In order to run a rigorous competition and obligate funds to grantees before December 31, 2012, the Department of Education (the Department) plans to waive formal rulemaking on this new program, pursuant to its authority in the General Education Provisions Act. However, the Department is very interested in your input. We encourage all interested parties to submit opinions, ideas, suggestions, and comments pertaining to the Race to the Top District (RTT-D) competition described below. Though the Department will not respond to comments, the Department will read and consider all comments in finalizing the RTT-D competition design.

The Race to the Top State competition incentivized bold and comprehensive reform in elementary and secondary education and laid the foundation for unprecedented innovation. A total of 46 States and the District of Columbia put together comprehensive plans to implement college- and career-ready standards, use data systems to guide teaching and learning, evaluate and support teachers and school leaders, and turn around their lowest-performing schools. The Race to the Top District competition (RTT-D) 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, RTT-D 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.


How does one correlate allowing students to progress at their own pace with heightened emphasis on standardized test score proficiency? Students cannot do what they haven't learned. If students choose a slower pace, they will not learn as much as the next student and, therefore, will not perform as well on standardized tests, which appears to oppose the ED's mission.

The 40% FRMP requirement worries me. Does this mean that monies are being pulled out of Title I to pay for this competition? If so, does the minimum 2,500 enrollment requirement violate Title I formula requirements between rural and urban schools? How can the Feds say that they have placed more emphasis on being fair to rural schools when they won't even allow them a fair opportunity to compete for such a large pot of money?

The $15 million minimum points to the same problem. How is a small school district with (say) two schools exepected to spend $15 million? Lowering the minimum to (say) $1.5 million would make the competition fairer to smaller school districts, who simply do not have the capacity to design and implement massive-scale technologies but could still offer some hghly effective solutions.

In short, do the $15 million and 2,500 student minima conflict with the program's stated goal to emphasize rural schools in the mix?

Citizen Schools commends the US Department of Education (Department) for its on-going efforts to use the federal Race to the Top program to encourage unprecedented innovation and bold comprehensive reform in elementary and secondary education. Citizen Schools currently partners with 16 school districts across eight states to expand the learning day with real-world “apprenticeships” and rigorous academic and leadership development activities, preparing students in the middle grades for success in high school, college, the workforce, and civic life. Our program has been shown through rigorous external evaluation to significantly boost school engagement, academic proficiency, and high school graduation rates.

We support the Department’s decision to create a Race to the Top, district level competition (RTT-D) that will reward LEAs committed to implementing the strategies, structures and systems of support tailored to the needs and goals of each student, with the goal of enabling all students to graduate college-and career-ready. We especially support what was noted on page 1 of the RTT-D Executive Summary, “As importantly, they (LEAs) 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.” Through Citizen Schools experience implementing research-based best practices for middle school students, we have found that students learn best and succeed academically and personally when they are given the opportunity to build upon their strengths and interests within a productive and safe environment with more time and caring adults.

This competition is an excellent opportunity for districts and their nonprofit and community based partners to scale and sustain proven education practices and models that decrease the achievement gap and increase the rates at which students graduate from high school prepared for college and careers. In order to help ensure successful outcomes for RTT-D grants, Citizen Schools believes all proposed criteria should encourage 1) partnerships with high-performing, nonprofit organizations, and 2) high-quality expanded learning opportunities for students.

Inclusion of All Youth Needing to Complete Their Studies: I recommend that you strengthen language to ensure that districts are considering alternative schools, disciplinary schools and over-age and undercredited students in their strategies. Although included in the definition of high need students, over-age, undercredited students and the schools that serve them are often overlooked in policy and programming. In addition, states and districts continue to under-invest in educational opportunities for OAUC students, thus continuing to push out or exclude them from access to education. This has powerful implications -- making it difficult for students who need access to education the most, young people returning from detention or disciplinary schools to re-enroll.

As a classroom teacher for 20 years, I believe that "quality" teachers strive to meet the needs of each child, but they do not have the freedom to do so. Due to so many "unqualified teachers" in the system, restrictions have been placed on "experienced" teachers that inhibit them from teaching with the fervor they desire.
Teachers are not allowed the freedom to select the professional development they need to expand their knowledge of how to meet the needs of the "kinds" of children we are teaching. The "higher" powers find ways to squash innovative ideas of creative teachers that do not fit the mold. Not every teacher needs the same professional development. It is important to enhance the teacher's learning experience so that he/she will better meet the needs of the child.
I think meeting the NEEDS OF THE CHILD is key in this portion, but having the "culture to enable teachers..." will be a the difficult aspect to evaluate.
I do believe that student "growth" is measured not with just a standardized test, but the child's whole range of achievement in all areas. Not everyone is good at everything, but we can provide "BALANCE" in what we teach our children AND make sure it is DEVELOPMENTALLY APPROPRIATE.