalization may help to counter that phenomenon. We further support the requirement that students and parents have “equitable access to content, tools, and other learning resources regardless of income.”

We are not clear on the extent to which progress on the “four core educational assurances” of the original Race to the Top serves as a predicate for grant funds in this competition. We understand that the proposed RTT-D guidelines would require school districts to “demonstrate a track record of commitment” to these assurances. But this provision is vague and we ask that ED provide clarification. We fear that aspects of these core assurances will fuel school pushout. To the extent that the progress on the “core assurances” affects an applicant’s score, we urge ED to address the following concerns:

Teacher Effectiveness
We support the use of multiple measures for teacher evaluation, particularly student and parent surveys, to evaluate educators and school and district leaders. (See the Dignity in Schools Campaign’s March 30th, 2012, letter on the Teacher Incentive Fund for related recommendations: http://www.dignityinschools.org/files/DSC_TIF_Comments.pdf). While we are encouraged that ED’s proposed RTTT-D guidelines would favor multiple measures to evaluate teachers, we remain concerned about the possibility for over-reliance on students’ standardized test scores as a “significant factor” in the hiring, firing, compensation, and promotion decisions of teachers.

We believe ED has a role to play in ensuring that great teachers fully staff our highest need schools and we acknowledge that meaningful teacher evaluation is essential to that task. However, history has demonstrated that overreliance on students’ test scores will yield unintended and unfortunate encouragement for schools to push out those students most in need of support. This concern only multiplies when administrator, superintendent, and school board evaluations are based primarily on student performance on standardized tests. We therefore urge ED to remove the requirement that evaluation systems be based on student test scores as “significant” factors.

School Turnaround
We are concerned by the requirement that school districts “achieve ambitious and significant reforms via implementation of one or more of the four intervention models” for school turnaround. Three of these four intervention models rely on school closure as a first step towards improvement. Since the inception of the state-level Race to the Top competition, far too many of our members have reported that their students were not welcomed into new schools once their prior schools were closed through a turnaround process. Indeed, it appears some districts are trying to turn around their lowest performing schools by pushing out (and keeping out) some students, while also transferring others to other struggling schools. Race to the Top District grants should be designed in a way that discourages this practice.

In order to mitigate this danger, ED should deduct points from applications submitted by districts that cannot account for the full re-enrollment of students in high-performing schools after school closure. Furthermore, ED should monitor related trends throughout the grant term(s) and prioritize districts that invest in low-performing schools by undertaking a thorough needs analysis (including measuring its disciplinary rates and disparities) and by addressing those needs in conjunction with community.

3. Community Engagement:

We enthusiastically support ED’s call for community engagement in the development of Race to the Top District applications. Too often, community organizations are not afforded meaningful opportunities to offer input into ED’s competive grant application process, and those community organizations allowed to give input may not fully represent the community. We ask ED to prioritize the applications of districts that demonstrate meaningful engagement with parents and community organizations from across the neighborhoods their schools serve. Furthermore, we urge ED to include a required public comment period of significant length, ahead of those for local and state government actors, for community members on each district’s application.

We thank you for the opportunity to comment.

Sincerely,

The Dignity in Schools Campaign

We strongly support the comments submitted by Dignity in Schools.

We strongly support the comments submitted by Dignity in Schools Campaign

Please support DSC's comments - we strongly support them. Thank you

Education Law Center of Newark, NJ strongly supports the DSC comments.

I strongly support these comments.

I strongly support these comments.

NDRN strongly supports these comments. We want to make sure that all school reform efforts reduce rather than expand the school to prison pipeline for students with disabilities.

I strongly support these comments!

I strongly support these comments. Most particularly, it's vital that our nation in the 21st Century stop the push-out of our youth from school. Homeless youth with whom my organization works are left to the streets alone when school systems expel them. Increasingly, expulsions become the gateway to jails and prisons. Sanctioning a system that tolerates such a result is simply not in our national interest.

I strongly support the comments of the Dignity in Schools Campaign.

The Chicago Coalition for the Homeless strongly supports Dignity In Schools comments

As an education researcher, I strongly agree with the statements and facts presented here by the DSC and urge the DoE to consider them in their R2Top policies.

These are intelligent and thoughtful comments. I hope DoE takes them to heart and makes the appropriate adjustments to the guidelines.

We strongly support these comments.

Please support these recommendations!!

Please support these recommendations!!

Dear Secretary Duncan,

First, I write to express excitement about the potential for the Race to the Top District (RTT-D) program to increase student learning across the country. Thank you for your continued leadership in the fight to increase student achievement.

My only aim in submitting these comments is to increase the probability that RTT-D will be successful. Given this, I will focus my comments on areas of improvement, rather than validating areas of alignment.

The remainder of the comment is organized into three broad areas: Specificity, Scope, and Structure. But to summarize at the outset: I believe RTT-D could be greatly improved if its mandated means of execution were less specific, its scope reduced, and its structure broadened.

Specificity
Reducing the specificity of implantation requirements will improve RTT-D. The field of personalized learning, while promising, is in its infancy. Little research demonstrates what, if anything, works. Promising studies in personal tutoring (Houston) indicate potential – but there is a paucity of research on most strategies, included blended learning. As such, rather than scaling “best practices,” RTT-D could perhaps better be viewed as a national opportunity to innovate in the area of personalized learning and evaluate what works.

Recommendation (1): Remove all formal requirements on the structure of personalized learning that are not supported by extensive research. This will hinder innovation. Specifically, remove the following:
- “A variety of high-quality instructional approaches and environments matching learning and development goals with individual
student performance, optimal learning approaches (e.g., discussion, project-based learning, videos, audio, manipulative), and
interests”
- “all participating educators participate in professional teams or communities”
- “the percentage of participating students who access their personalized learning plan (as
defined in this document) on a weekly basis”

While all these practices sound promising, we do not know if they are the most effective way to execute personalized learning. For example, what if the most effective model ends up being a personalized learning program where: one primary instructional approach is utilized, educators are trained in 1-1 coaching sessions, and students review their goals every two weeks. This is a perfectly plausible scenario that would be forbidden by the proposed rules.

Recommendation (2): Given how little we know, require each applicant to construct at least one controlled trial that will allow practitioners to understand both how the personalized program learning compared to traditional learning settings, as well as how different personalized programs compare against each other. In short: be loose on the front end and tight on the evaluation. This is a better role for the federal government, as it incorporates necessary amounts of humility, innovation, and accountability.

Scope
The scope of RTT-D is very broad, a challenge compounded by the fact that applications will likely have 60-90 days to write an application. Specifically, the scope of the “Competitive Preference Priority—Results, Resource Alignment, and Integrated Services” is extremely wide, and, moreover, involves a sub-set of education reform work that is very different from personalized instruction. This is not to say that integrated services are not important; rather, that in 60-90 days it will be extremely unlikely for LEAs to develop both high-quality personalized learning proposals as well as high-quality integrated service proposals.

Recommendation (3): Remove the “competitive preference priority” status of the integrated service component. Instead, include it as an “optional budget supplement” and increase the supplement to $3 million. For LEAs that have excellent integrated plans, they can use the supplement to forward this important work. But LEAs who have to develop new plans for both personalized learning and integrated services will not be required to tackle both in such a short timeframe.

Structure
In more entrepreneurial environments, the roles between LEAs and non-profits are more fluid. Specifically, in New Orleans non-profits have partnered with LEAs on multiple grants (i3, TIF) with significant success. As such, it may make sense to remove the restriction that only LEAs or new collaborative entities can be the fiduciary agent.

Recommendation (4): Allow existing non-profits to be lead fiduciary agents.

Thank you for considering these comments. I hope they are of use.

Neerav Kingsland

I respectfully suggest two things that I believe will strengthen the application and ensure much higher outcomes:
(1) adding at least one additional signatory to the application, from either a supportive business or community organization. Although the non-education signatories could not be held formally accountable for what the district does, their addition would recognize that the success of any kind of school improvement effort requires public/private/civic collaboration.
(2) in that same vein: asking the education community alone to develop and then hold themselves accountable to a performance evaluation system that they develop for themselves suggests that the performance bar will be set too low. I suggest requiring a third party, best practices, partner.
Thanks for the opportunity to comment.
Dori Jacobson

I think it is fantastic that Race to the Top is helping improve the graduation rates and focusing on the successful future of our children. I am writing to encourage that the program grants be open to Early Childhood programs as well. It is a well known fact that brain research has shown that what a child learns by age 5 sets the stage for their entire life, including how they will do in school and if they will graduate. It is very important to start a child off for success as early as possible. Thank you for considering my comments and for all the program is doing.

Sincerly,
Melissa Myers

Inclusion of Health Education and Physical Education in Successful RTT-D Applications

While the childhood obesity epidemic grows, schools today do not provide adequate health education or physical education, as recommended by leading healthcare professionals, health-related national organizations and the Centers for Disease Control and Prevention. In many school districts throughout the country, subjects that are not considered “core” have been marginalized or eliminated due to a lack of Congressionally directed funding or administrative priority - the Administration’s blueprint for ESEA reauthorization does not include health education or physical education.

To rectify this, health education and physical education should be included in this competition through professional development, innovative curriculum, engagement of parents and community, and the ability/desire of a district to create a culture of health and wellness in its schools.

Additionally, recent studies show that health and fitness are linked to improved academic performance, cognitive ability, and behavior as well as reduced truancy. Data from the Youth Risk Behavior Surveillance System administered by the Centers for Disease Control and Prevention (2008-2009) shows that students who engage in health-risk behaviors (such as inactivity, increased screen time, unhealthy eating and drinking habits) receive lower grades. Including health education and physical education in this competition will undoubtedly assist in making progress towards closing achievement gaps.

The Diplomas Now Collaboration (City Year, Communities in Schools, and Talent Development Secondary) applauds the Department of Education's efforts to empower districts to make bold, locally determined improvements in teaching and learning through the Race to the Top District (RTT-D) competition. We appreciate the Department of Education's efforts to require the creation of personalized learning environments that leverage student data to improve student outcomes and to encourage community partnerships through the Competitive Preference Priority.

We do, however, have some concerns about three of the definitions, including: on-track indicator, student attendance, and turnaround strategy. We urge the Department of Education to consider the revisions below.

On-track indicator: As it is written some districts may capture all of the requisite student data with this indicator; however, others may choose to examine a single indicator that does not accurately assess whether a student is truly on track to high school graduation and post-secondary success. As such, we propose changing the on-track indicator definition to: "A measure, available at a time sufficiently early to allow for intervention, of a composite of the three characteristics - attendance, behavior, and course performance - shown to most accurately predict whether a student is on track to on time high school graduation and post-secondary success. To be considered on-track a student must attend school 90% or more of school days over the course of a school year, have no suspensions over the course of a marking period, and perform on grade level in core academic courses."

Student attendance: We applaud the Department of Education for drawing attention to the importance of student attendance through the RTT-D competition. However, research has shown that monitoring the percent and number of students who are chronically absent - missing 10% or more of school over the course of a year for any reason including excused and unexcused absences and suspensions - is just as important as assessing student attendance. As such, we urge the Department to require participating districts to measure both student attendance and chronic absenteeism.

Turnaround strategy: RTT-D provides a unique opportunity for the Department of Education to encourage districts to invest their school improvement dollars in evidence-based, comprehensive school reform models shown to improve student and school outcomes. The Department of Education could do this by adding a competitive preference priority for districts that partner with a turnaround partner to ensure that all school reform efforts are coordinated, that school schedules allow for common planning time for inter-disciplinary teacher teams to review student data and personalized learning plans, and that all school improvement strategies are data-driven. The Department of Education should encourage districts seeking to obtain this competitive preference priority to partner with i3 scale up and validation grantees and other programs that meet the rigorous standards required of these i3 grantees. Partners of this caliber will not only provide districts with a clear road map to comprehensive reform, but also ensure that federal dollars are invested in programs that produce measurable results for schools, districts, and communities. It would be a missed opportunity not to align RTT-D in a way that leverages investments in i3.

The Association of Public Television Stations is pleased to submit comments on the proposed priorities for the Race to the Top - District grant competition. We are encouraged by the personalized learning and partnership priorities, as well as by the mentions of using digital assets, but feel there are a few opportunities to improve this competition.

Overall, we believe this grant competition is a missed opportunity to be bold around schools’ use of digital content and resources. The priorities would be more in line with the Department’s stated commitment to building students’ technological literacy if digital elements were fully integrated and non-negotiable. Digital technology provides vast opportunities to personalize students’ learning experiences and provide teachers with the tools to adapt their methods for users with different needs, abilities, interests, and preferences. Not fully integrating digital technology into this competition is an oversight.

Use of Digital Resources

While we support the inclusion of the Learning and Teaching selection criteria, we think these requirements must go beyond “including digital learning content as appropriate.” Children learn in a variety of ways, and the strongest resources and services are those that can engage them on multiple platforms. In fact, research shows that when high-quality video, online, and print materials are combined with teacher training, lesson planning, and classroom instruction, children from low-income backgrounds were able to make such rapid growth in reading that they narrowed or closed the achievement gap with middle-class children (Pasnik et. al. 2007). Proven-effective digital resources exist and should be implemented more broadly. Districts should be required to implement high-quality multiplatform digital content and services to students and teachers, including embedding professional development into these resources.

In both the “Learning” and “Teaching” sections, “including digital learning content as appropriate,” should be changed to, “including high-quality multiplatform digital content and services.”

Definition of Digital Learning Content

In this document, digital learning content is defined as “Learning materials and resources that can be displayed on a digital device and shared electronically with other users. Digital learning content includes both open and/or commercial content.”

This should be much more specific. Adding one digital textbook is not enough to improve students’ capacity for technology and digital learning. Digital content providers like public media stations provide bold and effective content and resources, and it isn’t enough to just “check a box” on digital, when richly diverse and engaging materials are available.

We propose changing the term “digital learning content” to “high-quality multiplatform digital content and services,” which is defined as “Learning materials or resources that can be accessed in different formats, including digitally, and available in in- and out-of-school settings.”

Partnerships

The proposed criteria incentivize partnerships, but we believe that nonprofit organizations should be more involved in the RTT-D program. We propose amending the eligible applicant definition to include non-profit organizations in partnership with an LEA or consortium of LEAs, similar to the eligibility definition in the Investing in Innovation (i3) program.

We also believe that the explanation of potential partner organizations should be clearer. The competitive preference priority singles out “after school” providers as possible partner organizations, but we think this should be expanded to include summer programs, before school, after school, and expanded learning time providers, and public media stations.

Respectfully,

The Association of Public Television Stations