U.S. Department of Education
The extent to which the State has demonstrated from January 2007 to the present--
On behalf of the Office of the Governor of the State of Illinois, the Illinois State Board of Education and the Illinois Department of Human Services: As was done in the earlier Race to the Top competitions we believe that a significant component of the scoring must relate to efforts to date, and we agree with the focus on past commitment, increased access, and investment in supporting Early Learning and Development Programs. However, we do not believe that January 2007 is an appropriate beginning point for this analysis as this date does not provide for a sufficient period of time before the commencement of the financial crisis. Instead, we suggest that the competition focus on commitments and increased access since January 2005, providing a sufficient period of analysis before State budgets were dramatically impacted by the financial crisis, or in the alternative, provide states with greater flexibility in demonstrating its past commitment.
We also believe it is critical that the analysis of a State's commitment to investing resources be solely in relation to the size of the State's population of High-Need Children, and that the scoring criteria should not punish a State if, due to the current financial crisis, it has been forced to reduce the level of its commitment but has still maintained a high commitment level in relation to other states.
The Children’s Defense Fund (CDF) is appreciative of the hard work reflected in the development of the criteria for this competitive grant process. Given the opportunity to review the document, CDF is submitting the following comments as an attempt to ensure equity in the award decision.
As this document is currently drafted, rural states will be required to demonstrate “commitment to investing resources in Early Learning and Development Programs” by stating the “amount of these investments in relation to the size of the State’s population of High-Need Children.” This is an important measure, however, rural states with smaller overall populations and state budgets will possibly be graded lower than states with a high urban population and greater total financial resources. In order to more accurately report a state’s commitment to Early Learning and Development Programs, CDF recommends that (A)(2)(b) be amended as follows:
(A)(2) (b) Its commitment to investing resources in Early Learning and Development Programs, including the amount of state and federal investments in relation to the size of the State’s population of High-Need Children and as a percentage of the overall average of the state’s total budget for each year from 2007-present.
This proposed language clarifies the ratio of investments in Early Learning and Development Programs given the overall total state resources as defined by the average state budgets from 2007 to the present, and is a more equitable measure of state commitment.
While this grant opportunity has defined "early learning and development programs" as (a) state licensed or regulated programs providing early care and education, B-K, (b) preschool programs, (c) Early Head Start and Head Start, (d) "any non-relative child care providers not otherwise regulated" -- many of the children it seeks to serve have a primary relationship with the state's child welfare, early intervention, or child/family mental health agencies.
To be competitive, this grant should expect that these child welfare, early internvetion, mental health agencies (or the consolidated children's agency where such exists, as in CT) be full partners in this work.
Too often, the early care and eduation agenda is all about child care and preschool, missing vital opportunities for essential cross-agency, family-centered and trauma informed service delivery.
It is also not unreasionable that a state might actually name its children's services agency (rather than its child care agency or K-12 agency) as the lead in this essential collaborative effort.
Dr. J.M. Gruendel, CT