Race to the Top District Competition Draft

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

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

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

Please check our RTT-D Program page for updates.

Thank you


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

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

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

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

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

The Department is posting this document on a moderated site, which means that all posts will be reviewed before they are posted. We intend to post all responsive submission on a timely basis. The Department reserves the right to withhold comments that are: unrelated to this request, inconsistent with the Department's Web site policies, advertisements or endorsements and/or otherwise inappropriate. Additionally, to protect your privacy and the privacy of others, please do not include personally identifiable information such as Social Security numbers, addresses, phone numbers, or email addresses in the body of your comments. For more information, please be sure to read the "comments policy."

Please understand that posts must be related to the Race to the Top District competition and program, and should be as specific as possible. We ask that you limit your post to 2,000 words. All opinions, ideas, suggestions, and comments are considered informal input and, again, the Department will not respond to any posts. If you include a link to additional information in your post, we urge you to ensure that the linked information is accessible to all individuals, including individuals with disabilities. We look forward to receiving your ideas and suggestions. However, the input you provide in your post may or may not be reflected in the final Race to the Top District requirements, priorities, selection criteria, or definitions or other policies that are announced in the Race to the Top District notice inviting applications.

Comments

I encourage the Department to include a priority for districts pursuing innovative ways to increase school-level diversity. As the "Guidance on the Voluntary Use of Race" and the "Supplemental Priorities for Discretionary Grant Programs" have shown, the Department recognizes the importance of promoting diverse classrooms. Research demonstrates that diversity provides academic benefits to all children, especially those at risk. This district competition provides an important opportunity to pursue this goal, as districts are particularly well situated to address diversity within their schools. There should be a competitive priority in the program that rewards districts that craft plans to help avoid concentrated poverty and racial isolation and instead encourage socioeconomic and racial diversity at the school and classroom levels.

I am a school board member of a local school board, and as such have been appointed by my board, the Robbinsdale School Board to serve on a Joint Powers Board of the West Metro Education Program (WMEP) an Integration School District in Minneapolis, MN. The joint powers board seerves over 100,000 students and staff in the collaborative relationship; and includes the staff and students of Minneapolis Public Schools. The districts collectively have a wide range in the demographic make-up of the districts, with virtually all of the first ring suburban districts now mirroring the high percentages of minority and free and reduced lunch students attending, versus the much lower numbers enrolled when the Joint Powers agreement was first established in about 2000.

WMEP is based in part upon the premise that racially integrated learning environments provide a compelling and important variable that enhances the academic achievement and the social development of our students who face a more and more culturally and racially mixed world, workplaces, and everyday living that requires skills that are best developed in an educational environment that fosters such exchanges. We urge the DOE to include specific language that highlights, embraces, and notes the importance of this type of consideration in planning by districts choosing to participate in Race to the TOP!

Thank you addressing this important issue. Thank you also for recoginzing our program and inviting our Principal, Mr. Kevin Bennett to attend an upcoming meeting at the Department.

Helen J.m. Bassett, Chairwoman
West Metro Education Program (WMEP)

Districts in particular are in a unique and optimal position to promote diversity, both within schools and districts, and between neighboring districts.

Reducing racial isolation in public schools is an important goal shared by the Department of Education and school districts. Race to the Top provides an important opportunity to implement your stated commitment to school diversity in this important funding program.

Simply put, federal funding should reward innovative approaches to achieving racial and ethnic diversity, and should not support proposals that choose to maintain or increase poverty concentration and racial isolation in schools.

It's critically important for the health and well-being of not only our kids, but our country, to include Health and Physical Education in the criteria for grant applications. Research shows that kids who are healthy attend school more often and they do better academically.

Also, quality before school, after-school, and summer learning programs need to be included in the application because they are successful strategies that engage kids that might not otherwise stay in school.

I feel that Early Childhood Programs should be considered in this grant proposal. I work at a DDTCS. Most of the children who are referred to our program have speech difficulties. Many of them have Cognitive, Adaptive, Social, and Motor problems. Some are physically disabled.

We provide activities that help the children gain knowledge and manipulative abilities that are necessary when they transition to Kindergarten. Now, children are learning skills in Kindergarten that use to be taught in the second or third grade. We feel that our programs help to give the children an advantage that will keep Kindergarten from being so difficult and to keep them from starting out behind.

Thank you for considering my comments.

The National Alliance for Public Charter Schools (NAPCS) commends the US Department of Education (the Department) for stressing the importance of an individually focused approach in the Race to the Top District (RTT-D) program. For twenty years, public charter schools have been have used this approach to provide excellent educations for their students. While the RTT-D program has the potential to provide additional resources to a charter sector facing a variety of budgetary constraints at all levels of government, as well as increase the potential for the growth and expansion of the most highly effective models, NAPCS does have a number of concerns and recommendations, detailed below. Most notably is the number of ways the program fails to be inclusive of the unique nature of some aspects of charter schools, namely in size and student populations served.
Accordingly, NAPCS submits the following comments and recommendations for RTT-D for the Department’s consideration.

Eligibility Criteria
Criterion 2 outlines the minimum size of an applicant. This size limitation negatively impacts a variety of LEAs, including rural and special districts. Most notably, however, is that in those states where charter schools serve as their own LEA (and are thus eligible to compete in RTT-D) an extremely small minority of LEAs would be eligible to meet this size requirement. According to the Common Core of Data for the 2010/2011, only 27 of the 2,525 charter LEAs, or 1.07% would be eligible to meet this size requirement. This poses an extremely unfair burden to charter LEAs who would be forced to participate only as a part of a consortium, at drastically higher rates than traditional LEAs. When reviewing the data, it is clear that a lower minimum size requirement would be both more inclusive to charter LEAs and be more in keeping with the Department’s focus on independent education.

LEA Size Number of LEAs Eligible (2010/2011 school year)
2500 27 (1.07% of charter LEAs)
1500 66 (2.61% of charter LEAs)
1000 91 (5.86% of charter LEAs)

Recommendation: Lower the size of LEA eligibility to 1000 students, and create a lower grant threshold for this group.

Criterion 4 outlines the evaluation requirements for the application. Eligible applicants must provide an assurance that they have designed and committed to implement, no later than the 2014-15 school year, evaluation systems that include student growth as a significant factor for teachers, principals, superintendents, and school boards. Under the 42 different state charter school laws, there are varying approaches to charter LEA structures, which is not taken into account in this section.

Recommendation: Evaluation systems under RTT-D should be designed in ways that take into account charter school governance consistent with state law (especially with regard to superintendent and school board evaluations which may not be applicable to charter districts in some instances), allowing for the charter LEA equivalent of superintendents and school boards, in particular.

Selection Criteria:

Vision
In section A2, the proposal requires applicants to include their LEAs high school graduation rate. This requirement assumes that there is at least one high school within the LEA. This is not the case for all charter LEAs.

Recommendation: NAPCS believes that the criteria should be amended to include completion rates (for elementary and/or middle schools) or graduation rates and college enrollment as appropriate. This change would maintain accountability requirements while also allowing eligible applicants that do not include a secondary school to participate in the program.

District Capacity
The first requirement in this section requires applicants to illustrate a four year track record of success. NAPCS is concerned that this requirement would give new, but successful, charter LEAs from participating in the RTT-D program.

Recommendation: If applying as a consortium, at least one member must have a proven for year track record of success, while all other members must illustrate an increasing rate of success for each year in existence, if less than four years. If applying as a stand-alone LEA, in existence for fewer than four years, the applicant must illustrate a proven record of success for each year in existence.

Preparing students for College and Careers
The performance measurements section includes a requirement that the grantee have established graduation rates. This language assumes that there are schools within an LEA which have or will at some point in the future include high schools which graduate students.

Recommendation: NAPCS believes that the criteria should be amended to include completion rates (for elementary and/or middle schools) or graduation rates and college enrollment as appropriate. This change would maintain accountability requirements while also allowing eligible applicants that do not include a secondary school to participate in the program.

Definitions
Participating Schools: Schools that are identified by the LEA and choose to participate. NAPCS is concerned that this definition does not require that LEAs will ensure the adequate participation of public charter schools.

Recommendation: The definition should be clarified to ensure that LEAs include public charter schools in an equitable manner to traditional public schools with regard to participation in RTT-D activities. Additionally, given the potentially strained relationships some charter schools experience with their traditional LEAs, NAPCS recommends that all communications of participation be required to be made in writing, and submitted as part of the RTT-D grant.

To see the NAPCS full comments on this proposal, please visit our webiste: http://www.publiccharters.org/editor/files/Federal/NAPCS_Comments_RTT-D%...

I firmly believe that the notice inviting applications should include the military child as an absolute priority.

I think that military-connected students should be added as a competitive priority.

The National Congress of American Indians (NCAI) is the oldest and largest American Indian organization in the United States. As the most representative national Indian organization, we serve the broad interests of tribal governments across the country. Tribal leaders founded NCAI in 1994 in response to termination and assimilation policies. Since then, we have fought to preserve the treaty rights and sovereign status of tribes and to ensure that Native people may fully participate in the political system.

NCAI appreciates the opportunity to provide feedback on the Race to the Top District (RTT-D) draft requirements, priorities, selection criteria, and definitions. We also welcome RTT-D’s focus on moving beyond one-size-fits-all models of schooling—models that have rarely addressed the unique needs of American Indian and Alaska Native students—to instead focus on supporting student-centered instruction. However, NCAI is deeply concerned that the draft competition will do little to improve the education of Native students because it fails to include—much less even mention—tribes or the Bureau of Indian Education (BIE). This exclusion stands in stark opposition to RTT-D’s express purpose of raising the achievement of all students and decreasing the achievement gap across all student groups. It also goes against Executive Order 13592, “Improving American Indian and Alaska Native Educational Opportunities and Strengthening Tribal Colleges and Universities,” which aims to leverage and coordinate federal resources to expand educational opportunities for Native students.

Indian education is in nothing less than a state of emergency. Native children experience large disparities in academic achievement and educational attainment: our reading and math scores are substantially lower than that of other groups, and we face some of the lowest high school graduation rates in the country.(1) Even fewer of our students enroll in and graduate from college.(2) The situation is even more dire in BIE schools, where during the 2010-2011 school year, the graduation rate stood at 59 percent and barely one-third of students performed at proficient/advanced levels in both language arts and math.(3)

Given this context, as well as the federal government’s trust responsibility to provide Native children with a quality education, any federal effort to effect national educational reform must meaningfully include tribes and all of the school systems that serve our Native students. Tribal inclusion is particularly imperative for the goals of the RTT-D competition, which seeks to “personalize” and “tailor” education to each student and “support bold, locally directed improvements in teaching and learning that will directly improve student achievement and teacher effectiveness.”(4) For Native students in tribal communities, tribal partnership and input exemplifies locally directed education and will be critical to developing a student-centered learning environment that meets Native children’s unique cultural and linguistic needs. Accordingly, NCAI recommends the following changes to the RTT-D competition draft.

Explicitly Make Bureau of Indian Education (BIE) Schools Eligible for RTT-D
Local educational agencies (LEAs) are eligible to compete for funding under RTT-D. The draft competition criteria only includes one part of the definition of LEA as offered in the Elementary and Secondary Education Act (ESEA) and does not include the provision that applies to BIE schools, thereby excluding them from the competition.(5) As educational home to some of the nation’s highest-need and most at-risk students, BIE schools must be eligible to compete for RTT-D. While BIE schools on their own do not have the requisite student population of at least 2,500 children to qualify for RTT-D, they should be eligible to apply in consortia in the same way that small, rural LEAs can.

  • The definition of “local educational agency” in the RTT-D competition criteria should be amended to explicitly make BIE schools eligible for the RTT-D.
  • Suggested language to add from the ESEA: “The term [local educational agency] includes an elementary school or secondary school funded by the Bureau of Indian Affairs but only to the extent that including the school makes the school eligible for programs for which specific eligibility is not provided to the school in another provision of law…” (20 U.S.C. 7801).

Require LEAs on Indian Lands to Consult with Tribes on Their RTT-D Applications
In the draft competition criteria, LEAs are required to provide their respective state educational agency (SEA) and mayor, city, or town administrator five business days to comment on the application, and these comments must be included in LEAs’ application packages.(6) As sovereigns who are vital members of the American family of governments, tribes must be accorded this same deference and opportunity.

  • To apply for RTT-D funds, LEAs who reside on Indian lands should be required to consult with the appropriate tribe and provide them with the same five-day period to offer comments.

Require LEAs on Indian Lands to Submit Letter(s) of Support from the Appropriate Tribe(s)
Meaningful stakeholder engagement is a central component of the RTT-D draft competition criteria. However, the list of key stakeholders does not include tribes.(7) Native nations have a tremendous stake in the education of Native children, and tribal support of an LEA’s RTT-D application would help ensure that their plans incorporate the unique cultural and linguistic needs of American Indian and Alaska Native students.

  • LEAs on Indian lands should be required to submit letter(s) of support from the appropriate tribe(s) as part of their applications.

Grant Preference Points to LEAs on Indian Lands Who Submit a Plan to Consult and Partner with the Applicable Tribe(s)
Partnering with tribes—those who know their children and communities best—is crucial if LEAs are to effectively teach Native students and build educational systems that encompass all of their needs. However, while the RTT-D competition draft grants preference points to LEAs who have formed “coherent and sustainable partnership[s] with public and private organizations,” it does not list tribes as among the possible partners.(8)

  • Not only should the RTT-D criteria list tribes as potential partners, but LEAs on Indian lands should also receive additional preference points if they describe a plan to consult and partner with the applicable tribe(s).
  • Conversely, LEAs residing on Indian lands who fail to consult with the appropriate tribe(s) or include them as a key stakeholder should not be eligible for funding under RTT-D.

NCAI looks forward to working with the Department of Education to ensure that RTT-D serves all of our nation’s students, including American Indians and Alaska Natives. If you have any questions or concerns, please contact Ahniwake Rose at arose@ncai.org or (202) 466-7767.

Endnotes:
(1) U.S. Department of Education, Institute of Education Sciences, National Center for Education Statistics, National Assessment of Educational Progress (NAEP), 2005, 2007, and 2009 National Indian Education Studies.
(2) US Census Bureau, American Community Survey 2005-2009 estimates.
(3) Bureau of Indian Education, "Bureau-Wide Annual Report Card, 2010-2011." Bureau of Indian Education, "Bureau-Wide Annual Report Card, 2010-2011."
(4) Department of Education, "Race to the Top District Competition Draft: Executive Summary”: page 1. http://www.ed.gov/race-top/district-competition
(5) Id.: page 16.
(6) Id.: page 2.
(7) Id.: page 5.
(8) Id.: page 12.

First Five Years Fund Comments:
Race to the Top District Competition

The First Five Years Fund is grateful for the opportunity to comment on the draft requirements for the Race to the Top-District competition. We appreciate the Department’s acknowledgement that high-quality early learning makes an important contribution to achieving our nation’s college- and career-readiness goals, and we commend the competition’s focus on coordination, integration, and comprehensive services. Our comments are intended to clarify some key points that will improve the likelihood that districts focused on early learning will be able to take advantage of this opportunity and use it to support the high-quality programs for children from birth through age five that research demonstrates have a significant impact on long-term education, health, and economic outcomes.

Clarify That "Preschool" Means Birth Through Kindergarten Entry. We appreciate the specific reference to the fact that LEAs may file a "preschool through third grade" application (Eligibility Criteria, 1.a). We recommend that the Department make explicit that for purposes of this competition, its definition of the age span encompassed by "preschool" is birth through the age of kindergarten entry. This is the definition used by the Department in B-1 of its April 16, 2012 Non-Regulatory Guidance titled "Serving Preschool Children Through Title I, Part A of the Elementary and Secondary Education Act of 1965, as Amended," and it is one we fully support. We assume that it was the Department's intention to use consistent definitions, but we believe the application will be stronger if that is made explicit.

Ensure That Metrics Are Appropriate to Grade Spans. In the Selection Criteria, LEAs will be scored for the quality of their vision, which includes articulating goals in some specific areas. In A.2 of the Selection Criteria, those areas include performance on summative assessments, decreasing the achievement gaps (as measured by ESEA-required assessments), graduation rates, and college enrollment rates.

Research shows that over the long term early learning addresses all of those areas. However, these are inappropriate short-term metrics for a project focused on preschool through third grade or some subset thereof. Because summative assessments do not begin until third grade, many of the children affected by a preschool-third grade project would not take any summative assessments during the grant period – and they clearly would not graduate from high school.

We believe it is appropriate to require applicants to discuss how their applications will address these areas in the long term, but ask that the Selection Criteria clarify that for each grant the metrics – including ambitious yet achievable annual goals – may be modified to be appropriate to the age span included. For early learning, we encourage the Department to refer applicants to the definition of Comprehensive Assessment System outlined in the Race to the Top – Early Learning Challenge, which encompasses screening measures, formative assessments, measures of environmental quality, and measures of the quality of adult-child interactions, and offers a useful framework from which the applicants can select appropriate metrics.

o This issue also comes up under C.4.e under Performance Measurement.

Participating School Definition: In many communities, much or most of the early learning provided is offered not by the school district but by community providers. In some communities these programs are funded directly by the school district, and in others they may work in close collaboration with the school district using funding from other sources (particularly federal and state funds such as Head Start, state preschool, child care, or home visiting). While the existing definition of "Participating School" appears to allow for the inclusion of these providers as "Participating Schools," we recommend a clarification specifying that the schools identified by the LEA or consortium may include community providers of early learning that choose to work with the LEA or consortium to implement the LEA(s)' Race to the Top plan. The Department should use the definition of early learning providers utilized in the Race to the Top – Early Learning Challenge, which encompasses child care centers, family child care homes, providers of early intervention services, and Head Start and Early Head Start programs.

Funding Flexibility to Support Early Learning: In the Selection Criteria addressing Preparing Students for College and Careers, under Teaching, C.2.c.i indicates that school-level leaders should have autonomy over school budgets. We believe that autonomy would be strengthened by explicitly stating that school level leaders have the autonomy to use a portion of their budgets to create or support existing early learning programs, either in their building or with community providers.

Integration With Early Learning: In the Selection Criteria addressing Policy and Infrastructure, C.3, the district's policy and infrastructure will be stronger if there is alignment between early learning and early elementary practices – a true birth-to-third grade continuum. This could be reflected by adding text in C.3.a under a new romanet that states, "through – iv. The mutual alignment of early learning policies and practices with early elementary policies and practices as part of a preschool to third grade continuum."

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

The RttT-D proposal allows districts to apply in consortia, including with Education Service Agencies, which is a solid step toward making competitive grants more accessible to all schools. Most ESAs work with a consortium of districts and are in a perfect position to assist any districts wanting to collaborate on the grant. For instance, we meet at least monthly with district superintendents and key district personnel to work on collaborative projects or to keep districts informed on current issues. This provides a solid foundation for effectively implementing and sustaining any project between several districts. However, there is a concern about the eligibility of education service agencies. Please consider making the following changes to the RttT-D proposal:
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 eligible to apply as part of a consortium, the eligibility is not listed in the formal document. The current wording as listed in the Fast Facts summary of the criteria lists ESAs as an eligible entity, “…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), AESA is concerned that certain ESAs will not be eligible to support consortia efforts. We recommend striking the phrase “the State recognizes as LEAs and” in order to ensure that all ESAs are eligible entities in order to best help all students and districts.
• 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.
Dr. Jack McAlpin
Southern-Regional Educational Service Agency

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.

In terms of integrated services, there are many strong models out there whose structures should be emulated in the guidelines for this competition. The competition should stress models that support efforts to integrate schools along race and class lines. Much of the research shows incredible gains from our initial integration efforts post-Brown vs. Board. A few of the models:

SUN Service System of Multnomah County, Oregon -- incredible integrated service network

The Learning Community of Douglas and Sarpy Counties (Omaha) -- interdistrict partnernships, shared tax base

Model Schools for Inner Cities (Toronto) -- resource-sharing amongst schools in lower-income neighborhoods

Redwood City 2020 (CA) & Vision 2020 (Berkeley CA) -- interagency partnerships between the city, district and higher ed

Furthermore, if we are trying to push TRUE cradle-to-career results, resource alignment, and integrated services, then the program should support and seek to replicate controlled choice models like those that exist in Berkeley CA, Cambridge MA and Wake County NC. Research from Rucker Johnson at UC Berkeley has shown the gains students who attended integrated schools in the past few decades have achieved in many areas, from academics to income to health.

I strongly recommend that one (if not the only) priority be the efforts of appicants to promote diversity of students. Evidence shows that nothing is more important to the achievemnt of low income children than a diverse student population. The ability to go outside one's school district, intra-district efforts at diversity, and magnet schools should all be a priority.

The American Speech-Language-Hearing Association (ASHA) is pleased to have the opportunity to respond to the U.S. Department of Education’s (ED’s) request for comments on its draft requirements, priorities, selection criteria, and definitions for the Race to the Top District Competition and Program. ASHA is the professional, scientific, and credentialing association for more than 150,000 members and affiliates who are audiologists, speech-language pathologists, and speech, language, and hearing scientists. More than half of our members work in public schools and have an integral and active role in the school community. Therefore, education is a priority area for the Association. We are pleased to submit the following comments:

• As local education agencies (LEAs) develop their plans for reform, the “other education support specialists” and “educators” mentioned in ED’s proposal to be tapped by LEAs in the planning and implementation phases should include specialized instructional support personnel (SISPs), also known as related/pupil services providers. SISP, which includes speech-language pathologists (SLPs) and educational audiologists, with their specialized training and skills can assist with addressing the individualized learning needs of all students. Teachers should use the team of professionals (i.e., SISPs) to help address the physical, social, and emotional needs of students. SISPs– with their specialized training and skills–can assist with addressing the individualized learning needs of students.

• In order to safeguard the success of all children, the Department of Education must ensure that these school-wide providers of services, SISPs, contribute to the overall success of children and, as such, should be included in its overall efforts related to preparation, equitable distribution, recruitment, professional development, emerging promising practices, support, and recognition. SLPs provide appropriate assessment and treatment of students in all educational settings ranging from pre-kindergarten through high school. They serve students exhibiting a full range of communication disorders involving speech, language, swallowing, and related hearing disorders. SLPs also address personal, social, and academic issues that have an impact on the student’s educational outcome. Through collaborating with classroom teachers and other school staff, SLPs offer assistance by addressing the linguistic foundations of the curriculum for students with disabilities as well as those at risk for school failure, including struggling learners in general education. With the ever increasing diversity in schools, SLPs ensure that students receive quality and culturally competent services.

• Specific and targeted professional development opportunities must be provided for the wide variety of “educators,” including SISPs. One-size-fits-all training does not prepare all personnel appropriately. For example, SLPs, psychologists, school counselors, and other personnel that are part of the school team all need specialized professional development to best prepare them to deliver their very specific and specialized services. Using student growth data is one way to identify professional development needs, but it should not be the only way, especially for the majority of educators who do not have a specific high stakes assessment associated with their teaching responsibilities. Using staff surveys, supervisory conferencing, and observations are other ways professional development topics should be selected.

Thank you for the opportunity to share our comments and suggestions above. Should you have questions about our comments, please contact Catherine D. Clarke, ASHA's director of education and regulatory advocacy,

It is very simple, cutting Health and Physical education is not working. If we want childern to "Race to the Top" they need health and physical education. Health and physical education is needed now more than ever.

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

As a health education teacher, I feel that it is important to also include physical education and health education in the RTT-D.

What has been ingrained in what we called white American school intergration will not change the domiant culture heart conditon toward the so called miniortiy. I personally believe the cirruculum of the families should be incorporate in all schools to make familiea accountable just as much as teachers. teachers and faculty need to let go of their percieve iideas about "the other. Most people around the world have a desire to learn new things. Scholastic learner will always have a narrow point of view since ilearning only applies to what happening in the context of the classroom olnly. Giving A's or B's or C's to any students be it in elementary school, middle school, High school,or college is very objective and does not take into account whether the students can applies what they have kearn in situtations outside of the classroom. I have learned students who get straight throughout primary and secondary education and perhaps iin higher education runs iinto a brick wall with the knowwledge that they have attain from school. Therefore, just fgiving grades alone does not determine whether or not students really understand what they have llearn. If they respond as though they are in preschool or an intutive learners who really does ot understand the concept fully to use knowledge in another application or discipline. This is my biggger conderns for all students at any age

June 6, 2012
Reading Partners
106 Linden St
Oakland, CA 94607

On behalf of struggling readers all across the country, Reading Partners writes to thank you for encouraging local education reform through the Race to the Top District competition. The competition draft requirements released May 22, 2012 take important steps toward improving our education system by incentivizing personalized learning environments, integrating public and private resources and ensuring meaningful stakeholder engagement.

We commend the US Department of Education for an ongoing emphasis on data and results to effectively target scarce resources. The competitive preference for districts focused on individual student needs and partnerships with public and private organizations is critical. School districts cannot be left alone to address our educational challenges and incentives like this encourage high performing partners to step up as part of the solution.

In the final requirements for the district Race to the Top competition, we encourage you to specifically call out early literacy interventions as an essential component of early education and whole school reform, particularly for our most disadvantaged students. Whether a child can read well in elementary school is a key predictor of future life prospects, and our nation’s low-income students are getting left behind—only 17 percent of low-income 4th graders in the U.S. read at grade level. Strong reading and writing skills are foundational to being fully literate and are essential to socio-economic success. Research shows that 74 percent of students who are not reading at grade level by the 3rd grade will not graduate from High School.

Based on our successful experience partnering with schools and school districts, we encourage you to include high-quality early literacy education and intervention strategies as a part of the selection criteria for the final Race to the Top District competition requirements. Specifically, a focus on tutoring and one-on-one personalized literacy education is critical to ensuring struggling readers have the opportunity to succeed in school and beyond.

Reading Partners is a national literacy nonprofit serving over 3,000 K-5 students from low-income families with a success rate of nearly 90 percent in helping students improve their performance in reading. Reading Partners recruits and trains volunteers to provide weekly tutoring to struggling readers in Title I elementary schools.

This is a time of unprecedented challenge and opportunity for our country's education system and for our nation’s students. We look forward to continuing to partner with you to ensure all children in this nation have the reading skills they need to reach their full potential.

Sincerely,
CEO, Michael Lombardo

As a Health education teacher I feel that it is important to also include physical education and health education in the RTT-D. Studies have shown how beneficial health and physical activity is to learning. To exclude it would minimize it's importance.

As a parent activist in Northern Virginia working with minority parent groups to eliminate the achievement gaps, I urge the Department to include increasing diversity by poverty level and race in the criteria and priorities for the new funding to school districts. Many programs designed to close achievement gaps are doomed largely to fail without more urgent and effective efforts to reduce the opportunity gaps that are inherent [i.e., not "separate but equal"] in our schools, so many of which are re-segregating by class and race, in metro areas, within school districts, and even with grouping and tracking mechanisms within classrooms.

1) Districts in particular are in a unique and optimal position to promote diversity, both within schools and districts, and between neighboring districts.

2) The Department has emphasized its revitalized mission to address racial isolation in public schools. (See, e.g., its Guidance on the Voluntary Use of Race to Achieve Diversity and Avoid Racial Isolation in Elementary and Secondary Schools (2011), making clear that school districts can lawfully work toward achieving their compelling interest in diversity, and its Supplemental Priorities for Discretionary Grant Programs (2010), including diversity as a permissible basis for a preference in federal funding competitions.) This competition provides an important opportunity for the Department to implement its stated commitment to school diversity in its most important competitive funding program.

3) Federal funding should reward innovative approaches to achieving diversity, and should not support proposals that choose to maintain or increase poverty concentration and racial isolation in schools.

It is important to include Health and Physical Education in this program. Why?
When Health is absent....
Wisdom cannot reveal itself,
Art cannot become manifest,
Strength cannot be exerted,
Wealth becomes useless, and
Reason becomes powerless

I very much agree with this comment! Health and Physical education should be included in the school setting without doubt! It is very important to teach health and wellness so students have a good handle on how they should take care of themselves as they get older.

I agree so much with this as well. Health and physical education are so important to have in the schools. Students need to learn the knowledge and have a chance to excell in different venues to learn that physical activity is good and doesn't have to be competitive. They can learn skills to last a lifetime.

Quality education for all children is of the upmost importance to the future of our country. Race to the Top plays an important role working toward an improved graduation rate and in preparing student for college
Research proves that during the early years of a child's life, the learning acquired impacts the success that child will have later in school. Due to the importance of early education, priority in approving grants should be given to programs that include ECE in their plan. Funding to help lower the cost of tuition to parents and to improve salaries to attract and keep more highly-trained professionals in the early education field are critical to making quality early education an option for every child.
Thank you for your consideration.

Inclusion of Health Education and Physical Education in Successful RTT-D Applications
It is important to include Health and Physical Education in this program. The one thing that every person has in common is we all have one body. Today's youth are unfortunately not living a healthy lifestyle. Obesity is growing, up to about 64% nationwide. By including Health and Physical education in this program, it would allow for more resources to continue to grow effective programs.
Today's physical education programs focus more on physical activity which have a lot of benefits for the whole student. Studies have shown that regular exercise rejuvenate brain cells and icrease in the overall learning ability. Schools that have effective programs generally have higher test scores and greater academic achievement. I hope that you will consider allowing Health and Physical education as part of the program

As a physical education teacher I feel that it is important to also include physical education and health education in the RTT-D.

As the Director of Secondary Education and CTE in a small, rural school district, I am concerned about the requirement that LEAs who apply must have the ability to match student level P-12 and higher education data. How much individual data from higher ed. will be required? What incentives are there to encourage the higher ed. institutions to help us meet this requirement?

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. I, personally, have received comments that my classes were the reason a student came to school. Students receive real-life opportunities for cooperation, collaboration, empathy and communication in addition to the physical activity they may be lacking with a strictly "core curriculum" day. 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.

Sincerely,
Martha M. Torrey
Allegany-Limestone Central School
Physical Education teacher
District Wellness Coordinator

It is so important for you to include Health and Physical Education so that our students are getting a knowledge that they can use to help them in their daily lives to live healthy. We need these education programs to help fight obseity and child hood diseases. Please do all that you can to keep these education programs in tact.

Please include Health and Physical Education in RTT. Childhood Obesity is skyrocketing in our schools and we need quality health and pe programs to help combat this. Plus Physical Exercise has been linked with better academic performance.

Definition of Student Attendance

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 is "the average percentage of days that students are present for school." Averages for schoolwide attendance can mask significant numbers of chronically absent individual students. For example, in Rhode Island's four core city school districts (the districts with the highest child poverty rates), average daily attendance in the elementary schools was 93% during the 2010-2011 school year, yet 20% of students in grades K-3 were chronically absent. Like Hedy Chang of Attendance Works and many others who have commented here, we would recommend using chronic absenteeism as an outcome measure, rather than average daily attendance.

Chronic absenteeism is defined as missing 10% or more of the school year, generally 18 days or more. Research over the past decade has documented the large number of students who are chronically absent as well as the toll these absences take on achievement and the connection to high school dropout rates. Missing so much school does not just affect the absent students, but impacts other students as well because teachers have to slow down the pace of instruction to accommodate students who missed lessons the first time they were taught.

In some districts in Rhode Island, more than 1 in 4 students in Grades K-3 are chronically absent and rates climb even higher in middle school and high school, where the most recent data we've reported show that in some districts almost one-half of students are missing 18 or more days of school (10% or more of the school year). Districts like Providence are focusing on chronic absenteeism and how to reduce it, recognizing that students cannot learn if they are not even in school.

We would encourage you to focus on chronic absenteeism as a key outcome measure and revise your definition of student absenteeism to reflect all of the research on the connection of chronic absenteeism to low educational achievement and dropping out.

Rhode Island KIDS COUNT

I believe that the Race to the Top grants will improve the graduation rate and ensure students are better equipped to attend college. It is imperative that priority be given in approving grants which include early childhood education in their plan. Research shows that what a child learn by age 5 sets the stage for their entire life. Without reaching children before the age of 5, the plan will miss the mark. Thank you for considering my comments. Melba Hobbs Connelly

Reach Out and Read applauds the thoughtfulness of RTT and ELCF specifically. As the current program is structured, it makes it diffcult for programs like ours, which are national in scope, serving more than 4 million children annually to apply because the children we serve are 6 months- five years of age and have no connective tissue to the LEAs within which they reside, especially in the first three years of life.

Given that we operate within the medical setting as a not-for-profit organization with virtually no infrastructure staffing, other than the physicians who are delivering the program, it makes it significantly difficult for us to reach out and form connections with LEAs.

If the RTTT application were to allow for not-for-profit organizations to apply without the direct partnerships with LEAs, it would include many education and literacy organizations to qualify, which currently cannot.

Thank you.

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

It is critical that Physical Education and Health be included in the Race to the Top District. In the words of Allen Russell: "Of all the subjects taught in school, Physical Education is the only subject which, by the very nature of it's context, has the potential to affect how a person will feel every moment of every day for the rest of his or her life" Truer words were never spoken. Physical education and health education need to be valued and included as part of a well-rounded education. Not doing so is at the cost of the well-being and future of our students. The conventional wisdom of considering them as add-on's or titled "specials" as they are often labeled and subject to being easily eliminated needs to be challenged.

The childhood obesity epidemic is out of control and schools can, and in fact have a responsibility to, be a huge part of the solution. They need the resources to do so through provision of adequate health education and physical education. Policy makers need a paradigm shift in the value of they place on these critically important subjects. Exercise is brain food; the science is clear, kids need to move to learn well. We need more, not less time for physical education particularly. We need to step back and see the paradox in marginalizing or eliminating these subjects for the sake of subjects thought to improve test scores. The truth is that by limiting time for movement, kid’s ability to learn well and excel on tests is diminished. The evidence is indisputable that healthy, fit kids focus, behave and learn better. By not seeing health and physical education as core subjects, we are compromising the heart of education in preparing healthy, productive citizens. If ever there was a time to invest in the wellness of our students, this is it.

Including Health education and physical education in the RTT – D will better foster a culture of health and wellness in its schools that ultimately creates the milieu for academic success. Given the proper resources, health and wellness will contribute mightily to the college and career readiness for our public school graduates. Promoting good health as a foundational asset to a viable, productive society continues to be undervalued and under appreciated.

I fully support the inclusion of physical education and health education in the RTT - D.

The Coalition for Community Schools (“Coalition”) at the Institute for Educational Leadership is an alliance of more than 150 organizations representing education, youth development, health and mental health services, social and emotional learning, community development, and related fields. The Coalition advances opportunities for the success of children and youth, as well as their families and communities, by promoting the development of more and more effective community schools.

We are very pleased that the research-based principles that drive the work of community schools across the country have been embedded into the draft RTT-D guidance and hope the following comments will help the Department and Local Education Agencies to strengthen this emphasis even further.

The Coalition is most excited that the only competitive preference priority focuses on results, resource alignment, and integrated services. This section is consistent with the principles of community schools and other place-based strategies that the Department has supported.

Under the competitive preference, the Department requires “coherent and sustainable partnership with public and private organizations.” This type of partnership is consistent with the leadership group comprised of key school and community stakeholders that are found in community school systems around the country.

Recognizing that standard test scores are insufficient for measuring student success, the Department also requires the aforementioned partnership to be organized to support a comprehensive results framework that includes education, family, and community results. We applaud the Department for its clear emphasis on a broad set of results that help create the conditions for teaching and learning.

Significantly, the Department also requires districts and their partners to identify how staff and families at the school-site will create the infrastructure and decision-making processes to assess needs and identify supports for students, families, and the community.

The Department’s draft guidance closely aligns with the community school strategies and structures described in the Coalition’s guide Scaling Up School and Community Partnerships: The Community Schools Strategy.

We are also heartened that the Department will require local review and comment from municipalities. Developing support from local jurisdictions is critical to successful implementation of a comprehensive strategy at the local level.

Eligibility Criteria
We are concerned about the requirement that applicants must meet a threshold of serving a minimum of 2,500 students. While consortia are a promising strategy, there is a cost in developing consortia that may make such applicants challenging, if not prohibitive for small rural districts. The Coalition suggests the Department reduce the threshold to under 2,000 students and fund these smaller school systems or consortia proportional to their size.

Absolute Priority 1, Personalized Learning Environments
The Department’s emphasis on personalizing instruction and supports to each child is consistent with best teaching practices. We suggest clarifying the strategies for personalization of supports however by modifying the sentence to include important social-emotional supports that create the conditions for learning (italicized):

“…to create student centered learning environment(s) that are designed to: significantly improve teaching and learning through the personalization of strategies, tools, and academic and social-emotional supports for teachers and students that are aligned with college- and career-ready standards….”

Selection Criteria; A. Vision; 2e. Student attendance
Research has demonstrated the importance of chronic absence as an indicator of student’s being at-risk of longer term school failure, and the potential for needing additional family supports. We suggest 1) either modifying the student attendance definition to include chronic absence or 2) adding an additional indicator that focuses specifically on chronic absence.

The definition of student attendance should be changed to:

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.

B. District Capacity and Success Factors; Reform Conditions; 3) Meaningful stakeholder engagement and support

The Coalition applauds the Department’s focus on engaging local stakeholders. For letters of support from key community stakeholders (B3b) to be meaningful, however, they must have a voice in the planning process (B3a). This change would be consistent with the Department’s continued emphasis on deep community engagement.

Consequently, we propose adding to 3a the following in italics:

“A description of how families, teachers, and principals in participating schools (as defined in this document) and such key community stakeholders as parents and parent organizations, students and student organizations, early learning programs, the business community, civil rights organizations, advocacy groups, local civic and community-based organizations, local government agencies, the local school employee organization, and institutions of higher education (IHEs) have been engaged in the development of the proposal…”

*Please note, we have modified “and/or” in the list to just “and” because it represents a more inclusive approach to partnerships. We have made this change throughout our recommendations.

To strengthen the definition of key stakeholders (we suggest adding “community” to that description) throughout the document, we suggest adding a new definition to the guidelines based on the existing language.

Key Community Stakeholders: Includes parents and parent organizations, students and student organizations, early learning programs, the business community, civil rights organizations, advocacy groups, local civic and community-based organizations, local government agencies, the local school employee organization, and institutions of higher education (IHEs).

C. Preparing Students for College and Careers; 1) Learning a) and b)
The work of community schools demonstrates that community partners have much to contribute to student academic success, through expanded learning, business partnerships, and internships for example. In this context we note that the role of community partners is noticeably absent from the key actors responsible for learning in this section. We suggest changing C1a and C1b to include the italicized:

“With the support of parents, teachers, and other educational support specialists and personnel, and such key community stakeholders as parents and parent organizations, students and student organizations, early learning programs, the business community, civil rights organizations, advocacy groups, local civic and community-based organizations, the local school employee organization, and institutions of higher education (IHEs), students…”

C. Preparing Students for College and Careers; 1) Learning a.iv)
A connection to the communities where student’s live in the curriculum is an important component of creating engaging and meaningful learning experiences. Consequently, we suggest adding the following in italics:

i) “Understand the relevance of what they are learning to their lives and goals and the communities in which they live.”

iv) “Are able to be involved in learning experiences of personal interest, including a focus on experiences connected to the student’s community;”

C. Preparing Students for College and Careers; 2) Teaching a.ii)

Similar to the comments above, the guidelines should more clearly emphasize the importance of the teaching and learning about community issues in order to increase the relevance of the curriculum to students and improve their engagement. We suggest:

“Adapt instruction in response to academic needs, optimal learning approaches (e.g., discussion, project-based learning, videos, audio, manipulative), the communities in which they live, and interests of students;”

C. Preparing Students for College and Careers; 2) Teaching c)
We suggest modifying the definition of “school leadership team” which is used in 2c to include a representative of key community stakeholders. We suggest adding: “community members and a representative of key community stakeholders”.

C. Preparing Students for College and Careers; 3) Policy and Infrastructure a)
We suggest adding a fourth point to reflect the growing recognition of the Universal Design for Learning principles as defined in the Higher Education Act. We suggest adding

iv. The application of Universal Design for Learning principles as defined in the Higher Education Act.

C. Preparing Students for College and Careers; 3) Policy and Infrastructure b.i & ii)
We suggest clarifying “other stakeholders” using the definition for Key Community Stakeholders we recommended above.

C. Preparing Students for College and Careers; 4) Performance Measurement
Surveys of educators (f) and students (g) should also include climate, culture, and the conditions for learning in order to paint a complete picture of the conditions in which teachers teach and students learn. Thus, we suggest making the following changes to the definitions for student survey:

Student survey: Measures students’ perspectives on teaching, learning, and related supports (e.g., school climate, school culture, and the conditions for learning) in their classrooms and schools. The surveys must be research-based, valid, and reliable.”

We suggest adding a parallel definition for educator survey (currently mentioned, but undefined) that would read:

Educator survey: Measures educators’ perspectives on teaching, learning, and related supports (e.g., school climate, school culture, the conditions for learning, faculty trust, etc.) in their classrooms and schools. The surveys must be research-based, valid, and reliable.

Finally, we strongly urge the Department to add a parent survey that would help districts learn more about parent engagement and their needs in supporting student learning. We suggest adding C4h) to read:

Parent survey: Measures parents’ perspectives on teaching, learning, and related supports (e.g., school climate, school culture, and the conditions for learning, teacher and principal support, opportunities for parent engagement) in classrooms and schools. The surveys must be research-based, valid, and reliable.

In order for all of these surveys to be useful, the Department should require applicants to explain how they are going to use the survey results to make changes to their plans, rather than just require a count and percentage of how many people complete the survey. We suggest the following language:

The number and percentage of participating (educators, students, or parents) who complete a survey…and specific strategies for how the applicant will incorporate survey results to inform their approach.

D. Transition Plan and Continuous Improvement; 3)
As illustrated in the guidelines and consistent with their previous statements, the Department correctly places a high value on engagement with parents and community stakeholders. However, we found the following point vague in regard to engagement: “High-quality plan for communication with both internal and external stakeholders.” We suggest specifying what communication the Department would like to see. It is unclear whether internal and external stakeholders should be included in the development of transition plans, updated about progress toward implementation, etc. Consistent with the principles of community schools, we suggest that communication rests on strong community engagement where internal and external stakeholders are working in partnerships on the preparation and implementation of transition plans. We suggest changing D3 to read: 3) High-quality strategy for engaging with internal and external stakeholders in the development, implementation, and assessment of the plan; and

F. Optional Budget Supplement
The concept of a budget supplement is an innovative approach to promote creative local practices. We would suggest that the examples in F1 be broadened to include: family and community engagement; family and community support; social, emotional, and health supports; expanded learning time and opportunities; and conditions for learning.

Competitive Preference Priority—Results, Resource Alignment, and Integrated Services
The Coalition is encouraged that the Department has made results, resource alignment, and integrated services through community partnerships key foci of this grant competition. We would recommend, however, that the Department either make this competitive priority part of the Absolute Priority or an additional Absolute Priority. Clearly the Department values collaboration towards results and making it an Absolute Priority would only make their case more explicit to applicants.

The Coalition would suggest the following minor changes to the language of the Competitive Preference Priority in order to include key community stakeholders in the development and implementation of the strategies described in the priority (in italics):

Add “parent and neighborhood groups” to the list of public and private organizations in (1). Parent and community buy-in and participation are essential to successful implementation.

“(3) How the partnership will enable…the integration of education and other services…for participating students and their families”

“(4) How the partnership will build the capacity of staff in participating schools and staff of community stakeholders and partners…by providing them with tools and supports to”

Definitions
Finally, research shows that families have a significant contribution to make when developing and implementing individualized or personalized learning plans. Consistent with the Department efforts to boost family engagement we propose the following definition of personalized learning plan as follows in italics:

“Personalized learning plan: A formal document, developed in partnership with parents and school staff, available in digital and other formats both in and out of school to students, parents, and teachers, that, at a minimum…”

I agree wholeheartedly with greater inclusion of parents, familieis, and neighborhood/community groups. I am addting organized community groups given my context which in New Mexico is not largely urban and therefore based on urban design. I also strongly encourage more meaningful and structured partnerships between teachers and parents where they can deeply discuss climate, cuilture, and improved/relevant condistions for learning...outside the current traditional structures.

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.

As an educator in Arkansas I support the Race to the Top initiative to provide exciting opportunities for states to receive funding for innovative programs. I am hoping that Early Childhood Education will be included in the final formation of this initiative. Early Childhood Education provides support for families of young children in a variety of areas. First, quality programs prepare young children for school success socially, cognitively, physically and emotionally. A quality program also includes parents in their children's education and gives them the confidence they need to continue to stay involved throughout their education. I am hoping that priority in approving grants will be given to programs that include Early Childhood Education in their plan. This will help to ensure that school districts will not ignore this population when making plans to improve their schools. Thank you so much for considering my comments. I appreciate the opportunity to have been heard.

Very Important. Health and Physical Education funding should be a must.

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.

I strongly believe that Health and Physical Education is just as important in the rcsd as any other subjects and should be compensated fairly due to the high importance. Without these two subjects are students might not be able to fully utilize other subjects without the proper knowledge and practice of Health and Phys. Ed.

Thank you for the opportunity to comment on the Race to the Top – District (RttT-D) Program. The Afterschool Alliance commends the Department for including personalized learning environments as an absolute priority and we encourage the Department and districts competing for RttT-D funds to consider the role of afterschool and summer programs in supporting personalized learning. In addition, we were pleased to see a competitive preference priority for the integration of public and private resources to augment the schools’ core resources through additional student and family supports. Afterschool and summer programs are a proven bridge between schools and families and are frequently supported by school-community partnerships. Both of these priority areas reflect the strong research base that highlights school-community partnerships and quality afterschool programs as effective means for supporting student success.

Education and youth development leaders across the country have made great strides to create access to individualized learning opportunities outside of the traditional school day. Student-centered approaches to learning acknowledge and respect the wide range of interests, aptitudes and needs of the students while supporting learning. In afterschool settings, particularly those grounded in strong school-community partnerships, student-centered programs empower and enable youth to pursue their own unique interests while also earning course credit and/or strengthening ties to the community. Through the student-centered learning opportunities offered in afterschool, youth can achieve a greater mastery of a broad array of skills needed for success in the 21st century and discover interests that will spur creativity and motivate them to succeed. Through participation in afterschool programs that shift the focus to learning and put them more in control, students can be better prepared to compete and thrive in a global, connected world.

Like many other commenters, we also suggest additional flexibility in the RttT-D guidelines to include an emphasis on health, nutrition and physical education, as well as science, technology, engineering and math, as these areas stand out as particular priorities to ensure success for today’s young people.

Quality, daily physical education in the nation’s schools
is an important part of a student’s comprehensive,
well-rounded education program and a means of
positively impacting life-long health and well-being.

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

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. A comprehensive health and physical educationprogram has a positive effect on wellness, disease prevention,academic success, psychological stability and social skills. A convincing body of knowledge shows that, as fitness increases, achievement increases, behavior issues decrease and wellness increases.
The childhood obesity epidemic continues to grow and 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.
Quality, daily physical education in the nation’s schools is an important part of a student’s comprehensive, well-rounded education program and a means of positively impacting life-long health and well-being. Including health education and physical education in this competition will undoubtedly assist in making progress towards closing achievement gaps.

Thank you

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.

I would like to whole-heartedly support this public comment and only add briefly that it is within the unique physical education construct that character attributes like caring and fairness come to the fore as a natural outcropping of the curriculum. While I appreciate the ability of other subjects to embrace problem-solving and even teamwork in their perview; I believe physical education to be singularly poised to put elements of character into practice on a daily basis. Building an accountable system, within which students and teachers alike are held to a high character standard, will demonstrate to the next generation that success bereft of character is not truly success at all.

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.

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

Including health and physical education into the Race to the Top District competition and program is vital. Simply put "You need to be healthy to learn and you need to learn to be healthy".

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
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As a teacher in the South Bronx I have first hand experience on the positive association that students have with physical activity and movement. I am proud to say that I have been able to incorporate and integrate math, literacy, geography, science, and social studies into my physical education classroom. When physical education teachers are given the opportunities to work and collaborate with other teachers, skills learned in the home classroom can be applied in the physical education classroom through games, instant activities, fitness, and individual and team sports.
By making health and physical education classes and innovative and meaningful curriculums part of the RTT-D application the government is ensuring that the minds and bodies of our youth are a high priority. It is time that we take our taxes and put them into quality education, quality teaching, and into the future of our country. Money should not be wasted on third party tests and assessments, but reinvested into quality curriculums and professional development for our teachers.Schools should focus on the overall well being of the students and invest in wellness, strong curriculums with technology, and professional development for their faculty.