Race to the Top - Early Learning Challenge (RTT-ELC) Program

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 RTT-ELC competition.

We received 349 Responses from the public.

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

Please check our RTT-ELC Program page for updates.

Thank you.


Thank you for your interest in the RTT-ELC Program, the administration's signature early learning reform initiative. This program will be jointly administered by the U.S. Departments of Education (ED) and Health and Human Services (HHS).

In order to run a rigorous competition and obligate funds to grantees before the December 31, 2011 statutory deadline, ED will waive rulemaking for this new program, pursuant to its authority in the General Education Provisions Act. However, we want your input on how we implement the major elements of this program so we are posting this draft executive summary of the draft requirements, priorities, selection criteria, and definitions for the RTT-ELC competition on this Web site and we encourage all interested parties to share their comments with us. This document will be posted for public input until 5:00 PM EDT on July 11, 2011, 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. We will publish those requirements, priorities, selection criteria, and definitions in a Notice Inviting Applications in the Federal Register later this summer.

The RTT-ELC competition is a powerful tool that will help highly committed States provide more children from birth to age five from low-income families – with access to high-quality Early Learning and Development Programs. As with the first two rounds of Race to the Top, the bar to receive an RTT-ELC grant will be set high.

Through the RTT-ELC, we want to support breakthrough work that dramatically improves the quality of Early Learning and Development Programs serving High-Need Children. The competition will focus on key reforms, including aligning early childhood resources and systems and improving early learning and development standards and assessment, program standards, tiered rating and improvement systems, and early childhood educators. We will be looking to fund applications that demonstrate courage, commitment, capacity, and creativity.

In commenting on this document, we encourage potential applicants to identify barriers in current federal programs that may impede implementation of an ambitious, high-quality State Plan.

We are posting this document on a moderated site. That means all posts will be reviewed before they are posted. We intend to post all responsive submissions on a timely basis. We reserve the right not to post comments that are unrelated to this request, are inconsistent with ED's Web site policies, are advertisements or endorsements, or are otherwise inappropriate. Please do not include links to advertisements or endorsements, as we will delete them before we post your comments. 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 RTT-ELC competition and program, and should be as specific as possible. Each post must be limited to 1,000 words. All opinions, ideas, suggestions, and comments are considered informal input and ED and HHS 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 these posts might or might not be reflected in the final RTT-ELC requirements, priorities, selection criteria, or definitions, or the other policies that are enunciated in the final RTT-ELC NIA.

Again, thank you for your interest in this historic opportunity to support early learning. We look forward to hearing from you.

Note to reader: Defined terms are used throughout this document and are identified using initial capitalization. Definitions are provided later in the document.

Click the links below to read the draft requirements, priorities, selection criteria, and definitions; then click "Add a New Comment" at the bottom of the screen to tell us what you think about that item.


Comments

The American Library Association (ALA) appreciates this opportunity to provide comments about the Race to the Top - Early Learning Challenge. The ALA has long advocated and promoted early learner programs by developing specialized materials and training librarians on early childhood education. Currently, there are many public libraries providing direct services to young children as well as their families and caregivers through many projects.

Local library programs educate parents, caregivers, daycare and preschool staff in on how to provide the pre-reading skills necessary for a child to get ready to read. Libraries also provide programs for children, including infants and their parents, with story hours, age appropriate materials, and other fun programs designed to help young children get “ready to read.”
As guidelines and regulations for the Early Learning Challenge develop, the ALA asks the Department of Education and the Department of Health and Human Services to assure that the application requirements and outreach for participants, whether at the state or federal level, be developed to include public library pre-school reading programs.

Public libraries can partner in such activities in countless ways. One of the successful programs that many public libraries provide to develop a young child’s developing brain is “Every Child Ready to Read @ your library.” This is an early literacy education outreach program and incorporates five simple practices that parents can use when working with children. It includes these elements:

I. Talking – Children learn language and other early literacy skills by listening to their parents and others talk. As children hear spoken language, they learn new words and what they mean.

II. Singing – By singing with a child it slows down language so children can hear the different sounds that make up words.

III. Reading – Reading together with a child is the most important way to help children get ready to read. Reading together increases vocabulary and general knowledge. It helps children learn how print looks and how books work. Shared reading also develops an interest in reading. Public libraries offer many age-appropriate materials as well as a support staff to determine which reading materials would be best for a child.

IV. Writing – Reading and writing go together. Both represent spoken language and communicate information. Children can learn pre-reading skills through writing activities provide at the public library.

V. Playing – Children learn a lot about language through play. Play helps children think symbolically, so they understand that spoken and written words can stand for real objects and experiences.

It is clear that exposing a child to reading at an early age will increase their chances of success in the future. Public libraries and public librarians are trained professionals who help young children prepare to enter school and educating families and caregivers to support reading readiness. When crafting the Race to the Top – Early Learning Challenge, it is important that public libraries be included to expand the reach of these programs through communities, reflecting the services and partnerships important to early learners and their families.

Comments from the National Association for the Education of Homeless Children and Youth and Horizons for Homeless Children
July 11, 2011

We are writing to thank you for your efforts to strengthen local and state systems for the delivery of early education in the country. We were pleased when you announced that $500 million of the FY 11 Race to the Top (RTT) funds would be used to fund an Early Learning Challenge (ELC) competition in support of bold initiatives for increasing access and raising the quality of early education. We are eager to work with you to ensure that young homeless children are able to effectively enroll in early learning programs. We greatly appreciate the Department’s effort to ensure that states focus on high need and homeless children.

Across the country, there is an urgent need for early education and care for young homeless children. Public schools have witnessed a 38% increase in homeless children over the past four years. The number of young children experienced homelessness also has increased dramatically: the number of homeless children in Head Start has increased by 44% over the same time period. In 2008, 52.6% of all children living in homeless shelters funded by HUD were under the age of six.

While the McKinney-Vento Homelessness Assistance Act ameliorates some of the effects of homelessness on school-aged children, the impact of homelessness falls particularly hard on the very young, for whom living without a home can contribute to or exacerbate critical delays in physical, psychological, academic and social development. At the same time, parents experiencing homelessness with young children are unable to take important steps toward independence, such as pursuing an education, holding down a job, or finding a place to live, if they cannot place their children in high-quality early learning programs.

A number of states have recognized the risks that homelessness poses to a child’s development and have included children living in homeless shelters in their definition of “children in need of protective services” or “children with special needs.” However, even those few states that prioritize children experiencing homelessness under a special category in their Child Care Development Fund state plan often fail to serve the majority of this vulnerable population. In Massachusetts, for instance, fewer than half of the children in homeless shelters around the state are accessing early education and care programs. Simply put, without specific, intentional planning and outreach, homeless children and families will not benefit from the Race to the Top funds.

Additional resources for early learning programs are necessary. However, better coordination among the various state stakeholders in early education, with an intentional focus on young homeless children, would improve access to these programs for this most vulnerable population. Accordingly, we urge you to establish explicit criteria focused on the state’s strategy for effectively serving homeless children. Specifically, we recommend the following:

• Clarifying the definition of “high-need children” with the explicit mention of homeless children in the body of the application – in addition to the glossary section.
• States should be required to demonstrate they have a plan for efficiently identifying and serving young homeless children.
• States should be required to demonstrate they have a plan for effective coordination between state agencies responsible for early learning and K-12 education to ensure the seamless transition of these children from early learning programs to K-12 schools, including the Office of Education for the Homeless Children and Youth.
• States should be required to demonstrate that all state agencies with jurisdiction over early childhood, including Departments of Education and Health and Human Services, have been involved in the development of the application and consent to it. All applicants should be required to show progress in achieving a unified governance approach for early learning systems and services as a result of this grant.

We are excited about the potential of RTT-ELC to support state enrollment of additional, at-risk homeless children in quality early education programs. We know these programs make all the difference, ensuring that children experiencing homelessness are prepared to take their best step forward in life even when their parents are on precarious footing.

July 11, 2011

Dear Secretary Duncan and Secretary Sebelius:

On behalf of the Congressional Black Caucus, we write to ask your leadership to ensure that the Race to the Top-Early Learning Challenge grants address the problem of the disproportionate preschool expulsion of boys, especially boys of color.

Our Caucus supports the Administration’s effort to improve access and quality early learning programs, especially for low income children. Given that high-quality preschool programs improve school readiness and reduce racial/ethnic disparities in school readiness, preschool serves as a critical tool in reducing the racial/ethnic disparities in achievement in K-12 education. Given concerns that delaying examination of disparities in this area could contribute to and potentially worsen unequal educational opportunities, addressing the pattern of differential discipline treatment by race and ethnicity was identified as a joint priority for the reauthorization of the Elementary and Secondary Education Act by the Congressional Black Caucus, Congressional Hispanic Caucus, and Congressional Asian Pacific American Caucus. Research shows that disparities exist in prekindergarten with regard to discipline of students by race/ethnicity, gender, and the interaction of race-by-gender. The Yale University Child Study Center conducted a study of almost 4,000 prekindergarten classrooms representing all 52 of the national state-funded prekindergarten systems. The research found that African-American students attending state prekindergarten programs were approximately twice as likely to be expelled as preschoolers of European descent. Alarmingly, the data further revealed that being both a boy and a racial/ethnic minority places a preschooler at dramatically greater risk for expulsion. Specifically, African American boys are 8.76 times as likely as African American girls to be expelled. Similarly, Latino boys are 6.66 times as likely as Latina girls to be expelled. Asian American boys are 5 times as likely to be expelled as Asian American girls.

Given that funding for most state-funded preschools comes from a variety of federal sources (e.g., Title I, Head Start, IDEA Part B, Community Development Block Grants, TANF) and that the focus of the new Early Learning Challenge grants on increasing access and quality of early childhood learning, we strongly believe that the Department of Education and the Department of Health & Human Services should demonstrate federal leadership to understand and intervene quickly in disparate discipline treatment for students of various racial and ethnic groups. Specifically, examining and addressing disparate disciplining of preschoolers should be an explicit requirement to receive Early Learning Challenge grants. We appreciate that the definition of essential data elements includes child suspension and expulsion rates; however, we believe that both data examination and intervention are necessary. Research clearly demonstrates that differential discipline exists by race and by race-by-gender. Addressing disparate discipline treatment is consistent with the goals of the Early Learning Challenge grant and federal civil rights laws. Delaying intervention into disparities in this area threatens to contribute to and potentially worsen unequal educational opportunities. The Yale research indicates that cost-effective strategies exist that improve early childhood education and reduce preschool expulsion. Monitoring and addressing disparities in discipline of preschoolers now promises to improve educational opportunities sooner rather than later.

We thank you for your consideration of our request to include examining and addressing disparate discipline treatment of preschools as an explicit requirement to receive an Early Learning Challenge grant. We look forward to working with you to ensure high-quality education for all students.

Sincerely,

Emanuel Cleaver
Chairman
Congressional Black Caucus

Danny K. Davis
Chairman
Education and Labor Taskforce

We at Strategies for Children and our Early Education for All Campaign are encouraged by the commitment to young children evident in the Race to the Top – Early Learning Challenge recently announced by the Obama administration. Overall, the draft criteria identify critical components of a high-quality system of early learning. We appreciate all of the thoughtful comments that have been shared in this forum. In an effort to ensure that this initiative helps states to maximize current resources and create long-term, positive outcomes for young children, we offer the following recommendations to strengthen the criteria:

Alignment:
Strengthen Priority 4, “Sustaining Program Effects in the Early Grades” by challenging applicants to align early learning professional development, assessment, and curriculum with K-3. Alignment of standards and transition planning, as currently called for in the draft criteria, are necessary but insufficient activities on their own to ensure true alignment and program effectiveness towards the shared goal of proficiency by the end of third grade.

Professional Development and Instructional Leadership:
Strengthen Selection Criteria D, “A Great Early Childhood Education Workforce” by outlining key evidence-based principles. Professional development should:
-Be data driven, collaborative, and sustainable over time
-Occur in collaborative professional cultures that support ongoing improvement
-Include quality standards for identifying appropriate professional development offerings

The Early Learning Challenge sets an important precedent for the importance all state systems should place on nurturing the education and development of its youngest residents, and we look forward to engaging in further conversation about this exciting work.

On behalf of the more than 5,000 police chiefs, sheriffs, prosecutors, attorneys general, other law enforcement leaders, and victims of violence who are members of FIGHT CRIME: INVEST IN KIDS, thank you for your extraordinary leadership on expanding access to high-quality early learning programs. Our members know from the front lines in the fight against crime—and from the research—that these investments have a powerful impact on reducing later crime. We applaud the recent announcement of funding priorities and selection criteria for the new Race to the Top- Early Learning Challenge (RTT-ELC).

We are specifically pleased that RTT-ELC:
(1) Requires states, through an absolute priority, to use early learning and development standards to inform their program standards, curriculum, assessments, and professional development (Priority 1);
(2) Requires states, through an absolute priority, to demonstrate that they are implementing and validating (or have a high-quality plan to implement and validate) a tiered Quality Rating Improvement System (QRIS) and gives preference to states that increase the number of kids in QRIS-participating plans (Priority 2);
(3) Urges states, through an invitational priority, to enhance their K-3 standards and align them with the early learning and developmental standards, and to conduct ‘transition planning’ between early learning and elementary schools (Priority 4);
(4) Evaluates, through selection criteria, states’ efforts to identify and address the health, behavioral, and developmental needs of kids through developmentally appropriate screening and referral, and to promote and improve family engagement (B)(4)(c);
(5) Evaluates, through selection criteria, states’ efforts to enhance professional development for early childhood teachers and professionals (D)(1) and (D)(2); and
(6) Requires states to maintain comprehensive longitudinal data systems (as required by the America COMPETES Act) (Requirement (e)).

We urge you to build upon this excellent foundation by making two improvements that will help states ensure increased access for at-risk kids to the highest-quality early care and education programs:
(1) Upgrading “Sustaining Program Effects in the Early Elementary Grades” from an invitational priority to a competitive preference priority; and
(2) Strengthening the definition of “high-need children” to include additional risk factors for later crime and violence such as coming from a family with a history of child abuse, neglect, and/or substance abuse.

As you know, in addition to educational outcomes, high-quality early education programs also have a profound impact on reducing later crime and violence. At-risk kids who were left out of the high-quality High/Scope Perry preschool program were five times more likely to be chronic offenders (more than 4 arrests) by age 27 than those who participated. A study of Chicago’s government-funded Child Parent Centers showed that children who participated were 29 percent more likely to graduate from high school by age 20 and 47 percent more likely to have attended a 4-year college by age 28 than similar kids left out of the program. By age 26, those who did not attend the Child-Parent Centers were 27 percent more likely to have been arrested for a felony and 39 percent more likely to have spent time in jail and/or prison.

The first five years of a child’s life form the foundation for lifelong learning, but the gains from even the highest quality early learning programs will require continuous reinforcement and development as the child progresses through elementary school. Elevating “Sustaining Program Effects in the Early Elementary Grades” from an invitation priority to a competitive preference priority will make clear the importance of a smooth transition between early learning and elementary school and provide greater incentive to states to plan for this transition, helping ensure at-risk kids not only arrive in kindergarten ready to learn, but that they continue to learn throughout their years in school, as well.

Finally, abuse, neglect, and substance abuse profoundly affect a child’s ability to succeed in school, and children who survive abuse and neglect or substance abuse carry the emotional scars for life. Although not all children who survive abuse or neglect go on to become criminals, research shows that they are almost 30 percent more likely to commit a violent crime later on in life. Strengthening the definition of “high-need children” to include additional risk factors for later crime and violence such as coming from a family with a history of child abuse, neglect, and/or substance abuse will help make our communities safer by targeting resources toward kids at the greatest for future crime and violence.

On behalf of law enforcement leaders who have seen too many kids grow up to become criminals, thank you again for your excellent leadership on expanding access to high-quality early learning programs. We look forward to continuing to work with you to expand these proven investments in kids that help reduce crime and make our communities safer.

Sincerely,

Miriam Rollin
National Director

Nick Alexander
Federal Policy Director

We at Strategies for Children and our Early Education for All Campaign are encouraged by the commitment to young children evident in the Race to the Top – Early Learning Challenge recently announced by the Obama administration. Overall, the draft criteria identify critical components of a high-quality system of early learning. We appreciate all of the thoughtful comments that have been shared in this forum. In an effort to ensure that this initiative helps states to maximize current resources and create long-term, positive outcomes for young children, we offer the following recommendations to strengthen the criteria:

Alignment:
Strengthen Priority 4, “Sustaining Program Effects in the Early Grades” by challenging applicants to align early learning professional development, assessment, and curriculum with K-3. Alignment of standards and transition planning, as currently called for in the draft criteria, are necessary but insufficient activities on their own to ensure true alignment and program effectiveness towards the shared goal of proficiency by the end of third grade.

Professional Development and Instructional Leadership:
Strengthen Selection Criteria D, “A Great Early Childhood Education Workforce” by outlining key evidence-based principles. Professional development should:
-Be data driven, collaborative, and sustainable over time
-Occur in collaborative professional cultures that support ongoing improvement
-Include quality standards for identifying appropriate professional development offerings

The Early Learning Challenge sets an important precedent for the importance all state systems should place on nurturing the education and development of its youngest residents, and we look forward to engaging in further conversation about this exciting work.

The American Library Association (ALA) appreciates this opportunity to provide comments about the Race to the Top - Early Learning Challenge. The ALA has long advocated and promoted early learner programs by developing specialized materials and training librarians on early childhood education. Currently, there are many public libraries providing direct services to young children as well as their families and caregivers through many projects.

Local library programs educate parents, caregivers, daycare and preschool staff in on how to provide the pre-reading skills necessary for a child to get ready to read. Libraries also provide programs for children, including infants and their parents, with story hours, age appropriate materials, and other fun programs designed to help young children get “ready to read.”
As guidelines and regulations for the Early Learning Challenge develop, the ALA asks the Department of Education and the Department of Health and Human Services to assure that the application requirements and outreach for participants, whether at the state or federal level, be developed to include public library pre-school reading programs.

Public libraries can partner in such activities in countless ways. One of the successful programs that many public libraries provide to develop a young child’s developing brain is “Every Child Ready to Read @ your library.” This is an early literacy education outreach program and incorporates five simple practices that parents can use when working with children. It includes these elements:

I. Talking – Children learn language and other early literacy skills by listening to their parents and others talk. As children hear spoken language, they learn new words and what they mean.

II. Singing – By singing with a child it slows down language so children can hear the different sounds that make up words.

III. Reading – Reading together with a child is the most important way to help children get ready to read. Reading together increases vocabulary and general knowledge. It helps children learn how print looks and how books work. Shared reading also develops an interest in reading. Public libraries offer many age-appropriate materials as well as a support staff to determine which reading materials would be best for a child.

IV. Writing – Reading and writing go together. Both represent spoken language and communicate information. Children can learn pre-reading skills through writing activities provide at the public library.

V. Playing – Children learn a lot about language through play. Play helps children think symbolically, so they understand that spoken and written words can stand for real objects and experiences.

It is clear that exposing a child to reading at an early age will increase their chances of success in the future. Public libraries and public librarians are trained professionals who help young children prepare to enter school and educating families and caregivers to support reading readiness. When crafting the Race to the Top – Early Learning Challenge, it is important that public libraries be included to expand the reach of these programs through communities, reflecting the services and partnerships important to early learners and their families.

Comments on Race to the Top Early Learning Challenge
By ZERO TO THREE: National Center for Infants, Toddlers, and Families

About ZERO TO THREE: ZERO TO THREE is a national nonprofit organization that informs, trains, and supports professionals, policymakers, and parents in their efforts to improve the lives of infants and toddlers. We translate research and knowledge into a range of practical tools and resources for use by the adults who influence the lives of young children. If you have questions about this submission, please contact Patricia Cole (PCole@zerotothree.org).

ZERO TO THREE supports the goals of the Early Learning Challenge grants to further the development of state early development and learning systems and increase the access of the most vulnerable young children to high-quality services that can prevent or close the gaps they often face long before entering Kindergarten. We appreciate the thoughtfulness behind the components stressed in the draft summary of the Request for Proposals as well as the opportunity to offer comments.

We particularly appreciate the recognition of the importance of supporting development during the infant-toddler years, which has been present in the Administration’s proposals from the beginning. We applaud your commitment to developing a birth-to-five system. We believe, however, that the rationale for including infants and toddlers as an integral part of preparing young children for success in school bears reiterating in the guidance and the requirement that the system being supported through this grant include infants and toddlers should be reinforced throughout. The critical role of development in the first three years of life in ensuring later success in school is not always understood. Infant-toddler learning and the support which fosters it look very different from that of older children and therefore may become more of a sidelight or afterthought, rather than a crucial beginning point.

We know from the science, so clearly laid out over a decade ago in From Neurons to Neighborhoods, that brains are built from the bottom up. Early experiences, coupled with the influence of genes, shape their architecture, forming the foundation—either sturdy or fragile—for all learning, health, and behavior that follows. These early experiences are literally the bedrock for later development. Different types of learning take place at different times, for instance, there is an optimal period of time for language development during the first year of life. The optimal time for higher cognitive functioning is age three. Of course we continue to learn, but our brain is shaped by how we feel AND what we learn early on. These “peak” periods for learning are necessary—they need to build on one another so that higher levels of learning can take place.

Relationships are the context in which early experiences unfold and are critical to how we develop. Domains of development are interdependent and work together to promote a child’s overall health and well-being. Cognitive and social-emotional development are not separate arenas to be nurtured in isolation, with the former being the more important for school readiness. Rather, they go hand-in-hand, with emotional health and social competence providing a solid foundation for emerging cognitive abilities.

High-risk children are more likely to face challenges that can negatively impact their development and create disparities in their cognitive and social abilities well before they enter a program serving three or four-year olds.

Systems that support development, like brains, should likewise be built from the bottom up. Therefore the guidance should be exceptionally clear that state plans must address and provide proportional support to programs and quality components directed at infants and toddlers.

In addition, we support and appreciate the goal of building a strong infrastructure for out-of-home programs providing early care and development. However, we also note that many at-risk infants and toddlers are not in such arrangements, and their developmental needs must be supported as well. Under A)(3) Organizing and aligning the early learning and development system to achieve success, we recommend that states be encouraged to develop strategies for High-Need infants and toddlers that cross program lines and be required to articulate how the early learning and development system will coordinate with and, where appropriate, be integrated with home visiting programs. For example, we appreciate the inclusion of home visiting programs in section (B)(5) on family engagement. These programs work with parents in supporting their young children’s development and could incorporate quality components such as Early Learning Guidelines or Standards.

The Inter-Tribal Council of California, Inc. believes this will be a fruitful endeavor in the effort to improve educational outcomes for young children. Tribal communities are always among the highest need for social services such as the RTT-ELC, and a higher percentage of social problems exist in tribal communities compared to other racial, ethnic, and cultural groups. Tribal communities have the highest cases of teen-pregnancy, suicide, alcoholism, domestic violence, child abuse, sudden infant death syndrome, fetal alcohol syndrome, incarceration, high school dropouts, and juvenile delinquency just to name a few. It is imperative that Tribes are included in these types of projects.

Recommendations
1.) Language should be added to the proposal to describe how Tribes can/will participate.
2.) Legislation should be in place requiring the State Advisory Councils on Early Childhood Education and Care (being established by RTT-ELC) to include tribal governments.
3.) This proposal should give priority to programs that have quality standards in place rather than programs with licenses.
4.) States should focus on strengthening licensing structures, increasing monitoring visits, and overseeing provider qualifications.
5.) The proposal should recommend that states partner with Tribes so that resources can be combined for the benefit of all children.
6.) Assessments should be culturally appropriate and require evaluators to receive training in cultural competency.
7.) The RTT-ELC should include a description of how Tribes can be included in data collection.
8.) The proposal should state how and when data will be available for review by the public.

The California Department of Education provides the following comments:

•Allow for Greater State Creativity and Flexibility
We strongly suggest that states be allowed full flexibility in the implementation of RTT-ELC funds. This flexibility should extend to all aspects of the competition including program design, determining focus and priorities, and creation and execution of related state policy. This competition should, in its design, encourage and support state-led innovation in creating a cohesive system and enhancing quality in programs for young children.

As part of our recommendation, we feel states should be allowed increased flexibility in setting priorities that fit each state’s current situation. States are at varying phases of building and implementing early learning systems, and as such may not be in a position to address all of the federal priorities. California demonstrates a strong commitment to a number of the priorities but recommends that states be able to focus on some or all of the federal priorities as they fit into the state’s current level of progress and capacity. Specifically, we feel that Quality Rating Improvement System (QRIS) should not be mandated and that states should be allowed full opportunity to determine if, and how, a QRIS is implemented.

•Provide Strong Support to States
A strong network of support will be critical to the successful implementation of the RTT-ELC program and therefore federal agencies should provide states with ongoing technical assistance during the application process that should continue through the award period. We also believe that this program should include a learning community component, with participation available to all states, which encourages collaboration among states and promotes sharing of best practices.

•Align and Streamline Federal Early Learning Programs
States across the country are currently involved in efforts to develop comprehensive and cohesive early learning systems to promote school readiness for all children. In order to continue to advance this national early childhood agenda, states need increased coherence in federal early childhood programs. We encourage the federal agencies to provide states with more tools and flexibility in implementing federal programs.

•Focus on Building High-Quality State Systems
The CDE believes the focus should be on improving quality in the existing early learning system. Through enhancing and building upon the current state infrastructure, California can better facilitate access for high-need children into those high-quality programs.

Thank you for the opportunity to comment.

Camille Maben, Director
Child Development Division
California Department of Education

Comment of National Education Association RE: RTT-ELC

On behalf of 3.2 million members, the National Education Association is pleased to submit the following comments on the Race to the Top Early Learning Challenge (RTT-ELC) Comments.

GENERAL RECOMMENDATIONS

NEA strongly supports the overall goal of the RTT-Early Learning Challenge (RTT-ELC) to place greater emphasis and resources on early learning education so that children are better prepared to enter kindergarten and succeed in the K-12 public education system. We also applaud the Administration’s prior efforts to align early childhood education systems with the K-12 system.

However, we have concerns about two aspects of the program:

First, while we support efforts to develop and improve individual providers’ ability to assess and evaluate the learning skills and needs of preschool and kindergarten children, the implementation of any state-led system for the assessment of preschool and kindergarten-aged children should be accompanied by an exceptionally clear and limited purpose statement and an equally clear set of regulatory guidelines and limitations. RTT-ELC does not yet adequately articulate these elements, some of which we list here:

• The purpose of the Comprehensive System of Assessments and the kindergarten entry assessments should be to assist in the design of services, instruction and activities geared toward preschool and elementary-school-aged children as well as to enhance the professional development of early learning educators and providers - not to provide rewards or sanctions for children, employees, providers or programs.
• “Assessments” or diagnostic evaluations of kindergarten-aged children must be a) developmentally appropriate; b) designed to be flexibly administered by a local educator who has received proper training in assessing young children and c) responsive to the individualized needs of each child; these assessments or diagnostic evaluations must not be designed or administered in a manner akin to standardized assessments of older elementary-school-aged children.
• No assessment developed or used as part of this program shall be tied to any requirement of the No Child Left Behind Act.
• RTT-ELC should discourage the use of an assessment or even multiple assessments as the sole measure of any determination of a child or program’s ability or progress. There should be multiple sources of evidence across all domains of development and learning for infants, toddlers, and preschoolers, including observational reports that would help improve instruction, educational activities or the provision of needed services in the areas of health and social and physical development.
• Assessment systems, accommodations and modifications must be developed to address English Language Learners and children with disabilities or special learning needs.
• Child-centered diagnostic assessments should include a component that takes into account family and community circumstances and needs.
• Assessments should not be used to bar or deter any child from entering or remaining in any publicly funded preschool program.

Second, we encourage the Department to place greater emphasis on obtaining support from, collaboration with, or funding to local early learning service providers. Given the extreme recent cutbacks to local early learning programs nationwide, this is a serious omission. In the main K-12 Race to the Top (RTTT) program, governors of revenue-strapped states had the ability to reserve the maximum authorized portion of funding (50%) for the state itself, thus depriving many schools from immediately, if ever, reaping any tangible benefit from the program. States’ reservation of funds would likely be even more pronounced in the RTT-ELC, which, unlike RTTT, does not require that a percentage of the funding go directly to participating local providers. Even if there is not enough funding in RTT-ELC to provide grants to a large number of local providers, a state’s own reform plan would be more honed, tailored and achievable if it were developed in coordination with local service providers to pilot, develop or enhance local early learning provider systems.

Therefore, the Department should require a greater commitment to supporting local early learning service providers by amending Selection Criterion A to address “Successful State and Local Systems.” It should further require that states directly grant a significant percentage of RTT-ELC funds to local service providers for the purpose of developing or enhancing local early learning provider systems that can serve as beacons or models for other providers throughout the state.

NEA has additional specific recommendations concerning priorities and selection criteria, which we are placing in the relevant sections of this online comment area.

Donna Harris-Aikens, Director
Education Policy and Practice
National Education Association

The Association Montessori International/USA (AMI/USA) upholds Dr. Maria Montessori’s original vision. Through teacher training programs, school recognition and consultation, AMI/USA supports the work of Montessori parents, teachers, administrators and schools. We believe that the Montessori method is more than knowledge; it is “education for life.”

AMI/USA is a representative of an international organization with over 100 years of practice on six continents. There are roughly 19,000 students enrolled in Montessori programs in the United States. The majority of children in the U.S. are enrolled in private sector versions of Montessori, but noteworthy strides have been made in the public sector; this year, over 11% of our students were enrolled in public schools from seven different metropolitan areas nationwide.

Montessori public school programs have proven extremely successful in closing the achievement gap in the inner cities that they currently serve. According to research “By the end of kindergarten, the Montessori children performed better on standardized tests of reading and math, engaged in more positive interaction on the playground, and showed more advanced social cognition and executive control. They also showed more concern for fairness and justice. At the end of elementary school, Montessori children wrote more creative essays with more complex sentence structures, selected more positive responses to social dilemmas, and reported feeling more of a sense of community at their school” (Lillard, “Evaluating Montessori Education,” Science, vol. 313). By building a child’s capacity to develop successful learning habits at an early age, the standards upheld in AMI schools prepare children for life-long learning—first kindergarten, then secondary and beyond to college.

Montessori graduates, such as Google founders Larry Page and Sergey Brin, Amazon’s Jeff Bezos, and Wikipedia founder Jimmy Wales, pioneers in the digital world, have directly credited the exposure they received in Montessori classrooms to creative problem-solving as the basis for their later success.

Dr. Maria Montessori saw the vital import of using a holistic approach and working with the human child in all societies from the very beginning. AMI Montessori is for all children, beginning with infants and toddlers (aged 0-3) and continuing throughout the high school years. However, work with children 3-6 years old has the most important impact. This is one of the sole educational methods that is naturally coherent and designed to bridge all phases of childhood development.

Focused on creating high-achieving, joyful and engaged learners, Montessori fits the needs of today. By introducing young children to complex concepts and topics and using multi-sensory materials with the freedom to repeat, children in Montessori environments build strong literary and math skills. Within the Montessori community, Association Montessori International provides clearly defined educational standards and has rigorous and internationally accredited year-long teacher-training programs throughout the country, along with regular professional development opportunities. All of these factors, which are already in place and being implemented, are aligned with the initiatives set out by the Obama administration’s grant program.

It is my hope that more children will receive a quality education from the start, one that will impact their future. You are to be applauded for this important initiative.

Virginia McHugh Goodwin
Executive Director
AMI/USA

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

RE: Race to the Top – Early Learning Challenge (RTT-ELC)

Dear Secretary Duncan:

The National Association of State Boards of Education (NASBE) represents state and territorial boards of education, state board attorneys, and state board executive secretaries. State boards of education exist in forty-eight states, the District of Columbia, Guam, the Northern Mariana Islands, and Puerto Rico. NASBE appreciates the opportunity to submit comments on the Department’s draft executive summary of the draft requirements, priorities, selection criteria, and definitions for the RTT-ELC competition. NASBE believes that what is most critical in quality early learning environments is having highly trained and well-supported teachers who can provide responsive interpersonal relationships, nurture children’s dispositions to learn, and cultivate their emerging abilities, particularly their foundational literacy skills.

Based upon the review of the draft executive summary, NASBE has identified the following concerns for the Department to consider and address in its final draft of the executive summary and notice inviting applications from states for the competition. NASBE seeks to ensure the RTT-ELC competition and the Department’s peer review process is fair and equitable to all states, especially rural and frontier states.

Issue 1 – Provide Special Consideration to Rural and Frontier States
Draft award information indicates that awards may be granted to high-quality applications from states with large high-poverty, rural communities (including state with high percentages of high-poverty populations in rural areas, as well as states with high absolute numbers of high-poverty individuals in rural areas). NASBE urges the Department to provide an equitable proportion of awards to rural and frontier states with high-quality applications. It is essential for the Department to provide special consideration to rural and frontier states that continue to suffer unique and challenging education issues, including educator and leader recruitment and retention issues in high-need subject areas and technology access issues. Rural and frontier states also continue to deal with capacity issues that are
more severe than their urban and suburban counterparts.
The first two RTT competitive rounds led to the awarding of grants to states located east of the Mississippi River, except for Hawaii. Besides Hawaii, none of the states in the Midwest or West are represented. Even though the Department plans to provide additional grants ($200 million) to the state finalists from the first two rounds, rural and frontier states are still underrepresented.

Issue 2 – Ensure Support from State Boards of Education
Pursuant to A(3)(c)(i), states are required to demonstrate an understanding and commitment of their plans from various stakeholders, including strong letters of intent or actions of support from Early Learning Intermediary Organizations and, local early learning councils, if applicable. NASBE urges the Department to require states to secure strong letters of intent or actions of support from state boards of education. The first two rounds of RTT required signatures from presidents of state boards of education. The Department should require states to secure such support for the RTT-ELC. State boards of education have broad oversight over public education systems, including standards, licensure, accreditation, accountability, and assessment. They are uniquely positioned to ensure their systems respond to the needs of young children and their families and to address issues of equity to quality education and care.

Issue 3 – Eliminate the requirement for states to repurpose or reallocate existing education funds
Pursuant to (A)(5), states are required to develop a budget to implement and sustain the work of their grant by demonstrating how resources will be repurposed or reallocated from other federal, state, private, and local sources to align resources with, and support and sustain, states’ plans. NASBE urges the Department to eliminate this requirement. States continue to face challenging fiscal environments and need the flexibility to utilize their federal education dollars in the most effective and efficient way according to their needs as allowed under existing federal education law. States should not have their existing flexibility restricted because they apply for one-time, short-term competitive funding.

Citizen boards have been an integral part of American educational governance for over 175 years, and state board of education service is one of the highest forms of public service in the nation. With a diversity of views and a commitment to meeting the needs of all students, state boards of education are the preeminent educational policymaking body for students and citizens, providing citizen engagement and public oversight of education in the states.

Thank you again for allowing NASBE to submit comments concerning this RTT-ELC competition. NASBE looks forward to continuing its work with you to ensure all children have equitable access to a high-quality education. If you have additional questions about our concerns, please contact Tony Shivers, Director of Government Affairs, at (703) 740-4824 or tonys@nasbe.org.

Sincerely,

Brenda Lilienthal Welburn
Executive Director

On behalf of the Chief State School Officers who lead departments of elementary and secondary education in all 50 states and the District of Columbia, we appreciate the opportunity to comment on the Race to the Top - Early Learning Challenge (ELC) draft requirements, priorities, selection criteria and definitions. We commend the Administration and the Congress for providing this important opportunity for states to increase access to high quality early learning programs for low-income and disadvantaged infants, toddlers and preschoolers; and develop more integrated systems of high-quality early learning programs. We believe the ELC also provides an important opportunity to establish early learning as the foundation for a fully aligned continuum of education from birth through post-secondary. We further commend the Departments of HHS and ED for their rapid development of a thorough and thoughtful set of proposed guidelines for this important competition.

Our recommendations are based on the collective experience of chiefs working with governors, legislators, business leaders, state human service agencies and other partners to expand and improve a wide variety of early childhood programs; the deliberations of our recent Early Childhood Task Force; and our experience with the Dept. of Education’s Race to the Top initiative, as similarly- ambitious strategy to promote education reform through offering substantial funding to a limited number of states.
We are providing six general recommendations to improve the overall structure and strategy of the ELC, followed by more specific recommendations to improve and clarify the proposed priorities, selection criteria and definitions. Our six general recommendations are as follows:

I. Support states by providing a two-tiered funding opportunity, including foundational grants to create a nationwide state capacity for standards-based program improvement & allow interested states to develop the capacity to compete in future years for the larger grants described in the current ELC announcement, and competitive grants to develop fully comprehensive early childhood policy systems in 5-9 leading states.

II. Level the playing field for small rural states by allowing them to submit multi-state applications for ELC funding.

III. Encourage ELC-funded states to collaborate and share resources as they address common challenges such as developing and validating improved early learning standards, and tools for assessing young children and program quality.

IV. Elevate the status of Priority 4 – Sustaining Program Effects in the Early Elementary Grades from an Invitational Priority to a Competitive Priority

V. In conjunction with implementing the ELC initiative, lead a more proactive ED/HHS effort to work with states to overcome barriers to program coordination in federal policy.

VI. Use the experience of the Race to the Top competition to design a more consistent, equitable and credible peer review process for the ELC initiative.

We appreciate your consideration. CCSSO's full recommendations can be accessed at: http://www.ccsso.org/Documents/Race%20to%20the%20Top%20-%20Early%20Learn...

The Association of Public Television Stations (APTS) is a nonprofit membership organization established in 1979 to represent the interests of local public television stations across the country.

As providers of high-quality, highly effective educational multiplatform programming for preschool children, the public broadcasting community applauds the U.S. Department of Education for making early learning a priority for this round of Race to the Top funding. We believe that preparing our children for school, particularly children from low-income families, is critical to building a nation of students who grow up ready to learn and succeed in today’s world. Our multiplatform programming and services–available on television, online, through mobile devices and apps, and as classroom resources – work.

The proposed priorities and selection criteria represent a bold investment in early childhood education, but we believe there are further steps that this program should take to make the greatest impact.

Add “Digital Outreach and Engagement” as a Competitive Preference Priority. States should be encouraged to create and implement high-tech digital content and services that engage families, educate children at home, improve early learning in a variety of educational institutions, and can raise awareness of local early learning initiatives throughout the community. This program should include incentives for working with a range of partners who have a proven track record of success and have demonstrated the capacity to help. Public television stations around the country can attest to the fact that it is only with the buy-in and engagement of parents and families that a program can truly succeed in a high-need neighborhood. The first step in that process is ensuring that families are aware of the program’s existence, goals, and opportunities. The Department should encourage applicants to partner with organizations that can distribute information about programs and services throughout the state, and the benefits of high-quality early education. This outreach should be thoughtful, comprehensive, and accessible via multiple delivery methods, including digital mechanisms.

We support adding a Competitive Preference Priority that reads:
To receive competitive preference under this priority, the State’s Plan must include measures to use high-tech digital multiplatform content and services to—

a. Provide services to early learning institutions and families, including at-home learning materials for students;
b. Educate parents and caregivers about the work being done in the community around early learning and how they can engage in it; and
c. Ensure that this content and these services are accessible to disadvantaged and low-income families.

Require States to Include Content Development, Including Digital Content, in their plans as part of effective implementation. While we support efforts to build and improve on high-quality state early education systems, simply planning for improved systems is not enough. Planning for effective implementation on the ground must be contemplated during the systems-building stage and executed in a timely fashion in order to achieve maximum results for children. Many resources and services have been aggressively researched and proven to make a difference for early learners. States should consider how to create and deliver high-quality implementation of core learning elements such as curriculum and related content as they create their plans, including digital delivery methods. In doing so, the Early Learning Challenge should take advantage of the strong content that has already been created by the Department of Education, including the suite of Ready to Learn digital programming and resources. States should be required to identify and use resources that are known to be effective and can be scaled up.

Children learn in a variety of ways, and the strongest resources and services are those that can engage them on multiple platforms. In fact, research shows that when high-quality video, online, and print materials are combined with teacher training, lesson planning, and classroom instruction, children from low-income backgrounds were able to make such rapid growth in reading that they narrowed or closed the achievement gap with middle-class children (Pasnik et. al. 2007). Additionally, content that is available online, on television, and elsewhere provides children with more opportunities to learn anytime, anywhere. Interventions that do not address the multiplatform lifestyle and learning styles of children are missing a critical component. States should be required to help children and families access educational content on a variety of platforms.

We propose adding to the selection criteria, under “Promoting Early Learning and Development Outcomes for Children,” a new (B)(6): Improving Curricula and Content for Early Learners:

The extent to which the State provides, or has a High-Quality Plan to provide, curricula and related curricular content and materials aligned to State standards and professional development, that is proven effective in improving early literacy and other skills among early learners by:

a. Leveraging existing resources to promote early learning in schools and at home;
b. Engaging educators, childcare providers, and parents in identifying materials and resources;
c. Identifying the appropriate outlet for content, including high-tech digital platforms; and
d. Including high-quality professional development with each resource or program.

Require States to Include Media Representatives as Stakeholders. Public television stations are critical community resources that can provide outreach services to hard-to-reach neighborhoods and homes, through both digital broadcasting and on-the-ground interaction. The GAO recently reported that a critical barrier in providing early learning services to students with limited English proficiency was their parents’ lack of awareness of available assistance (GAO 2006). Local media can help raise awareness of issues and solutions, and public broadcasting stations can provide additional resources to the community.

We propose amending Section (A)(3)(c)(ii) to include “representatives of the public broadcasting community.”

Embed Digital Resources in Professional Development Activities. In addition to high-quality digital content for students, teachers should have access to high-quality digital resources for professional development, including distance learning programs and on-the-ground community-based programs.

We propose adding a new Section (D)(2)(d):
Professional development opportunities that use digital means to help teachers improve their practice, and those that help teachers introduce digital learning to young students.

Again, the public broadcasting community is pleased to see this focus being placed on early learning. We support the Race to the Top — Early Learning Challenge initiative in concept, and believe that with the right priorities, this program can help improve states, communities, and children’s lives. We look forward to working further with the Departments of Education and Health and Human Services toward our shared goal of improving educational outcomes for all children.

Questions regarding our comments can be directed to Meegan White, mwhite@apts.org, (202) 654-4214.

Sincerely,
Lonna Thompson
Executive Vice President, Chief Operating Officer and General Counsel
Association of Public Television Stations

The National Board for Professional Teaching Standards (NBPTS) appreciates the opportunity to provide comments on the draft selection criteria for the Race to the Top Early Learning Challenge Program. It is essential that our youngest children, who are at a critical point in their development, have access to highly accomplished educators. Thus, NBPTS would recommend that RTTT-ELC emphasize the importance of professional standards that describe the key aspects of accomplished teaching in improving the knowledge, skills, and abilities of early childhood educators. NBPTS suggests standards in the following areas:
• Early childhood educators build the appropriate foundations with young children to ensure their future success.
o Early childhood educators have the knowledge of child development that enables them to promote student learning in
their classrooms.
o Early childhood educators reach out to parents and the surrounding community in order to create a collaborative
environment that fosters child development.
o Early childhood educators welcome diversity. They interact in ways that show respect for other’s perspectives and
cultures and work to establish this kind of community in their classrooms.
• Early childhood educators incorporate their understanding of young children into their teaching practices.
o Early childhood educators integrate the basic concepts of different subjects into their method of teaching in ways that
allow children to understand and appreciate each subject.
o Early childhood educators employ a variety of assessment tools to support and build upon children’s abilities and needs.
o Early childhood educators establish a learning environment that promotes young children’s development and learning.
o Early childhood educators plan for children’s development and learning by setting developmentally appropriate goals
and designing learning activities to achieve those goals.
o Early childhood educators promote learning and development by utilizing a variety of strategies and resources.
• Early childhood educators demonstrate professionalism.
o Early childhood educators engage in systematic reflection as a means to becoming a more effective teacher.
o Early childhood educators contribute to the profession by engaging in partnerships with other educators, attending
educational events, and taking on leadership roles to inform early childhood programs, practices, and policies.

Through the use of professional teaching standards, early childhood educators are able to identify areas in which they excel as well as areas for growth. When early childhood educators can assess their own teaching through the use of professional teaching standards, they can learn and grow in their teaching practices and advance their knowledge, skills, and abilities.

NBPTS also recognizes the value of strong professional development for all educators and would suggest the following in regard to partnerships between states, postsecondary institutions, and professional development providers:
• Create partnerships that utilize professional teaching standards in their approach to preparing early childhood educators.
• Create partnerships that use standard-based, job-embedded professional development to develop more effective early
childhood educators.
• Create partnerships that produce professional learning communities so that early childhood educators can collaborate to
improve their practice.

For example, NBPTS has a number of programs that would facilitate partnerships such as those listed above. The NBPTS Early Childhood Generalist Standards (revised in 2010) can be implemented into the curriculum postsecondary institutions use to develop early childhood educators. In conjunction with these standards, the Take One! program can be used by postsecondary institutions. Take One! is built upon the foundation of National Board Certification, and can be incorporated as a professional development tool for soon-to-be educators at post-secondary institutions. Participants prepare and submit one pre-selected video portfolio entry, making it possible for teacher candidates, for example, to video themselves teaching a lesson during a clinical experience such as student teaching. Participation in Take One! affords teacher preparation programs an opportunity to emphasize the critical role of professional development to the newest early childhood educators and help them reflect on their practice before entering the classroom full-time.

Partnerships between postsecondary institutions and early childhood programs with educators who have already been in the classroom for three years or more could utilize full National Board Certification to further examine and improve their teaching practices. Some master programs already include the National Board Certification process as part of the degree. In either case, teacher candidates have the opportunity to use National Board programs as a basis to inform their developing teaching practices. Many teachers who pursue National Board Certification regard it as the most significant professional development experience in their career. Furthermore, both National Board Certification and Take One! contribute to professional learning communities in which educators collaborate to improve their teaching. Partnerships that create a coherent system of professional development that encourages growth from even the earliest point in an educator’s training are an integral component of developing effective early childhood educators.

Thank you again for the opportunity to comment.

Sincerely,

Seth Gerson
Director of Government Relations
National Board for Professional Teaching Standards

To be successful at improving child and youth outcomes, states and localities need to have strong and effective interagency governance bodies, strategic plans, goals, performance measures, data, evaluation and accountability systems, and technical assistance capacity. Unfortunately, most states and localities suffer from having numerous parallel, duplicate efforts for narrowly defined aspects of children’s lives, each of which lack the capacity necessary to succeed. Ready by 21 helps states and localities align fragmented, under-funded efforts into a comprehensive child and youth infrastructure with the combined resources necessary to succeed.

One of the ways the Forum for Youth Investment helps states and localities implement comprehensive solutions is by advocating for federal policies to allow the flexibility necessary for states and localities to leverage them as part of larger efforts already underway.

States understandably tend to interpret federal policies, rules, and regulations conservatively for fear of losing funding if they run afoul of a federal agency. So it comes as no surprise that if a policy does not explicitly state that it may be aligned with other policies and other agencies, states and localities generally assume that they are not allowed to connect it to parallel efforts. Therefore we recommend that policies allow interagency alignment explicitly, not just implicitly. Ideally, policies will go one step further by directly incentivizing interagency alignment and collaboration.

ELIGIBILITY REQUIREMENTS
Setting up interagency governance structures is one of the most common duplicative tasks that States and communities take on for different funding streams. This results in multiple interagency governance structures, which then must be aligned with each other.

  • At the end of eligibility requirement (b) “The State must have an operational State Advisory Council on Early Childhood…” add “which may be a component of, and/or aligned with, an existing interagency governance structure such as a State children’s cabinet, council or commission.”

 
PRIORITIES
Priority 1

  • Add “These standards, assessment systems, professional development activities may be aligned with those of other existing State child and youth services.”

 
Priority 2

  • Add “This Rating and Improvement System may be aligned with other existing State rating and improvement systems for child and youth services.”

Priority 3

  • Add “The State’s Plan may be aligned with other existing State plans for child and youth services.”

Priority 4
The priority is currently written to solicit information about a few narrowly crafted potential areas of alignment. We recommend broadening it to solicit information about alignment with all relevant child and youth services. In particular, it should also allow alignment with non-academic services, and organizations other than schools – such as afterschool programs and health care providers.

  • Add “(d) Ensuring interagency alignment of early childhood governance bodies, strategic plans, goals, performance measures, data, evaluation and accountability systems, and technical assistance capacity with those of existing State child and youth services.”

This could also be an opportunity to solicit information from States on what administrative barriers they are facing, which could help inform the U.S. Department of Education's response to the President’s Memorandum on Administrative Flexibility.

  • Add “(e) Identifying any Federal and State barriers to aligning this funding stream with other existing Federal and State child and youth funding streams, specifying what steps will be taken to mitigate State barriers, and providing information on what steps the Federal government could take to remove Federal barriers.”

 
SELECTION CRITERIA
(A)(1)

  • Replace “child outcomes statewide” with “a comprehensive set of child outcomes covering the Essential Domains of School Readiness”
  • After “are consistent with the State Plan,” add “and are aligned with other established State goals related to children”
  • Under Performance Measures, add “These baseline numbers, annual targets, and final goals may be aligned with those of other existing State child and youth services.”

(A)(3)
Setting up interagency governance structures is one of the most common duplicative tasks that States and communities take on for different funding streams, resulting in multiple interagency governance structures which then must be aligned with each other. Recommendations:

  • (A)(3)(a)(i) after: “The organizational structure for managing the grant,” add: “and how this structure builds upon existing interagency governance structures such as children’s cabinets, councils and commissions, if any already exist and are effective.”
  • (A)(3)(a)(iv) after: “The plan for when and how to involve… key stakeholders,” add: “and how this plan builds upon existing efforts to engage key stakeholders, if any already exist and are effective.”
  • (A)(3)(c)(i) after: “Strong letters of intent or actions of support from… early learning councils,” add “children’s cabinets, councils, commissions and other interagency child and youth coordinating bodies.”

(A)(4)
Currently, many states are creating duplicative data systems in various departments, for example creating an education data system and a separate health and human services child and youth data system which are not interoperable. Therefore we recommend:

  • (A)(4) after: “…and is interoperable with the Statewide Longitudinal Data System,” add “and with other statewide data systems that collect information about children”
  • (A)(4)(b) after: “…data definitions such as Common Education Data Standards,” add “and other statewide data standards regarding children”

(B)(1)

  • (B)(1)(b) After: “…aligned with the State’s K-3 academic standards in, at a minimum, early literacy and mathematics,” add “as well as other existing State standards for children’s outcomes, including non-academic outcomes”
  • (B)(1)(c) Add to the end of the sentence “which may be aligned with existing State standards, curricula, assessment systems, workforce knowledge and competencies and professional development activities related to children.”

(B)(3)

  • After: “aligned with the State’s Early Learning and Development Standards,” add: “and that may be aligned with other existing State standards relating to child outcomes.”
  • (B)(3)(e) After “Statewide Longitudinal Data System,” add “and may also be reported to other existing State data systems that include data related to children.”

(B)(4)

  • (B)(4)(a) After “… a progression of standards,” add “, which may be aligned with existing State standards related to children.”
  • (B)(4)(b) After: “… annual targets,” add: “, which may be aligned with existing State targets related to children.”
  • Add: (B)(4)(c)(v) “other health, behavioral and developmental targets established by the State.”

(C)(1)

  • Add: (C)(1)(c) “are aligned with existing state program standards for children’s programs”

(C)(3)

  • After: “a system for rating, monitoring, and improving the Quality of Early Learning and Development Programs,” add “, which may be aligned with existing State rating, monitoring and improvement efforts”
  • (C)(3)(b) After “in ways that” add “align with existing efforts to provide information to families, and that”
  • (C)(3)(c) After “compensation” add “all of which may be aligned with existing State efforts to advance continuous improvement”

(D)
There is a wonderful opportunity to connect the administration’s early childhood agenda with the administration’s youth employment agenda by training disadvantaged youth to become early childhood educators.

  • (D)(1)(b) Add to end of sentence “and which are designed to be accessible to disadvantaged older youth who are out of school and unemployed.”
  •  (D)(2)(a) Add to end of sentence “and which are designed to be accessible to disadvantaged older youth who are out of school and unemployed.”
  • (D)(2)(b) After “career pathway” add “which is designed to be accessible to disadvantaged older youth.”
  • Add (D)(2)(c)(iii) Increasing the number of older disadvantaged youth who are gainfully employed as Early Childhood Educators.”

 
DEFINITIONS
High-Quality Plan
Add (i) “An explanation on how this plan aligns with and builds upon existing State plans related to children.”

Lead Agency
In many if not most states, the best entity to serve as a lead for an interagency efforts is one that is neutral from any particular agency, such as the Governor’s Office, Lieutenant Governor’s Office, the First Spouse’s Office. However the current definition of Lead Agency states that it must be one of the Participating State Agencies, which in turn is defined as “a State agency that administers public funds related to early learning and development.” It is not clear that the Governor’s Office, Lieutenant Governor’s Office, or the First Spouse’s Office would qualify under that definition. Likewise it is not clear that existing interagency efforts (which may be housed in the Governor’s office or similar non-agency entity) would be eligible under that definition.  Recommendation:

  • In the definition of Lead Agency, after “…must be one of the Participating State Agencies” add “or the Governor’s Office, Lieutenant Governor’s Office, or an existing interagency governance structure such as a children’s cabinet, council or commission.”

We commend the administration for its commitment to assuring the school and life success of the Nation’s youngest citizens and wholly support the Race to the Top – Early Learning Challenge (RTT-ELC). We are particularly pleased and concur with the comprehensive emphasis you have placed on strong licensing as the foundation of quality.

Reflected in the systems approach taken here in the Early Learning Challenge, the administration has incorporated strengthening regulations, monitoring and inspection capacity as essential parts of all its major initiatives for child care. This intentional and comprehensive approach that starts with strong licensing is reflected throughout the efforts of the ACF, including in the visionary Pathways to Excellence, the new state biennial planning requirements and tools, the Office of Child Care plans for FY 2012 technical assistance, and now strengthened licensing systems is an explicit goal within this worthy and ambitious plan for state early childhood systems initiatives in the RTT-ELC.

We are eager to partner with you and with states to realize this vision, and provide our comments to support the effort within these online provisions:

The National Association of State Early Childhood Specialists in State Departments of Education (NAECS-SDE) commends the Administration for tackling the hard task of taking a systemic approach to assuring the successful development and early learning of the Nation's most precious resource, its children. Thank you, too, and for modeling what the RTT-ELC asks states to do -- step up to the very complex and challenging systems work needed to assure that success, and transcending the divides that can erupt in cross-agency efforts. We think the draft proposal goes a long way toward realizing success. We are pleased to submit specific recommendations within the online provisions.

The Tribal Child Care Association of California is pleased with many components of the RTT-ELC and would like to ensure its success within our communities.

Selection Criteria (B)(1) and throughout the program: The development of a statewide, high quality early learning and development system must include language that allows Tribes the opportunity to participate and contribute to the overall success of the project while increasing the academic success of Indian kids. Without language that specifically includes the participation of tribal governments, tribal communities will be inadvertently left behind again. In California, Senate Bill 1629 provides legislation for the establishment of an Early Learning Quality Improvement System comprising of an appointed Advisory Committee. The group developed an exceptional report on quality improvement. However, the legislation neglected to include language related to how Tribes would/could participate, thereby discounting all tribal communities in the state. On the group’s behalf, they did indeed allow one representative from the state’s tribal community to participate further along in the process. Although other tribal people were “allowed” to attend, they were not allowed to speak. Thus, without the inclusion of tribal language in this proposal, Indian communities can count on being an afterthought in a process that affects ALL of our children. Lack of tribal inclusion is detrimental in an area of the state’s highest needs population, with the highest levels of poverty and people who reside in desolate, hard to reach rural communities.

Eligibility Requirements (b): Legislation should be in place requiring the State Advisory Councils on Early Childhood Education and Care (being established by RTT-ELC) to include tribal governments.

Priorities, Priority 3: The RTT-ELC should address the mechanism by which early learning programs, legally operating without state licenses, will be permitted to participate. Funding streams are often tied to the obtainment of a state license thereby excluding many programs from funding opportunities. This proposal should allow such centers to be supported as they are (legally operating without a license), rather than punished by not being able to receive priority status. If we are to adopt a common, statewide set of tiered program standards, these legally operating programs must be entitled to exercise their right not to obtain a license but should be able to prove the quality of their program based on other measures. Furthermore, state licensing does not equal quality. State licensing meets basic health and safety requirements and does not determine program quality. In California, monitoring visiting occurs once every five to seven years when no complaint has been filed against a provider. This proposal should give priority to programs that have quality standards in place rather than programs with licenses. Further, states should focus on strengthening licensing structures, increasing monitoring visits, and overseeing provider qualifications.

Priorities, Priority 5: The “encouraging private sector support” piece of the RTT-ELC provides a foundation for Tribes and states to work together for the betterment of all children. Tribes are able and willing to contribute to the composition and overall success of this project. This could be in the form of financial contributions, meeting space for training, or drawing from the expertise of parents and community members who understand the educational needs of this specific high need group. However, in doing so, Tribes would like to be included in other areas of this plan such as data, advisory boards, and workforce development.

Performance Measures: Assessments should be culturally appropriate for the many children that will be measured. The RTT-ELC might consider holding focus groups in different ethnic communities to determine which of the many assessments available would be most appropriate for their children. Further, evaluators should receive training in cultural competency.

Performance Measures (A)(4): The RTT-ELC should mention whether or not tribal data is important to this project and, if so, how states will record and track those data sets and what kind of data will be gathered. Traditionally, Tribes have not always been included in data collection by California. For example, when the state collects data from licensed child care providers for the purposes of determining maximum reimbursement rates for subsidized child care in California, Tribes were not consulted. Although Tribes were eager to oblige for purposes of inclusion in the survey, they were not afforded the chance. Above all, the RTT-ELC should specifically state how any data gathered will be made available to the public.

Barriers in current federal funding- Access to the Child and Adult Food Program by Tribes has been discouraging. The high level of documentation required in order to be eligible for meal reimbursements and the licensing requirement of program defer Indian early learning programs/providers from even considering the program as a resource. Another problem occurs when tribal early learning programs are housed with elementary schools. The school has a priority in getting reimbursed for meals and early learning programs are able to use any leftover dollars which leads to early learning programs getting under-reimbursed. Per the National Indian Child Care Association, Tribes recommend a Tribal Advisory Board be created by the program to investigate all the barriers that inhibit Tribes from accessing this program. The Board could then recommend strategies for easier access by Tribes.

Recommendations
1.) Language should be added to the proposal to describe how Tribes can/will participate.
2.) Legislation should be in place requiring the State Advisory Councils on Early Childhood Education and Care (being established by RTT-ELC) to include tribal governments.
3.) This proposal should give priority to programs that have quality standards in place rather than programs with licenses.
4.) States should focus on strengthening licensing structures, increasing monitoring visits, and overseeing provider qualifications.
5.) The proposal should recommend that states partner with Tribes so that resources can be combined for the benefit of all children.
6.) Assessments should be culturally appropriate and require evaluators to receive training in cultural competency.
7.) The RTT-ELC should include a description of how Tribes can be included in data collection.
8.) The proposal should state how and when data will be available for review by the public.

The Center for the Study of Social Policy and the National Alliance of Children’s Trust and Prevention Funds thanks the Obama Administration for the opportunity to offer feedback on the proposed Executive Summary of the Race to the Top – Early Learning Challenge. This grant represents an unprecedented opportunity to support state efforts to close the achievement gap and promote positive outcomes for young children.

We offer comments throughout this draft document in support of the following recommendations:

* Include as an Absolute Priority that States include as a primary goal: “Supporting parents in their primary role as their children’s first teachers and engaging them as decision-makers and leaders.”

* Require State Plans to include development and implementation of Family Leadership and Support Standards that clearly identify what professionals should know and be able to do, what programs should do, and what policies and systemic functions are necessary to ensure that the entire early care and education system supports parents in their role as their children’s first teachers.

* Expand the Definition of High-Need Children, and require States to develop a specific plan for ensuring access to and continuity of high quality Early Learning and Development Programs for all children within the following categories: children of teen parents; children who have been exposed to domestic violence in the home; children who are or have ever been connected to the child welfare system and differential response system; children who are at risk of developmental delays or disabilities; and children whose parents suffer from depression, other mental health problems, or substance abuse

We applaud the secretaries for their thoughtful and ambitious efforts to raise the bar on early learning and development opportunities for High-Need Children. Thank you again for the opportunity to offer our suggestions for strengthening the grant’s design to optimize its positive impact on young children and their families.

Signed,
Frank Farrow, Director, Center for the Study of Social Policy
Judy Langford, Senior Fellow and Director, Strengthening Families Initiative, Center for the Study of Social Policy
Teresa Rafael, Executive Director
National Alliance of Children's Trust and Prevention Funds

As the pastor of Sweethaven Baptist Church and Sweethaven Christian Academy, I wish to express serious concern regarding the Race to the Top - Early Learning Challenge. Private Christian preschools are part of the solution to providing quality, affordable preschool to low-income families. As such, their autonomy should in no way be affected by RTT-ELC.

As a private school we bring no burden to the cost of education yet give a great deal to the education of our children. Our preschool children leave the K-4 program; with a strong grasp of both numbers as well as phonics. They move to the K-5 actually reading on their level.

The proposed requirements for the RTT-ELC will inevitably bring the private and faith-based early learning centers and preschools under state and federal government control, even though they do not operate with public funds and already have a strong accountability system in place to ensure the quality of their programs.

The following quote from Dan Zacharias the Executive Director of Old Dominion Association of Church Schools is both accurate and appropriate.

“In order to ensure that the existing privately-run and faith-based programs remain successful and able to operate, we strongly recommend that these proposed requirements undergo revision to ensure that they do not require states to infringe on the freedoms that are allowing excellent education to take place across the country in the privately-run and faith-based centers. A program designed to improve American education should not do so at the sacrifice of the existing, successful educational programs in our nation.”

Cary R. Borkert

These comments developed by members of the Broader Bolder Approach Early Childhood Education working group reflect the input of a group of early childhood experts with diverse backgrounds and expertise.

Children’s earliest years are unique, and they are different from those of later periods in their education. Young children learn experientially, and their cognitive, behavioral, and social skills are intertwined to a particularly strong degree. Because early foundations form the basis for subsequent learning, a focus on the zero-to-three period, as well as the three-four pre-k years, is critical.

These comments primarily applaud the Department for a comprehensive, thoughtful set of criteria. We are delighted at the overall focus on: program quality; increased access to quality for the highest-need young children; acknowledgment of the need to bring more providers into licensing and regulation; built-in supports and incentives to help service providers and teachers increase their quality and skill/education levels; attention to systemic and governance factors to improve collaboration across agencies, which is key to sustaining quality longer-term; and the focus on the whole child, with health and the wide range of development critical to early education.

Our suggestions for particular attention to detail in grant allocation and monitoring include:
Early Learning Standards: The earliest years of life provide unique opportunities to lay the foundation for a lifetime of love of learning, creativity, and broadening of children’s horizons. Low-income and at-risk children disproportionately live in constricted worlds that limit those opportunities. While we agree wholeheartedly with the need to ensure all children’s school readiness, we urge the Department to focus on early standards that are context-relevant, content-rich, and sufficiently flexible to be tailored to individual needs.

  • Children benefit from a curriculum in which language and literacy occur through their engagement with meaningful content, not a fragmented set of skills. When we set literacy and math skills apart from other important areas of content-rich instruction, we make learning harder rather than easier for those who have had limited background knowledge and experience. These skills, especially in the early years, should never be taught through isolated skill instruction, but integrated in rich content that engages children’s minds.
  • No Child Left Behind’s focus on reading and mathematics has been driven by a misapplication of research findings and has resulted in a substantial narrowing of curricula, with other subjects limited or eliminated. We would not want to see similar consequences for early learning programs from a disproportionate focus on rote learning of early literacy and mathematics.

Assessments: We applaud the use of a comprehensive assessment system that requires screenings, formative assessments that include physical well-being and social and emotional development, and measures of both environmental quality and the quality of adult-child interactions. This holistic approach is particularly appropriate for evaluating the status of young children’s developmental progress and needs, and for providing appropriate professional development for teachers, providers, and other staff. However, given the requirement that RTTT grantees hold Early Learning programs accountable and track school readiness, we strongly urge the Department to forbid the use of any assessments to evaluate teacher and/or provider “quality” or to deny children access to kindergarten.

  • Too often, high-stakes tests have resulted in widespread gaming of test systems, narrowing of curricula, and difficulty in understanding real learning gains in the K-12 system and would have even more pernicious impacts if employed at the early childhood level.
  • We understand the draft criteria to forbid the use of kindergarten readiness assessments to delay or deny kindergarten entry and emphatically urge the Department to ensure that this remains so.
  • Putting pressure on such young children would be detrimental to their physical and mental health and would embed perverse disincentives for early childhood care and education providers to work with those who are most in need.
  • While screenings are critically important, the funds expended to conduct them may be wasted unless needs that they identify result in access to appropriate services. Ensuring this follow-up requires putting in place both a system of collaboration with relevant providers and insurance or other funding to make them attainable.

    Professional Development: We are delighted to see professional development incorporated as part of enhancing teacher and provider quality. To be effective, state plans must make it available, accessible, and attractive to people at all levels of the system and must help establish career ladders to keep more skilled workers working with young children. Specifically, it must be targeted to those serving infants and toddlers zero-to-three and to providers of child care, and not just public pre-k programs, as that is where it is most lacking and most needed. One recent meta-analysis on vocabulary for example, found that many early childhood providers were ill-prepared to help children develop language and vocabulary, especially among those at risk. Professional development is key to developing and sustaining quality programs by ensuring that our teachers and all providers are well prepared to engage in these rich learning experiences.

    Budget: It is important to ensure that receipt or acceptance of Race to the Top Early Learning Challenge grant support does not result in a loss of funds for programs that provide important services to young children and are already seriously underfunded.

    In closing, we wish to note that all children need and deserve the quality early education systems this grant is intended to develop. We hope that this challenge grant program serves as a blueprint for such expansion as NCLB is reauthorized.

The Council for American Private Education (CAPE) is a coalition of 18 national organizations and 33 state affiliates serving private elementary and secondary schools. There are 33,366 private schools in the United States; one in four of the nation’s schools is a private school. About 5.5 million students (10 percent of all students) attend them. CAPE member organizations represent about 80 percent of private school enrollment nationwide.

CAPE's issue paper on early learning embodies the following four key principles:

- Formal early childhood education should be voluntary.
- Legislation promoting early childhood education should support the right of parents to choose from a range of programs and providers without financial penalty.
- Programs designed to assist children and teachers should provide benefits to comparably situated children and teachers, whether in independent or government-run settings.
- Early childhood education regulations should not seek program uniformity; they should promote pluralism that allows institutions to fulfill their unique missions and parents to choose from a variety of truly distinctive options.

The full issue paper is available at:
http://www.capenet.org/pdf/IP-EC2008.pdf

We believe that the draft requirements, priorities, selection criteria, and definitions for the RTT-ELC competition should reflect all of the above principles and that state applicants should adhere to them when developing state plans.

In addition, we propose that the draft document be revised to make clear that the delivery of early learning programs should include all providers in order to ensure that parents have the freedom to choose from an array of options the programs that best meet the needs of their children. Moreover, states should be required to consult with and involve key representatives from a variety of major providers of early learning programs in the development and implementation of state plans. Such involvement would help ensure pluralism in early learning opportunities and help protect the unique missions and philosophies of diverse programs.

Nemours Health & Prevention Services (NHPS) thanks you for the opportunity to comment on the Race to the Top – Early Learning Challenge Program. NHPS is a nonprofit organization based in Newark, Delaware, and we work with families and community partners to help children grow up healthy. Our goal is to effect long-term changes in the policies and practices that promote child health and to leverage community strengths and resources to have the greatest impact on the most children. NHPS is a division of Nemours, one of the nation's largest pediatric health systems, which operates the Alfred I. duPont Hospital for Children in Wilmington, Delaware, as well as outpatient facilities throughout Delaware, Pennsylvania, New Jersey, and Florida. NHPS expands Nemours’ reach beyond clinical care to consider the health of the whole child within his or her family and community.

Absolute Priority 2: Using Tiered Quality Rating and Improvement Systems to Promote School Readiness

NHPS commends the inclusion of QRIS as an absolute priority. The early care and education setting is recognized as an ideal environment to support all aspects of healthy child development, both physical and early mental health. There are currently a number of existing agencies within the federal government that support healthy child development as a key component of early care and education, including the Department of Health and Human Services’ Centers for Disease Control and Prevention (CDC), Administration on Children and Families (ACF), Health Resources and Services Administration (HRSA), and Substance Abuse and Mental Health Services Administration (SAMHSA), and the U.S. Department of Agriculture’s Food and Nutrition Service (FNS) and National Institute of Food and Agriculture (NIFA).

To prevent duplication of efforts, we recommend encouraging states to utilize existing guidance and resources from these agencies to establish health, nutrition, and social-emotional development curriculum standards within the early learning framework. For example, Let’s Move! Child Care (LMCC) includes a set of nutrition, physical activity and screen time standards that may be helpful to states as they develop QRIS standards. Additionally, LMCC includes an array of tools and resources to support early care and education providers in implementing best practices in healthy eating, physical activity and screen time. CDC is also developing a guide for states relating to wellness best practices in the early care and education environment, and QRIS is among the topics covered that could be a useful resource to states. HRSA’s Child Care America Program and USDA’s Child and Adult Care Food and Team Nutrition Programs also provide standards and resources related to healthy eating and physical activity.

In order to support overall healthy child development, we suggest the following options relating to healthy eating and physical for QRIS:

* Tying nutrition and physical activity requirements, screen time limits, and breastfeeding support to quality rating tiers.
* Recommending that all eligible, licensed early childhood programs are required to participate in the Child and Adult Care Food Program as a standard of achieving a Level II status in any QRIS system to ensure compliance with national and state nutrition best practices.
* Including a systematic assessment of policies and practices related to healthy eating, physical activity, screen time, and breastfeeding as part of the ratings process.
* Incorporating nutrition, physical activity, screen time, and breastfeeding support into coursework training and continuing education requirements for early care and education providers.

In addition to promotion of healthy eating and physical activity, early childhood programs should seek to develop a comprehensive child health approach which could include activities to support emotional and physical wellness, developmental milestone tracking, personal hygiene (e.g.; hand washing), oral health, behavioral health and well-being, accident prevention, and access to resources (e.g.; health consultants for staff and family education, policy development, and action planning; early childhood mental health consultants; etc.) that can be linked to professional development.

We recognize that physical and social-emotional wellness is the foundation for health, well-being, readiness to learn and explore, and life-long success for all children. In order to support overall healthy child development, we recommend inclusion of quality assessments pertaining to social-emotional development standards into components of QRIS. We suggest the following options:

* Tying social-emotional development support to quality rating tiers.
* Including a systematic assessment of policies and practices related to social-emotional development as part of the ratings process.
* Incorporating social-emotional development education into coursework training and continuing education requirements for early care and education providers.
* Requiring all participating programs to have an evidence-based social-emotional development curriculum that is implemented within all classrooms. (e.g., Center on the Social and Emotional Foundations for Early Learning (CSEFEL) is a national resource center for disseminating research and evidence-based practices to early childhood programs across the country. CSEFEL is focused on promoting the social emotional development and school readiness of young children birth to age 5. The early childhood program content for infants, toddlers, preschoolers and parents is available in the public domain).
* Requiring all participating programs to have access to early mental health consultants on-site to assist caregivers and teachers with action plans to address challenging behaviors with positive reinforcement and create environments in which children’s social-emotional development is supported.
* Providing incentives at the state level to encourage classroom ratios that support healthy attachment and interaction between staff and children.

By integrating nutrition, physical activity and social-emotional development assessment, standards, and education into QRIS, states can support healthy early care and education environments for children to learn, grow and thrive.

Thank you again for the opportunity to provide comments. Please feel free to contact me directly with any questions.

Sincerely,

Mary Kate Mouser
Executive Director
Nemours Health and Prevention Services

The National Council of La Raza (NCLR)—the largest national Hispanic civil rights and advocacy organization in the United States—is pleased to submit comments on the Race to the Top–Early Learning Challenge (RTT-ELC) grant competition. NCLR applauds this new investment and views it as critical to achieving better educational opportunities for Latino and English language learner (ELL) students and closing the academic achievement gap. This new initiative presents a prime opportunity to incentivize states to expand services and design early learning systems that meet the needs of all children.

In order for states to make the most progress in ensuring that Hispanic and ELL children and families have access to high-quality programs, NCLR recommends that the Department of Education and the Department of Health and Human Services provide further assurances that states develop proposals that are truly inclusive and comprehensive in nature. Specifically, NCLR recommends that the RTT-ELC application make more explicit the importance of building systems that meet the needs of diverse children and families by requiring that states:

• Implement Truly Comprehensive Early Learning Standards—According to the National Institute for Early Education Research (NIEER), of 49 state preschool programs, 41 have comprehensive early learning standards that include children’s physical well-being and motor development, social/emotional development, approaches to learning, language development, cognition, and general knowledge. However, a recent NCLR report shows that less than a handful of states make any reference to the needs of ELL students, leaving the vast majority of states with no articulated program strategies or policy recommendations to address the needs of ELLs in their state early learning guidelines.

The lack of comprehensive early learning standards that address the diverse language and ethnic child populations is alarming, given the growing rate of ELLs in preschool classrooms across the country. Without clear early learning guidelines to outline how ELL students should be progressing in a variety of content areas, the quality of services will continue to suffer for this vulnerable subgroup of students. The RTT-ELC grant should require that states examine their early learning standards and to integrate what research has found to be essential for the healthy language literacy and social-emotional and cultural development of young ELLs.

• Revise Quality Rating and Improvement Systems (QRIS)—Current QRIS systems have been developed with little attention paid to how programs address the needs of culturally and linguistically diverse children and families. Researchers have documented that culturally competent early childhood programs are those that have skilled and effective teachers, low teacher-child ratios and appropriate group sizes, age-appropriate curriculum, engaged families, well-designed facilities, linkages to comprehensive services, culturally and linguistically appropriate assessment, and available and accessible bilingual education and services. To date, few QRIS systems have considered these components in developing tiers and overall rating options. NCLR strongly recommends that states be required to improve their QRIS systems as part of a broader statewide adoption process.

• Devise Professional Development Systems that Help Providers Work with Culturally and Linguistically Diverse Children and Families—Despite the growing diversity among American children, few state-funded preschool programs have considered the qualifications, skills, and competencies early childhood education (ECE) teachers must have in order to work effectively with a diverse group of students, including ELLs. In fact, new research from the Erikson Institute shows that most colleges and universities that prepare early childhood educators have few requirements related to understanding the needs of children from diverse communities, English language learners, children of immigrants and children with special needs. States should work with Institutions of Higher Education (IHEs) to 1) develop coursework to help ECE educators better understand how children acquire a second language and how to work with diverse populations of children and 2) offer credit-bearing coursework and training in languages other than English.

• Promote Technical Assistance for Data Collection—NCLR strongly supports the language included in the RTT-ELC proposal regarding the collection and disaggregation of data. This data will certainly allow states to have a better picture of the needs of the children and families served by the programs. However, we are concerned that states currently do not have the capacity to collect such comprehensive information and recommend that more supports be given to states to assist them in developing improved data collection systems and strategies.

In a challenging fiscal environment, it is all the more important to identify areas of investment that would have the most impact on student learning. For Latino and ELL children and families, this means investments in efforts that improve the quality of ECE programs. In order for states to start making these improvements, they must be given clear guidance from each agency to develop inclusive and comprehensive systems. We look forward to working with you in helping to improve early learning opportunities for young children. If you have questions or concerns, please contact Erika Beltran, Senior Policy Analyst at ebeltran@nclr.org or by phone at (202) 776-1815.

Janet Murguía
President and CEO
National Council of La Raza

On behalf of the 40,000 members of the Council for Exceptional Children who are special education teachers, early interventionists, special education administrators, high education faculty, researchers and others concerned with the development and education of children and youth with disabilities and/or gifts and talents, we welcome the opportunity to provide feedback on the Race to the Top-Early Learning Challenge program (RTTT-ELC). CEC’s comments echo those made by its Division for Early Childhood, whose members work with or on behalf of children and youth with disabilities and other special needs.

CEC has long recognized the critical importance of investing in high quality early intervention and preschool programs for young children with disabilities and supports a cohesive system that meets the needs of all children. CEC requests consideration of the following comments and recommendations as the application package is finalized:

Inclusion of Children with Disabilities and the Professionals, Systems that Serve Them:
CEC strongly supports the clear and comprehensive inclusion of children with disabilities and the services, providers and programs that support their success in quality early learning settings within the community. CEC was pleased that many of these references were included in RTTT-ELC, such as in the definition of “high need children” which includes children who have disabilities and developmental delays; inclusion of Part C and Section 619 Preschool under Part B are recognized programs under this plan; Part C lead agencies and the state agencies administering the Section 619 program under IDEA are required partners; the Part C of IDEA Interagency Coordinating Council is included in the governance structure; child find activities under IDEA are covered; organizations such as CEC state affiliates are mentioned; and finally it is clear that the requirements of IDEA must be met as a condition of a state’s participation under this program.

Funding Considerations:
While CEC is appreciative of the $500 million funding commitment it must be noted that existing federal, state and local resources are not adequate to ensure the needs of all children are met. The package requires states to “reallocate or repurpose” existing funds. The obvious implication is that adequate funds are available but not being spent wisely. These funds, particularly IDEA funds, have statutory requirements about their use. All funding sources mentioned are in fact underfunded and stretched beyond their limit. Therefore, CEC recommends that states not be required to report how the state will “reallocate or repurpose” existing funds. Instead states should be asked to address how all funds will be used to support the overall goal of the effort.

Data-Based Performance Measures:
CEC supports the inclusion of data-based performance measures particularly related to tracking and reporting increases in the numbers of children participating in high-quality early learning and development programs. We strongly support subgroup reporting including by age group and disability status.

Collaboration with Families:
While CEC strongly supports the emphasis on engaging and supporting families as a selection criterion we recommend that the final package emphasize not only what early learning systems provide “to” families but how systems partner “with” families. Family engagement is a core element to the success of this initiative and states should be directed emphasize the role of parents and family members.

Addressing the Home Environment:
CEC notes that many infants and toddlers do not participate in group or program settings in their community. Infants and toddlers receiving early intervention services may receive those services in their home, a family member’s home or in a family child care setting. The application package should be reviewed and revised consistent with this reality to be sure that the home environment is appropriately addressed in this investment. This is particularly true for the existing component of a “State’s Tiered Quality Rating and Improvement System” that seems to more closely align to group or program settings.

Emphasizing Evidence-Based Practices:
While supporting this federal initiative to improve early learning and development programs for young children, CEC asks that states be encouraged to utilize evidence-based practices that are associated with positive child and family outcomes. These practices should be at the core of services provided to children and families and should also serve as the centerpiece of professional development. In the application criteria, this would require a definition of evidence-based practices and ask states to place greater emphasis on early care and education practices throughout the criteria. CEC’s Division on Early Childhood’s Recommended Practices initiative underscores the need for a focus on specific, evidence-based practices in order to build a strong early childhood system.

Assessments:
CEC is concerned about the required plan to have a kindergarten entry assessment for all children entering kindergarten by 2014-15 school year. We agree with many of our colleagues that a onetime snap-shot of a child is not an adequate way to measure a child’s knowledge and functional capabilities. It is important that teams conduct comprehensive, universally designed, and authentic assessment and ongoing monitoring of all children’s development and learning. Team members need a clear understanding of all children’s current skills and abilities to ensure access and participation, and to develop appropriate learning opportunities. The comprehensive assessment system should differentiate between child performance measures and indicators of program quality. The assessment should have established technical adequacy including evidence of validity and reliability for both the population it is used on and the purpose it is being used for.

Supporting the Early Childhood Education Workforce:
CEC fully supports the emphasis on professional development and training for early childhood professionals. Professional development and training is particularly critical for early childhood educators to appropriately administer assessments and interpret and use assessment data in order to guide and improve instruction, programs and services. This training is particularly important as it applies to children with disabilities and other special needs.

Thank you for the opportunity to comment.

Deborah A. Ziegler, Associate Executive Director , Policy & Advocacy
Council for Exceptional Children

Selection Criteria (B)(1) and throughout the program: The development of a statewide, high quality early learning and development system must include language that allows Tribes the opportunity to participate and contribute to the overall success of the project while increasing the school readiness and academic potential of Indian kids. Without language in this grant proposal that specifically includes the participation of tribal governments, tribal communities will be inadvertently left behind again. In California, Senate Bill 1629 provides legislation for the establishment of an Early Learning Quality Improvement System comprising of an appointed Advisory Committee. The group developed an exceptional report on quality improvement. However, the legislation neglected to include language related to how Tribes would/could participate, thereby discounting all tribal communities in the state. On the group’s behalf, they did indeed allow one representative from the state’s tribal community to participate further along in the process. Although other tribal people were “allowed” to attend, they were not allowed to speak. Thus, without the inclusion of tribal language in this proposal, Indian communities can count on being an afterthought in a process that affects ALL of our children. Lack of tribal inclusion is detrimental in an area of the state’s highest needs population, with the highest levels of poverty and people who reside in desolate, hard to reach rural communities.

Eligibility Requirements (b): Legislation should be in place requiring the State Advisory Councils on Early Childhood Education and Care (which is being created by this proposal) to include tribal governments.

Priorities, Priority 3: The RTT-ELC should address the mechanism by which early learning programs, legally operating without state licenses, will be permitted to participate. Funding streams are often tied to the obtainment of a state license thereby excluding many programs from opportunities to improve. This proposal should allow such centers to be supported as they are (legally operating without a license), rather than punished by not being able to receive priority status. If we are to adopt a common, statewide set of tiered program standards, these legally operating programs must be entitled to exercise their right not to obtain a license but should be able to prove the quality of their program based on other measures. Furthermore, state licensing does not equal quality. State licensing meets basic health and safety requirements and does not determine program quality. In California, monitoring visiting occurs once every five to seven years when no complaint has been filed against a provider. This proposal would do greater justice to children and families by requiring quality standards be met rather than requiring state licensing. Further, states should focus on strengthening licensing structures, increasing monitoring visits, and overseeing provider qualifications.

Priorities, Priority 5: The “encouraging private sector support” piece of the RTT-ELC provides a foundation for Tribes and states to work together for the betterment of all children. Tribes are able and willing to contribute to the composition and overall success of this project. This could be in the form of financial contributions, meeting space for training, or drawing from the expertise of parents and community members who understand the educational needs of this specific high need group. However, in doing so, Tribes would like to be included in other areas of this plan such as data, advisory boards, and workforce development.

Performance Measures: Assessments should be culturally appropriate for the many children that will be measured. The RTT-ELC might consider holding focus groups in different ethnic communities to determine which of the many assessments available would be most appropriate for their children. Further, evaluators should receive training in cultural competency.

Performance Measures (A)(4): The RTT-ELC should mention whether or not tribal data is important to this project and, if so, how states will record and track those data sets and what kind of data will be gathered. Traditionally, Tribes have not always been included in data collection by California. For example, when the state collects data from licensed child care providers for the purposes of determining maximum reimbursement rates for subsidized child care in California, Tribes were not consulted. Although Tribes were eager to oblige for purposes of inclusion in the survey, they were not afforded the chance. Above all, the RTT-ELC should specifically state how any data gathered will be made available to the public.

Barriers in current federal funding- Access to the Child and Adult Food Program by Tribes has been discouraging. The high level of documentation required in order to be eligible for meal reimbursements and the licensing requirement of program defer Indian early learning programs/providers from even considering the program as a resource. Another problem occurs when tribal early learning programs are housed with elementary schools. The school has a priority in getting reimbursed for meals and early learning programs are able to use any leftover dollars which leads to early learning programs getting under-reimbursed. Per the National Indian Child Care Association, Tribes recommend a Tribal Advisory Board be created by the program to investigate all the barriers that inhibit Tribes from accessing this program. The Board could then recommend strategies for easier access by Tribes.

Recommendations

  1. First item
  2. Second item

1.) Language should be added to the proposal to describe how Tribes can/will participate.
2.) Legislation should be in place requiring the State Advisory Councils on Early Childhood Education and Care (being created by this proposal) to include tribal governments.
3.) The proposal should ensure accessibility to resources and funding for early learning programs legally operating without state licensure.
4.) States should focus on strengthening licensing structures, increasing monitoring visits, and overseeing provider qualifications.
5.) The proposal should recommend that states partner with Tribes so that resources can be combined for the benefit of all children.
6.) Assessments should be culturally appropriate and require evaluators to receive training in cultural competency.
7.) The RTT-ELC should include a description of how Tribes can be included in data collection.
8.) The proposal should state how and when data will be available for review by the public.

I wanted to congratulate the Obama Administration for their thoughtful approach in designing the Early Learning Challenge. I wanted to suggest three specific areas in which the proposal could be strengthened:

1. I would like to see invitational priority #4 "sustaining program effects in the early elementary grades" be moved to an absolute priority. It would seem that with the latest research on Head Start and other high quality early learning programs all states need to do a better job of ensuring that the gains made do not fade out in anyway. In Washington State we have seen the benefit of a true P-3 approach in many of our school districts--most notably in Bremerton where the gains made in Head Start and other early learning programs are maintained and increased. It would only make sense to include the P-3 approach as an absolute priority based on the research and the need to build a more integrated system.

2. The Early Learning Challenge draft criteria from my perspective contains several major themes including the need for long term sustainability. Thus, it would only make sense to make invitational priority #4 "encouraging private sector support" an absolute priority. If we are to establish full buy in and sustainability we need the private and foundation sectors at the table and contributing resources. With states and the federal government being cash starved we can't expect the public sector to carry the full load nor should we ask them to. In Washington we have a great private public partnership in Thrive by Five Washington which has been instrumental in leveraging private sector resources both financial and know-how to our state's work in such areas as home visiting and parent resources among others. Again I think encouraging private sector support should be an absolute priority.

3. I appreciate that efforts have been made to include various stakeholders in a very fast process. But I would still like to see more intentionality on ways to bring parents into the conversation especially those that might benefit the most from these changes such as Head Start and Prek parents and parents utilizing child care subsidies. Our state is doing a good job of encouraging parent involvement and conversation but I think it should be more intensive and intentional around the country. If ultimately these funds will help states support at risk parents and their children, then parents need to be at the forefront of putting these proposals together.

Go Washington State!!

Joel Ryan, Washington State Association of Head Start and ECEAP (WSA)
www.wsaheadstarteceap.com

To: U.S. Department of Health and Human Services
U.S. Department of Education
Congressional Offices

From: Joan Wodiska, Committee Director, National Governors Association
Education, Early Childhood and Workforce Committee

Re: Race to the Top-Early Learning Challenge Fund

On July 1, 2011, the U.S. Departments of Health and Human Services and Education released draft requirements, priorities, selection criteria, and definitions for the new $500 million Race to the Top Early Learning Challenge (ELC) Fund. Governors offer the following statements of principle and general recommendations to inform the Department’s work.

Governors appreciate that the Departments of Health and Human Services and Education are working together to implement this new program. Governors support greater cross-federal agency collaboration to reduce red tape, duplication, and burdens on states and local government. Governors support and encourage integration and coordination with all other federal agencies that oversee early learning and child care programs to ensure a truly seamless system to create a continuum of high-quality early learning services for children ages birth to 3rd grade.

How to Make RTT-ELC Work for States and Governors

• Apply the Lessons Learned from Race to the Top
The nation’s governors learned many lessons from Round I and Round II of the K-12 Race to the Top program. Based on those experiences, governors strongly believe that any federal Race to the Top and similar types of competitions must resist prescribing a federal agenda that will define, direct, or control state policy. Race to the Top competitions must authentically support, spur, and help scale state-led innovation. Governors encourage the Departments to draw upon governors’ expertise in this area.

To this end, governors believe that the RTT-ELC program should support cross-state collaboration, promote the sharing and fine-tuning of state-led best practices, recognize differences in states capacity, and support the development of a learning community that will benefit all states, even those outside the program. It is critically important that all states benefit from the lessons learned through this new program. States should be allowed to compete in all priorities, or in a subgroup of categories, to ensure equitable distribution of awards across states, including small, rural, or frontier states, as well as states at varying stages in the implementation of their early learning systems. The Departments’ proposed budget caps merely reflect state population, and do not acknowledge the variations among states with respect to their development and implementation of early learning systems. The governors also believe that all states and U.S. territories should be eligible to apply and compete for the RTT-ELC program. Also, states ask that the Departments allow governors to electronically submit applications to save time and money. Lastly, the federal agencies should provide states with intensive and ongoing technical assistance during the application process, as well as after awards have been granted.

• Align, Streamline, and “Truly Integrate” Federal Early Education Programs
Across the country, governors are leading efforts to develop comprehensive high-quality early education systems to promote school readiness for all children, birth to third grade. Governors’ strong and early leadership in this arena has yielded numerous advances, innovations, and successes to improve the quality and access of early childhood education for our nation’s youngest students. In some instances, however, state efforts have been frustrated or restrained by a lack of coherence in federal early childhood programs. The new federal RTT-ELC offers an important opportunity for the federal government to begin addressing the shortcomings of existing federal early learning programs.

If states are to build a high-quality early learning system for all children, the federal government must do more to align, streamline, integrate, consolidate, and even possibly eliminate federal programs. While governors are encouraged that the Departments of Education and Health and Human Services are collaborating on this program, work remains. The federal government must take serious steps to review and align the many federal early learning and child care programs, spread across 10 federal agencies, and to provide states with greater and broad flexibility to get the most out of existing federal dollars and programs. Governors strongly encourage the Departments to provide states with the tools to integrate, consolidate, and streamline federal funding and programs. Without changes, the effectiveness of state initiatives to create a coordinated, high-quality approach to early education and care will be hampered. For example, states should be allowed to better connect, complete applications, and fulfill data reporting requirements for Child Care and Development Block Grant Funds, Early Childhood Comprehensive Systems grants, Early Learning Advisory Council grants, and many other federal programs. Additionally, the Departments should allow states to include Head Start and Early Head Start data in their comprehensive data systems.

• Retool Application to Support State-Led, State-Determined Plans
Especially in light of the rapid process to create this new federal program, governors strongly encourage the Departments to develop and implement this competition in a manner that respects, supports, and spurs state-led innovation. The RTT-ELC application priorities, criteria, and definitions must be significantly retooled to allow and preserve the maximum flexibility for states to propose innovative plans in early childhood education. For example, RTT-ELC eligibility and scoring criteria must give governors significant flexibility to address the needs within each state, and recognize the unique challenges faced by rural states or communities. States, not the federal government, should determine and document state needs, target populations, or geographic coverage.

Moreover, it is important to the integrity of the RTT-ELC program that the scoring criteria be drafted with enough flexibility to reflect rural needs. It is not sufficient nor fair for rural or frontier states to rely upon the indefinite authority of the Secretary to possibly make awards out of rank order. The RTT-ELC scoring should also consider the relative progress proposed by a state compared to their starting point, versus past RTT competitions that ran a straight comparison across all states.

The current criteria would require states to assess all incoming kindergarten children. This new requirement presents a considerable new cost burden for states. States have been allowed to use a random sampling model for collecting and reporting requirements under IDEA, and there is ample statistical support for the use of a random sampling model. States are in the best position to determine what method – assessment of all incoming kindergarten children or random sampling models – would be the best method.

Many states intentionally set-up QRIS as a voluntary system, rather than a system where all licensed and state regulated programs must participate. States are in the best position to determine if, and how, to utilize QRIS; it should not be mandated by the federal government. Related, the criteria would not only require use of QRIS, but validation of the model with outcome data. Again, the states are in the best position to create and propose a stronger, scientifically sound, validation process.

• Recognize Governors’ Lead Role
Governors are uniquely positioned to systematically advance early childhood initiatives and have been successful in this endeavor. Governors strongly believe that as the eligible applicant and responsible party for overseeing early education in the states, theirs should be the only required signature on the application. Governors well understand their state agencies, State Advisory Councils, Children’s Cabinets, stakeholders, partners, or even philanthropic community that need to be engaged, included, or participate in the application.

• Insist Upon a Transparent, Public Legislative Process
Governors are concerned the Departments waived the rulemaking process of this new $500 million program, and that the process to create this new program is occurring outside of the normal federal legislative and regulatory processes.

• Focus on Building High-Quality State Systems
Given these one-time federal funds and limited state resources, governors believe it is imperative that RTT-ELC focus on helping states build high-quality early education systems aligned to K-12 education for all students, to best and better serve the state-determined targeted populations. These one-time federal funds should not be used to unsustainably direct or require states to expand “slots.” Furthermore, given the limited and one-time nature of these funds and states’ challenging fiscal situation, no federal match requirement should be required of states to add additional funding into this initiative; rather the application should ask states to demonstrate their commitment and plans for sustainability.

Thank you for the opportunity to comment. For additional information on the views of the nation’s governors, please contact Joan Wodiska, Director, National Governors Association, Education, Early Childhood, and Workforce Committee, at (202) 624-5361 or jwodiska@nga.org.

The National Board for Professional Teaching Standards (NBPTS) appreciates the opportunity to provide comments on the draft selection criteria for the Race to the Top Early Learning Challenge Program. It is essential that our youngest children, who are at a critical point in their development, have access to highly accomplished educators. Thus, NBPTS would recommend that RTT-ELC emphasize the importance of professional standards that describe the key aspects of accomplished teaching in improving the knowledge, skills, and abilities of early childhood educators. NBPTS suggests standards in the following areas:
• Early childhood educators build the appropriate foundations with young children to ensure their future success.
oEarly childhood educators have the knowledge of child development that enables them to promote student learning in their classrooms.
oEarly childhood educators reach out to parents and the surrounding community in order to create a collaborative environment that fosters child development.
oEarly childhood educators welcome diversity. They interact in ways that show respect for other’s perspectives and cultures and work to establish this kind of community in their classrooms.
• Early childhood educators incorporate their understanding of young children into their teaching practices.
oEarly childhood educators integrate the basic concepts of different subjects into their method of teaching in ways that allow children to understand and appreciate each subject.
oEarly childhood educators employ a variety of assessment tools to support and build upon children’s abilities and needs.
oEarly childhood educators establish a learning environment that promotes young children’s development and learning.
oEarly childhood educators plan for children’s development and learning by setting developmentally appropriate goals and designing learning activities to achieve those goals.
oEarly childhood educators promote learning and development by utilizing a variety of strategies and resources.
•Early childhood educators demonstrate professionalism.
oEarly childhood educators engage in systematic reflection as a means to becoming a more effective teacher.
oEarly childhood educators contribute to the profession by engaging in partnerships with other educators, attending educational events, and taking on leadership roles to inform early childhood programs, practices, and policies.

Through the use of professional teaching standards, early childhood educators are able to identify areas in which they excel as well as areas for growth. When early childhood educators can assess their own teaching through the use of professional teaching standards, they can learn and grow in their teaching practices and advance their knowledge, skills, and abilities.

NBPTS also recognizes the value of strong professional development for all educators and would suggest the following in regard to partnerships between states, postsecondary institutions, and professional development providers:
•Create partnerships that utilize professional teaching standards in their approach to preparing early childhood educators.
•Create partnerships that use standard-based, job-embedded professional development to develop more effective early childhood educators.
•Create partnerships that produce professional learning communities so that early childhood educators can collaborate to improve their practice.

For example, NBPTS has a number of programs that would facilitate partnerships such as those listed above. The NBPTS Early Childhood Generalist Standards (2010) can be implemented into the curriculum postsecondary institutions use to train early childhood educators. In conjunction with these standards, the Take One! program can be used by postsecondary institutions. Take One! is built upon the foundation of National Board Certification, and can be incorporated as a professional development tool for soon-to-be educators at post-secondary institutions. Participants prepare and submit one pre-selected video portfolio entry, making it possible for teacher candidates, for example, to video themselves teaching a lesson during a clinical experience such as student teaching. Participation in Take One! affords teacher preparation programs an opportunity to emphasize the critical role of professional development to the newest early childhood educators and help them reflect on their practice before entering the classroom full-time.

Partnerships between postsecondary institutions and early childhood programs with educators who have already been in the classroom for three years or more could utilize full National Board Certification to further examine and improve their teaching practices. Some master programs already include the National Board Certification process as part of the degree. In either case, teacher candidates have the opportunity to use National Board programs as a basis to inform their developing teaching practices. Many teachers who pursue National Board Certification regard it as the most significant professional development experience in their career. Furthermore, both National Board Certification and Take One! contribute to professional learning communities in which educators collaborate to improve their teaching. Partnerships that create a coherent system of professional development that encourages growth from even the earliest point in an educator’s training are an integral component of developing effective early childhood educators.

Thanks again forthe opportunity to comment.

Sincerely,
Seth Gerson
Director of Government Relations
National Board for Professional Teaching Standards

I wanted to congratulate the Obama Administration for their thoughtful approach in designing the Early Learning Challenge. I wanted to suggest three specific areas in which the proposal could be strengthened:

1. I would like to see invitational priority #4 "sustaining program effects int he early elementary grades" be moved to an absolute priority. It would seem that with the latest research on Head Start and other high quality early learning programs all states need to do a better job of ensuring that the gains made do not fade out in anyway. In Washington State we have seen the benefit of a true P-3 approach in many of our school districts--most notably in Bremerton where the gains made in Head Start and other early learning programs are maintained and increased. It would only make sense to include the P-3 approach as an absolute priority based on the research and the need to build a more integrated system.

2. The Early Learning Challenge draft criteria from my perspective contains several major themes including the need for long term sustainability. Thus, it would only make sense to make invitational priority #4 "encouraging private sector support" an absolute priority. If we are to establish full buy in and sustainability we need the private and foundation sectors at the table and contributing resources. With states being cash starved we can't expect the public sector to carry the full load nor should we ask them to. In Washington we have a great private public partnership in Thrive by Five Washington which has been instrumental in leveraging private sector resources both financial and know how to our state's work in such areas as home visiting and parent resources among others. Again I think encouraging private sector support should be an absolute priority.

3. I appreciate that efforts have been made to include various stakeholders in a very fast process. But I would still like to see more intentionality on ways to bring parents into the conversation especially those that might benefit the most from these changes such as Head Start and pre-k parents and parents utilizing child care subsidies. Our state is doing a good job of encouraging parent involvement and conversation but I think it should be more intensive and intentional around the country. If ultimately these funds will help states support at risk parents and their children, then parents need to be at the forefront of any serious conversations.

Go Washington State!!

Joel Ryan, Washington State Association of Head Start and ECEAP (WSA)

The Race to the Top--Early Learning Challenge provides a wonderful opportunity to build upon current state and federal initiatives to further strengthen the early childhood work at the state and local levels. However, some of the wording in the draft application and selection criteria may reduce the ability of a state to participate fully in the opportunity presented by the grant. Some suggested considerations:

Priority 4: this is not an invitation priority which does not carry points with it and which therefore reduces its potential impact on the educational and learning continuum. Please consider making this a Competitive Priority, thus truly 'sustaining' the impact of this grant into the early elementary years.

Selection Criterion (A)(5): Sustaining the impact of this grant will require committment and effort beyond 'just' financial. Allowing re-alignment of resources, and reallocation of funds will show committment of agencies and states. Please consider reframing the requirement to "sustain funding levels (A-5-(a) ii) which may be a barrier to many states in this time of fiscal restraint and reduction. Sustainability could be desribed as encouraging states to show their committment to maintaining high quality early learning opportunites through leveraging current funds and building on current activities and intiatives to maintain the efforts of the RTTT-ELC while adding in funding from current sources that may have been reallocated during the grant years. Such wording allows states to build upon what is already in place and takes into account the fiscal contraints that many states have.

Selection Criterion (B)(3)(c): Rather than requiring all children entering kindergarten to be assessed, allowing a system of representative sampling for determing the skill level of entering kindergartners is more fiscally possible and will provide the state with the necessary information to inform instruction at the kindergarten level as well as provide information for professional development for early childhood educators who work with children ages birth tofive.

Thank you for the opportunity for input and the support and interest in early learning!
Gayle

We are a private church based day care and we oppose the program as presented. The proposed requirements for the RTT- ELC state that in order for states to be eligible they will have to have a plan to bring all early learning programs (including private and non-regulated) under their improvement system and licensing program. This would bring our day care under governmental control, even though we do not operate with public funds and already have a strong accountability system in place that ensures the quality of our program. These regulations would take away rather than enhance what we already have instituted which is to ensure that our students have a strong educational base given in a caring, nurturing enviroment.

The Race to the Top Early Learning Challenge (ELC) represents an important federal initiative to support the development of early learning systems in states. The systemic approach reflects and supports the need for infrastructure – strong state frameworks that make feasible the integrated, efficient, coherent delivery of a continuum of services for young children and their families. The BUILD Initiative applauds the spirit and systemic direction of the Challenge; working from our key principles, we are committed to supporting states as they use this significant opportunity to advance their systems planning and implementation.

The Obama administration has received accolades for the commitment to partnership among leaders in the US Departments of Education and Health and Human Services, a commitment exhibited most strategically through the appointment of a high level representative to purposefully align efforts across the Departments. This recognition of the importance of cross-departmental planning, however, could be more visible and practical by modeling, through the ELC, thoughtful interaction and shared leadership, commitment and accountability from all related federal offices on the expectations and priorities of the ELC and by intentionally building upon the assets of other federal initiatives. Great value would be added by outlining, for example, the Office of Head Start’s position and commitment to the promotion of cross-sector early learning systems development, along with clear guidance for more effective integration of federally-funded Head Start grantee programs with state and privately-funded programs in states’ QRIS. The administration’s strategic promotion of State Advisory Councils could be more fully leveraged through a requirement that SACs hold authority and responsibility for states’ ELC planning and application. At present in the ELC, promotion of quality is limited to programs licensed by the state; promoting coordinated networks of early learning service delivery in states among all types of programs is a significant opportunity that would be bolstered by cross-departmental leadership and agreement at the federal level. For states to be able to make significant progress in developing strong cross-sector early learning systems, federal level integration (cross-office development and implementation of policy, funding, and accountability efforts, communicated through clear and coordinated guidance to states) is necessary.

Many states, even as they grapple with severe economic challenges, are taking strategic steps to establish the infrastructure for high quality comprehensive early childhood systems to reach the goal of thriving children and families. While the ELC promotes system building in early learning, the current Executive Summary falls short in strategically linking policies and practices across and among the early learning, health, and family leadership and support sectors. As well, a strong, stable early childhood system ensures stability and continuity of services along a continuum from prenatal to school entry and beyond across health, early learning and development programs, and family leadership and support.

We strongly recommend that the application include a new competitive preference priority to integration and alignment, awarding points to applicants who show a thoughtful plan for the integration of services, programs and policies across early learning, health, and family leadership and support. We recommend that applicants be awarded points for showing a thoughtful plan for addressing the continuum of prenatal into the elementary years, successfully bridging and aligning 0-5 and K-12, as well as for encouraging private sector support.

We affirm the commitment to quality and accountability reflected in the ELC, particularly through the absolute priority placed on the implementation of early learning standards and kindergarten entry assessments and the competitive priority placed on the pace and scope of implementation of QRIS. Yet the pace of implementation on short-term deadlines may prompt states to take short-cuts, sacrificing long-term quality and accountability for short-sighted urgency of access. In terms of scope, the ELC focus is limited to early learning programs licensed by the state; the ELC could be strengthened to influence states’ vision and action in delivery of early learning services through a coherent network, involving child care, state-funded preschool, Head Start, infant toddler programs, as well as family, friend and neighbor care, acknowledging and addressing the large numbers of children served within that community. While much family, friend, and neighbor care is provided without payment and because of a personal connection with the child and therefore is not included within state licensing definitions, there are actions states can take to help these caregivers promote children’s early learning and development.

We strongly recommend that priority should be placed squarely on quality and rigor, supporting states in setting ambitious yet achievable timelines for implementation rather than setting artificial deadlines that may not support high quality implementation. Specifically, we recommend that the ELC should incent thoughtful implementation of kindergarten readiness assessment that is comprehensive of all domains of children’s learning and development, as well as of QRIS that hold all licensed early learning programs accountable to research-informed quality indicators that signal children’s optimal growth and development and provide incentives and supports to strengthen the capacity of family, friend, and neighbor care to be of high quality and connected to other support systems.

The emphasis on “High-Need Children” in the ELC is well placed. Supporting states in addressing issues of disparity is critical to achieving the goal of closing the school readiness gap at kindergarten entry – and is key to BUILD’s work. We also appreciate the draft’s definitional inclusion of “children who have disabilities or developmental delays, who are English language learners, who reside on ‘Indian lands,’…who are migrant, homeless, or in foster care; and other children as identified by the State.”

We strongly recommend that the ELC guidelines go a step further in promoting more explicit and expansive attention to issues of race, language, and culture, in each component area. States should be required to be specific in their identification and definition of “High-Need Children,” in outlining their plan to reach those children and engage their families and communities, and in how race, language, and culture will be addressed in implementation of early learning guidelines, kindergarten assessment, QRIS, data systems, and workforce development.

BUILD congratulates federal leaders for extraordinary diligence in making the Early Learning Challenge possible, and for persisting in their vision, which we share, of supporting and promoting early childhood systems in states to reach our common goal of thriving children and families. Grasping the benefit of a high tide raising all boats, BUILD commits to making the most of this wave by supporting states in utilizing the ELC opportunity as powerful incentive to advance discussion, planning, and action in the best interests of our nation’s youngest children.

Voices for America’s Children School Readiness Advisory group thanks you for the opportunity to provide comments on the proposed criteria for the Race to the Top – Early Learning Challenge Grants (RTT-ELC). The School Readiness Advisory Group is comprised of 73 members from 48 Voices organizations in 40 states. The following comments reflect the chronological outline of the proposed requirements.

We applaud and agree with the absolute priorities that state applications must address the need to improve early learning and development outcomes for High-Need Children. It is essential to provide access to high quality early learning experiences for all children, especially those in greatest need. Requesting states to have a plausible plan to implement kindergarten entry assessments is beneficial to advance our knowledge about the nature of the school readiness gap and enhance the ability to respond early to prevent continuing gaps. Is there a requirement for the quality of the assessments? What percentage of the grant will be allowed to fund the implementation of a comprehensive assessment (including professional development)?

We concur with your priority that there needs to be an increase in the number of High-Need Children who have access to high-quality learning and development programs. We are curious to know, however, how and if Priority 2 could exclude states from being eligible for competition.

The competitive preference priority 3, to include all early learning and development programs in the Tiered Quality Rating system, is admirable and ambitious. Our Advisory Members express concern that it may be impossible for the vast majority of states to implement and enormously challenging to apply standards to all early childhood settings within the grant period. Most states have limited tiered quality rating systems that are in early stages, and are voluntary-- and public pre-K programs are not included in nearly every system and are likely to be resistant. At a time of major cuts to public education, this seems too onerous as a one of the competitive preferences. Is other language preferable – such as “develop a comprehensive plan to include all early learning and development programs in the Tiered Quality Rating system, and make significant progress toward that goal during the grant period”?

Can you provide more guidance on the funding source(s) to implement a “licensing and inspection system covers all programs that are not otherwise regulated by the State and that regularly care for two or more unrelated children for a fee in a provider setting”? Will recipient states be allowed to use RTT-ELC grant funds to implement a comprehensive licensing and inspection system?

We are pleased to see the inclusion of Invitational Priorities 4 and 5. The sustainability of program effects through the elementary years for all children is highly desirable. Other states can benefit from effective and tested models of success. Priority 5 encouraging states to describe how they will engage the private sector to provide financial and other resources to support this effort.
The next set of comments and questions are related to the proposed selection criteria.
• Will there be a minimum requirement for the increase in the percentage of high-need children participating in high-quality Early Learning and Development Programs?
• Building and improving statewide longitudinal data systems are essential components to supporting children. Data systems have multiple uses including information gathering, transition planning, and quickly gauging if and when supports need to be amended. (A) (4)
• We concur that applications should provide information on how they will engage and support families of High-Need Children. (B) (5)
• Will recipients be required to incorporate competencies around race equity, culture, and language? (D) (1)
• Will grant recipients be required to include the associated cost of developing workforce knowledge and capacity? (D)(1). We think this would be helpful in informing the rest of the field.
• Will there be a recommend scope of professional development opportunities? (D) (2) (a)
• Will RTT-ELC be allowed to be used for the recommended policies and incentives (D)(2)(b)?

In conclusion, we think the RTT-ELC provides a learning opportunity approach for states and local government. The grant will enable us to see how far a state can move within the framework provided. While we encourage excellence, reform, and innovation we also would like to see inclusion of funding supports for states that start at different stages to learn how this type of funding can move the bar. Are we missing an opportunity to develop models that improve states that will not qualify for the competition based on the current proposed criteria?

With 62 member organizations in 46 states, [the District of Columbia and the U.S. Virgin Islands,] Voices is the largest network of its kind. Nonprofit and nonpartisan, Voices works at the local, state and national levels to ensure that all children have what they need: safe families and communities, quality education and care from a young age, health care and other supports.
We thank you for the opportunity to submit our comments.

The School Readiness Advisory Committee, Voices for America’s Children

The Early Childhood Funders Collaborative comprises national, regional, and local foundation leaders who support young children by investing in their healthy growth and development from birth. Over the past decade, our foundations have invested hundreds of millions of private dollars to improve availability and quality of care and education programs and services. We launched BUILD in 2001 and through that early childhood systems building initiative have seen first-hand the power of an integrated, comprehensive approach – creating early childhood policies that respond to child health, nutrition, mental health, family support, and early care and education needs across all services and supports for young children and their families.

The Obama Administration has been a pioneer in collaboration, evidenced by the structure of the Early Learning Challenge and the strong working relationship between the U.S. Departments of Education and Health and Human Services on early learning issues. Many states have been challenged to follow suit and build stronger state collaborations. While we commend the Administration on this unprecedented partnership, we feel the guidelines could go further to build true and lasting collaboration and alignment at the state level.

The ELC represents an opportunity for states to make important advances in creating the flexible, comprehensive, and high quality early childhood systems that will help our youngest children thrive. While this opportunity is exciting, it is also challenging for states facing grim economic realities. The ELC guidelines must recognize the context within which states are operating.

Comprehensive & Integrated Approach Is Critical
To promote long-term, substantive change the ELC should focus first and foremost on systems integration, giving weight to states moving beyond individual programs and building and strengthening connections across all early childhood services and supports, including early learning, healthy child development, mental health, nutrition, medical home, and family supports such as home visiting. The guidelines mention the importance of a comprehensive approach, but the priorities, definitions and selection criteria miss the important opportunity to incent and reward true integration across all early childhood system aspects and alignment between the early childhood system and K-12 education. We believe that a comprehensive approach represents the best chance for all children, particularly the most vulnerable, to receive the equal opportunity they deserve to develop the social, emotional, cognitive and physical skills necessary to grow to their full potential.

The roles of Head Start and Early Head Start, for example, should be called out and states challenged to achieve integration across these and other programs while developing data systems. An advantage should be awarded to states that can show they are planning comprehensively and that can demonstrate strong linkages across systems, such as effective referral mechanisms, coordinated/streamlined licensing processes, aligned data systems, and shared goals and training requirements.

Better Alignment Between Early Childhood and K-12 Is Needed

Learning begins at birth and a continuum of high quality educational experiences is necessary for our children to succeed. The ELC should reward states that are taking a comprehensive approach to education reform – supporting families, communities, early educators and schools that partner to help children learn from birth through adulthood. Too many children are lost in the transitions between the early education and K-12 systems. College and career-readiness can be achieved only by building a strong foundation for learning from birth onward with smooth transitions into the elementary schools.

QRIS is a Powerful Lever For Systems Reform

We applaud the ELC’s emphasis on quality. Since accountability is essential to quality improvement, we are heartened to see an absolute priority placed on the use of early learning and development standards and kindergarten entry assessments to promote readiness and drive consistent expectations of high quality. The guidelines should incent assessments that incorporate the multiple dimensions of child development (not merely cognitive or early literacy assessment) and also incent states to invest in the early childhood workforce by increasing opportunities for professional development and improving pay, health care coverage and leave policies for early childhood teachers to bring them to parity with K-12 teachers.

Many states are making significant progress toward creating and implementing Quality Rating and Improvement Systems (QRIS) and using QRIS as a powerful lever for systems reform. We are pleased that the ELC will reward states that have a clear plan to use QRIS as a quality framework. However, we are concerned that the guidelines are focused more on broadening access to QRIS without adequate focus on rigor and assurances that implementation will be supported to sustain high levels of quality over time. The speed at which you are asking states to move on QRIS is a concern. Pushing states to serve so many, so quickly, could strain capacity and result in systems that do not drive quality high enough and do not have the infrastructure in place to sustain quality over time.

Higher Priority on Private Sector Support and Sustaining Program Effects into Early Education Years

Based on decades of experience in supporting states, we believe it is important that the ELC guidelines are flexible enough to allow states to push forward innovative ideas that get beyond rigid funding streams to foster true collaboration and create seamless systems of supports for children and families. While we are pleased to see priorities encouraging private sector support and sustaining program effects into the early education years, we believe they should be absolute rather than invitational priorities. Both are critical to advancing a “cradle to career” education agenda.

Value in Supporting States All Along the Continuum

Finally, although we understand that readiness to use an infusion of funding effectively is an important selection criterion, we hope that the ELC will employ a thoughtful and careful definition of readiness. While it will be important to reward states who are farthest along and elevate states as examples of what is possible, this funding could provide a critical boost to those states who are showing beginning signs of progress. We hope that the ELC can support states at many stages on the continuum toward the high quality early childhood system toward which we strive.

While I believe this program may provide states with exciting opportunities to link early childhood programs with public education, I worry about the "kindergarten entry assessment." Kindergarten has already become far too academic when it ought to be about play and building creativity, motor and social skills. If developmental screening for all kids is done early then the assessment could wait until 3rd grade. There's too much testing already -- teachers are teaching to the tests, not giving children appropriate educational activities for where or how they live.

The Council of the Great City Schools, the coalition of the nation’s largest central city school districts, submits the following RTTT comments in the context of the high importance of early education to our urban schools. The Council has been consistent in our strong support for raising standards and appropriately assessing outcomes. As importantly, however, are the strategies, methodologies, practices, supporting materials, and training to implement the higher standards at the operational level with children.
1) In general, the proposed Early Learning requirements, priorities, and criteria appear to miss the mark by not requiring the clear expansion of program capacity to serve additional children in a state’s early learning and child development programs. The Council notes only one reference to a goal of increasing the number and share of high need children (page 14), but no overall emphasis on increasing the number of children served. The proposed absolute and competitive priorities, and selection criteria focus on encouraging early learning programs to become “high quality” programs. However, it appears that a state could meet these new requirements merely by ensuring existing programs participate in the new standards, assessments, data systems, qualifications requirements, and other statewide policies without serving any more children than are currently served. After five years of funding, it is critical that the Early Learning RTTT States are required to serve more young children than in the current baseline, as well as demonstrate that additional low-income children, English language learners, and children with disabilities are being served in greater numbers and proportions. [Recommendation: Revise the program priorities and criteria to require increasing the numbers of children served by programs in the state, as well as requiring all programs to meet the new High Quality requirements.]
2) The Council notes that nothing in the requirements, priorities, or criteria ensures any significant amount of the $500 million in new Early Learning funds will be used at the local level to improve local early learning instructional practices. Moreover, no attention is addressed to documenting effective practices and disseminate information on such effective practices in serving young children or children with specialized needs across the state or nationally. There is a significant dichotomy between establishing statewide standards, measures, benchmarks, systems, and qualifications, and the essential operational strategies, methods, techniques, and supports that put statewide policies into action at the program level. Little attention seems to be addressed to these critical operational issues of direct services to young children. [Recommendation: Add an additional selection criteria to address the amount and use of funds directed to implementing and improving instructional and service delivery practices, and to documenting and dissemination effective practices across the state and nationally.]
3) The Council is concerned that the proposed requirements and criteria will suggest to state policymakers that the Race To The Top Early Learning Initiative supersedes other statutory and policy priorities including ESEA or IDEA. The states do not have the legal authority to "reallocate" ESEA or IDEA formula grants nor to use those funds for other "repurposing". [Recommendation: On page 11 in criteria A(5)(a) strike "repurposed and reallocated" and "repurposing and reallocating", and insert "coordinate" and "coordinating" respectively.]
4) The Council supports the emphasis on closing achievement gaps among the disadvantaged, minority, language minority and disabled at the early learning level. The Council's previous comments are designed to help the program better effectuate this important goal.
5) The Council supports the use of the authority of the Secretary to ensure that early learning grants are awarded broadly enough to meet critical national needs and demographic needs (page 6). The Council urges the Secretary to use this authority to ensure that high need urban areas, not just rural areas are properly served with these funds. The Council urges that the multi-faceted effects of intense central city poverty on huge segments of the nation's population, particularly young children, should not be discounted in addressing other less concentrated needs.

Jeff Simering
Council of the Great City Schools
Washington D. C

As a father I applaud this opportunity and hope we recognize this as journey, not a race to creating a society that embraces the value that every child matters and that their life course should not be dependent on what zip code they were born in and that success is not defined by scores, creditentials and dollars. America needs to create the space and place, everywhere and for every child so that they are set on a strong, stable life course and success is defined by positive social and emotional well-being. America means all of us who say we care about children, the social well-being of our society and want to be a strong America for the many, not the few need to be a part of this journey and help it continue and succeed. And as we look to solutions that are in the best interest of the child we should look from the child's place and be mindful they do not thrive in isolation. Community matters, women's health matter, environment matters, income security matters, housing matters, empathy matters, fathers matter. Again, I commend the tiresome advocates, this adminstration and the many others who have and are making this journey possible. "Take care of our children, for how the children grow so will be the shape of America, our world and ourselves."

The Kentucky School Boards Association (KSBA), representing nearly 900 local school board members, is pleased to submit comments on the draft proposal of priorities and criteria for the Race to the Top Early Learning Challenge (RTT-ELC) program. KSBA has been a longtime advocate of full funding for early childhood education. Most recently, KSBA was represented on Governor Steve Beshear’s Early Childhood Education Task Force. As part of that task force, KSBA supported increasing access to high-quality early childhood education programs. Many of the task force’s recommendations align with the priorities set in the RTT-ELC, including developing early learning standards for the promotion of school readiness, using a tiered quality rating system and sustaining effects of early learning through throughout elementary school. Kentucky already has begun to implement some of the recommendations.
Currently, Kentucky has a voluntary rating system for public schools and private child-care providers of early childhood education. Kentucky has also embraced Response to Intervention programs for children starting as young as 3.
Finally, many local school districts in Kentucky are embracing new programs to bring highly qualified, effective teachers to the classroom, even in private child-care classrooms. For example, the Christian County school district partnered with a local child-care provider to send a certified public school teacher to private child-care centers to teach children eligible under Kentucky’s preschool program. This is benefiting both the district and the child-care provider. For all of these reasons, KSBA believes that the Commonwealth of Kentucky is well- positioned to be awarded a RTT-ELC grant. KSBA looks forward to being a partner in this endeavor, but we do have some specific concerns about the draft RTT-ELC priorities and criteria for awarding the grant.
1. Local school board members should be included as stakeholders in the process of applying for and implementing RTT-ELC grants. Local school districts in Kentucky are successfully coordinating with multiple partners to implement high-quality early learning programs. In many communities the largest provider of early learning is the local school district. Without the inclusion of local school district leadership, it would be more difficult to successfully implement such a grant. It is for these reasons that KSBA supports adding local school district governance representation to the stakeholders list. KSBA will work with the Kentucky Department of Education in getting letters of support for Kentucky’s grant application from local school districts and other education advocates.
2. KSBA supports equal representation of both early childhood advocates and K-12 educators in the application and implementation of the RTT-ELC. Kentucky was the first state to adopt the Common Core Standards and is in the process of developing a new assessment and accountability system. For Kentucky to improve the education for all children, we need to make sure that early childhood advocates and K-12 educators are working collaboratively to achieve this goal. Kentucky has a model for this in our P-20 councils, made up of local community leaders at all levels on the education spectrum. The draft proposal states one of the invitational priorities is to sustain early learning results through the third grade. This cannot be done without a coalition of partners at all levels of education, especially local school board members.
3. Our final, and greatest, area of concern is the requirement to redirect existing state, federal and local education funds, including Title I and IDEA. The wording of this section makes it appear that this is mandatory. Local school districts in Kentucky already are hard-pressed to provide education services to their students. In Kentucky, the General Assembly provides funding for only half-day kindergarten, but the overwhelming majority of local school districts provide full-day kindergarten to all students, paid for with local funds. Current allocations of IDEA and Title I, are not adequate to fulfill the current requirements of the program. The ongoing national economic situation has already placed a hardship on local school districts. If they were forced to redirect funds from other programs, it could be at the cost of other educational goals. KSBA sees this requirement as an unfunded mandate and strongly asks that you consider changing it.
KSBA agrees with the National School Boards Association’s comments that local school district leadership plays a vital role in student achievement at all levels. In Kentucky, we want to build on our successful partnerships to improve early childhood education. KSBA believes that without strong involvement from local school district leadership, we will not reach our highest potential. Therefore, we ask that you make local school district governance an equal partner in the RTT-ELC application and implementation process. We also ask that you do not require districts to redirect local, state and federal dollars to be eligible to participate in the program. We thank you for the opportunity to submit comments on the draft proposal. If you would like further information on incorporating local school district leaders, please contact NSBA or KSBA. Questions regarding our concerns may be directed to Shannon Stiglitz, director of governmental relations at 502.783.0061 or Shannon.stiglitz@ksba.org

Sincerely,

William G. Scott
Executive Director, Kentucky School Boards Association

Nemours thanks you for the opportunity to comment on the Race to the Top – Early Learning Challenge Program. As one of the nation’s leading child health systems, Nemours is dedicated to achieving higher standards in children’s health by offering a spectrum of clinical treatment, research, advocacy, education, and community-based prevention initiatives extending to families in the communities it serves. Starting with Alfred I. duPont’s bequest over seventy years ago, Nemours has grown into a multi-dimensional organization offering personalized clinical and community-based preventive care focused on children. Nemours operates Nemours BrightStart!, which has developed an innovative early screening and differentiated instruction program that targets four- and-five-year-olds who are at risk of reading failure. Cluster randomized research studies have proven the efficacy of this unique program in increasing critical early literacy skills for young, at-risk learners, and longitudinal data analyses suggest significant lasting effects.

General Comments and Priority Area 2

As a foundation, Nemours recognizes the importance of increasing access to quality early learning programs. We commend your focus on early childhood development. In particular, we are pleased that you included language and literacy as part of the “essential domains of school readiness.” Reading ability is the strongest individual predictor of adult health status and the foundation for academic and employment success. Reading failure affects 30 percent or more of our nation’s children, making it a major child health issue. If states are to increase access to quality early learning programs, then improving reading readiness skills for children at risk of reading failure should be part of the state plan, and evidence-based literacy instruction should be addressed in a state’s Quality Rating and Improvement System. This should include enabling states to use funds to support developmentally appropriate comprehensive literacy programs and programs that provide differentiated instruction for “high-need children.”

Priority Area 4

Nemours recognizes the importance of the transition between the pre-school years and the early elementary years, and we agree that this transition is worthy of prioritization. In addition to integrated data systems and technical support, maximizing transition opportunities requires shared philosophy, pedagogy, and child development knowledge across varied service delivery systems and diverse teachers. For this reason, we encourage you to promote comprehensive joint trainings of early childhood educators, child care providers and elementary educators, as well as program administrators, supervisors, center directors, and school principals, as part of Priority Area 4. This collaborative training would help develop mutual understanding of critical instructional priorities and challenges at each age and grade, foster a broader sense of shared responsibility and accountability for long-term child development outcomes, and facilitate a smooth “hand off” as children move from one learning setting to another.

We commend your inclusion of a reference to increasing the percentage of children who are able to read at grade level by the end of third grade. The foundation for successful reading is built in the early years, when a young child’s brain is highly responsive, adaptable, and attuned to learning language. Research has shown that if a child is not reading on grade level by the end of first grade, he or she has only about a 10 percent chance of reading on grade level at the end of fourth grade. Therefore, early childhood educators, child care providers and early elementary educators should receive joint professional development regarding research-based early literacy instruction and strategies for all children, including “high-need children,” to ensure that children are receiving quality early literacy instruction during key developmental years.

Selection Criteria (A)(3) - Organizing and Aligning the Early Learning and Development System to Achieve Success

Nemours commends your inclusion of a criterion requiring demonstration of commitment to the State Plan from a broad group of stakeholders and local communities. We recommend adding health providers serving children as an optional category on the list of stakeholders. Health care providers serve a critical role in a child’s early development. They are trusted resources for families and parents and can foster a child’s healthy development and early learning by encouraging parents to read to their children, encouraging healthy and active lifestyles, providing health, literacy and other developmental screenings, and referring parents to resources in the community. As a result, health providers serving children should be among the stakeholders consulted as states organize and align their early learning and development system.

Selection Criteria B – Promoting Early Learning and Development Outcomes for Children

Selection Criterion B focuses on promoting early learning and development outcomes for children. Nemours recommends including a section that addresses training early childhood educators in essential child development knowledge and implementation of research-based instructional tools, strategies, programs, or techniques to specifically address the needs of “high-need children” through developmentally-appropriate differentiated instruction.

Selection Criteria – (B)(5) Engaging and Supporting Families

We commend your inclusion of a selection criterion relating to family and parental engagement. Through our experiences with Nemours BrightStart!, we have found that parental engagement is critical to a child’s healthy development and future academic success.

Selection Criteria (D)(2) Supporting Early Childhood Educators in Improving their Knowledge, Skills, and Abilities

Nemours commends your inclusion of Selection Criteria D, which focuses on the early childhood workforce. Within sub-part 2, we recommend that you add a requirement that specifically references training that focuses on differentiated instruction for diverse learners. As states develop their early childhood education workforce, if they are to truly improve the academic and developmental outcomes of “high-need children”, then educators must receive specific training or targeted professional development related to the characteristics and needs of diverse, at-risk learners. Teachers sometimes make erroneous assumptions that students with diverse learning needs cannot learn in the mainstream classroom, and do not see themselves as capable of effectively teaching them. When these issues are specifically addressed through training, teachers can change their belief systems about diverse learners and themselves, which is critical to effective instruction for all children.

Thank you again for the opportunity to comment. Please feel free to contact me with any questions.

Sincerely,

Laura Bailet
Executive Director
Nemours BrightStart!

One of my concerns about this initiative relates to the poor results achieved by Outcome Based Education, No Child Left Behind, and standards applied through use of the SOL testing program. In my 17 years of teaching, I have yet to see a federal education initiative achieve what it hopes to. There are many with noble goals, and ideals in educational outcomes are wonderful, but on the federal level, no local school system can be paired with another. Each locality is unique, with different types of needs among children, different levels of support through taxpaying population, and different ability to attract highly qualified teachers. The best education in America has always been locally directed and funded; whenever the federal government has stepped in to "level the playing field," even in terms of funding, the results have been costly for localities and for students.

Another of my concerns is that there is no room for an exemption for religious and faith-based schools and pre-schools. This all-encompassing initiative would lump everyone under government control. There are many, many faith-based pre-schools (which were begun in churches and homes, anyway) that provide an excellent start for children preparing for school. These programs may be forced to shut down rather than allow any additional government intrusion into their religious practices, including day cares and pre-schools; this would further handicap children and burden state programs, while removing a presence that has accomplished so much good for the children of this country. A religious exemption clause desperately needs to be added in.

My final concern is that nationally standardized testing can create problems in the classroom. Those who don't test high enough are labeled one way, and seem to never escape the label, even though they may blossom later down their road. Those who test very high are labeled another way, and we still have not "leveled" anything; in fact, high-scoring students are often held back from soaring because of the lesser-abled students in the classroom. Teachers, too, wind up smothered in paperwork for each student and unable to devote time to developing solid, quality lesson plans that would challenge all the learners in the classroom. And any honest public school teacher will tell you that trying to score high enough on SOL tests in order to qualify for federal funding causes the pressure from the top on down to teach the test until it is taken, and then subject matter can be taught again. What have we taught the children by doing that? We have taught them to cram so that their teachers, aides, principals, and janitors can keep their jobs. Just do this work for 1/3 to 1/2 of the year, and then we can do what we are really here for. But have they learned thinking skills or life skills?

Control needs to remain, as much as possible, at the local level, so that the universality of federal control does not wipe out a system already overburdened with red tape. Not being a politician at any level, I don't know how to reconcile that with opportunities for funding. But as an educator, I have seen many times over that the stronger control there is locally, the better all the students do in the school district. And isn't that what we're after here?

On behalf of the Division for Early Childhood (DEC) of the Council for Exceptional Children, we appreciate the opportunity to comment on the new Race to the Top – Early Learning Challenge (RTTT-ELC) application package. We support the commitment of the Administration to invest $500 million to early learning from the Race to the Top funds available in FFY’11.

DEC requests consideration of the following comments and recommendations as the application package is finalized.

DEC recognizes and strongly supports the clear and comprehensive inclusion of children with disabilities and the services, providers and programs that support their success in quality early learning settings within the community. For example, we note the definition of “high need children” includes children who have disabilities and developmental delays. Further, Part C and Section 619 Preschool under Part B are recognized programs under this plan; Part C lead agencies and the state agencies administering the Section 619 program under IDEA are required partners; the Part C of IDEA Interagency Coordinating Council is included in the governance structure; child find activities under IDEA are covered; organizations such as DEC state affiliates are mentioned; and finally it is clear that the requirements of IDEA must be met as a condition of a state’s participation under this program.

DEC must take this opportunity to state clearly that adequate federal investment is essential to successful outcomes for all young children and their families. While the $500 million is a significant investment, it must be noted that existing federal, state and local resources are not adequate to ensure the needs of all children are met. The package requires states to “reallocate or repurpose” existing funds. The obvious implication is that adequate funds are available but not being spent wisely. These funds, particularly IDEA funds, have statutory requirements about their use. All funding sources mentioned are in fact underfunded and stretched beyond their limit. Therefore, DEC recommends that states not be required to report how the state will “reallocate or repurpose” existing funds. Instead states should be asked to address how all funds will be used to support the overall goal of the effort.

DEC supports the inclusion of data-based performance measures particularly related to tracking and reporting increases in the numbers of children participating in high-quality early learning and development programs. We strongly support subgroup reporting including by age group and disability status.

While DEC strongly supports the emphasis on engaging and supporting families as a selection criterion we recommend that the final package emphasize not only what early learning systems provide “to” families but how systems partner “with” families. Family engagement is a core element to the success of this initiative and states should be directed emphasize the role of parents and family members.

DEC notes that many infants and toddlers do not participate in group or program settings in their community. Infants and toddlers receiving early intervention services may receive those services in their home, a family member’s home or in a family child care setting. The application package should be reviewed and revised consistent with this reality to be sure that the home environment is appropriately addressed in this investment. This is particularly true for the existing component of a “State’s Tiered Quality Rating and Improvement System” that seems to more closely align to group or program settings.

While supporting this federal initiative to improve early learning and development programs for young children, DEC asks that states be encouraged to utilize evidence-based practices that are associated with positive child and family outcomes. These practices should be at the core of services provided to children and families and should also serve as the centerpiece of professional development. In the application criteria, this would require a definition of evidence-based practices and ask states to place greater emphasis on early care and education practices throughout the criteria. DEC’s Recommended Practices initiative underscores the need for a focus on specific, evidence-based practices in order to build a strong early childhood system.

DEC is concerned about the required plan to have a kindergarten entry assessment for all children entering kindergarten by 2014-15 school year. We agree with many of our colleagues that a onetime snap-shot of a child is not an adequate way to measure a child’s knowledge and functional capabilities. It is important that teams conduct comprehensive, universally designed, and authentic assessment and ongoing monitoring of all children’s development and learning. Team members need a clear understanding of all children’s current skills and abilities to ensure access and participation, and to develop appropriate learning opportunities. The comprehensive assessment system should differentiate between child performance measures and indicators of program quality. The assessment should have established technical adequacy including evidence of validity and reliability for both the population it is used on and the purpose it is being used for. DEC fully supports the emphasis on training early childhood educators to appropriately administer assessments and interpret and use assessment data in order to guide and improve instruction, programs and services. This training is particularly important as it applies to children with disabilities and other special needs.

Thank you for the opportunity to comment.

Kristie Pretti-Frontczak PhD, President
Sarah Mulligan, Med, CAE, Executive Director
Division for Early Childhood of the Council for Exceptional Children

Thank you for your tireless efforts to secure this significant new investment in young children, and for drafting such a thoughtful and thorough set of requirements for public comment. The following points for your consideration are informed by my experience as the first Commissioner of the Massachusetts Department of Early Education and Care, and by my current work as State and Local Initiatives Coordinator in the Education Division of ICF International.

- Quality is also about access and stability.
The priorities in the Early Learning Challenge draft application are critical to establish a baseline for quality, and a framework for improvement. The same type of priorities need to exist for providing consistent, predictable access to that quality if we want to help high-need children start school ready to learn. We know that eligibility policies and mobility affect child outcomes and kindergarten readiness because of their linkage to access and stability. We also know that every state struggles with how to connect or align eligibility policies across multiple funding streams and programs. Data on CCDF placements shows that the average length of time a child spends with one program or caregiver is six months, not long enough to form lasting relationships or go through a typical curriculum. And as is well-articulated in the draft, disconnects between half-day, school-year programs and the needs of working families often put the highest quality programs out of reach for the highest need families. The data requirements articulated in the draft summary are essential to understanding more about which programs children are enrolled in and what level of quality they provide. An important addition to the performance measures would be to track what eligibility requirements are attached to being able to access those programs, how long children stay, and why they leave.

To achieve the desired outcomes of the Early Learning Challenge, states should get credit in their applications for articulating how they connect or plan to connect eligibility across multiple programs, sectors and participating State Agencies. We need to understand and improve access and stability to ensure low-income children can get into high quality programs and stay long enough to benefit. By developing shared policies, data, and communication on eligibility and enrollment, states can help reduce one of the most significant barriers to building high-quality state systems- the philosophical gap between funding streams that provide access to early education as a critical support for working families, and those that provide access as a critical early learning opportunity for children. Allowing children to stay in high quality programs when parent’s circumstances change would help close that philosophical gap.

- Very “high need” children are served by TANF and Child Welfare agencies.
The focus of the Early Learning Challenge fund on high-need children is terrific, as is the requirement for each “Participating State Agency” to join together in their efforts to serve those children. Since TANF and Child Welfare agencies serve the lowest income and most at-risk families in any state, and since they often provide funding and determine eligibility for families to enroll their children in early education and care programs, their participation is critical to the state system effort. Requiring TANF and Child Welfare administrative entities to be part of the “Participating State Agencies” would help increase the likelihood that the children they serve are enrolled in the highest quality programs. Including these agencies as full partners would also help improve continuity of access and connections to other funding streams, so the closing of a family’s TANF or Child Welfare case wouldn’t have to mean the end of a child’s enrollment in a high quality early education program.

- “Adult-adult interaction” is a key factor in state system success.
It’s great to see the Early Learning Challenge draft requirements reflect the latest research on the importance of “adult-child interaction.” In the same way, the quality of “adult-adult interaction” will be critical to each state’s system success. Just as we know that teacher qualifications and credentials are only one part of an educator’s success, anyone who’s worked in system-building efforts knows that priorities and performance measures are only one part of a state’s success in realizing dramatic improvements. The real test comes in the relationship-building and development of high levels of trust among state leaders and agency-heads, and in the work that goes into establishing a shared sense of purpose, guiding principles, an understanding and analysis of the “current state” and the desired “future state,” and an agreed-upon process for taking action and implementing change. Ongoing work at the Office of Policy Research and Evaluation on measuring collaboration should be a key part of helping states assess and build their capacity to work together toward reaching the goals of their State Plan.

Thank you for the opportunity to comment on this ambitious new effort. The Early Learning Challenge fund provides great opportunities for states to bring together the right people, data and frameworks to help more children start school ready to learn.

Ann Reale, MPA
State and Local Initiatives Coordinator
Education Division
ICF International

The successful education of young people is a topic everyone desires. The problem is that many well-intentioned people differ in the methodologies they believe necessary to achieve this goal. The American education system has a long history of multiple avenues of education: private and public, and have allowed its citizens to freely choose what they believe is best for their children. For the federal government to pressure state governments through regulations and monetary incentives to infringe on the autonomy of private and faith-based education programs within their jurisdiction is problematic. Other commentators have referenced the areas of concern in Priority 3; therefore, this author will not re-hash them. The author strongly encourages the federal government to review and revise the proposed regulatory guidelines and remove those requirements that would "force" state governments to bring private and faith-based programs under the state-operated rating and improvement system.

Michael H. Bryant, Ed.D.
Executive Director, Georgia Association of Christian Schools

July 11, 2011

The following comments are provided on behalf of the IDEA Infant & Toddler Coordinators Association (ITCA). ITCA represents state lead agencies that are responsible for implementing Part C, Infants and Toddlers with Disabilities, of the Individuals with Disabilities Education Act (IDEA) in all 50 states and other eligible jurisdictions. ITCA appreciates the opportunity to comment on the new Race to the Top – Early Learning Challenge (RTT-ELC) application package and we support the commitment of the Administration to invest $500 million to early learning from the Race to the Top funds available in FFY’11.

ITCA requests consideration of the following comments and recommendations as the application package is finalized.

ITCA recognizes and strongly supports the clear and comprehensive inclusion throughout the application of children with disabilities and the services, providers and programs that support their success in quality early learning settings within the community. For example, we note the definition of “high need children” includes children who have disabilities and developmental delays. Further, Part C and Section 619 Preschool under Part B are recognized programs under this plan; Part C lead agencies and the state agencies administering the Section 619 program under IDEA are required partners; the Part C of IDEA Interagency Coordinating Council is included in the governance structure; child find activities under IDEA are covered; organizations such as DEC state affiliates are mentioned; and finally it is clear that the requirements of IDEA must be met as a condition of a state’s participation under this program.

ITCA must take this opportunity to state clearly that adequate federal investment is essential to successful outcomes for all young children and their families. While the $500 million is a significant investment, it must be noted that existing federal, state and local resources are not adequate to ensure the needs of all children are met. The package requires states to “reallocate or repurpose” existing funds. The obvious implication is that adequate funds are available but not being spent wisely. These funds, particularly IDEA funds, have statutory requirements about their use. All funding sources mentioned are in fact underfunded and stretched beyond their limit. Therefore, ITCA recommends that states not be required to report how the state will “reallocate or repurpose” existing funds. Instead states should be asked to address how all funds will be used to support the overall goal of the effort.

ITCA supports the focus on the full early childhood age range including children birth to five years and permitting the option to extend through the early elementary grades. Consistent with this optional extended priority, the final package should be expanded to include programs, partners and funding sources applicable to the early elementary grades including Part B of IDEA.

ITCA supports the inclusion of data-based performance measures particularly related to tracking and reporting increases in the numbers of children participating in high-quality early learning and development programs. We strongly support subgroup reporting including by age group and disability status.

While ITCA strongly supports the emphasis on providing information and support to families to enhance their capacity to support their child’s development, we recommend that the final package emphasize not only what early learning systems provide “to” families but how systems partner “with” families.

ITCA notes that many infants and toddlers do not participate in group or program settings in their community. Many young children receive services in their home, a family member’s home or in a family child care setting. The application package should be reviewed and revised consistent with this reality to be sure that the home environment is appropriately addressed in this investment. This is particularly true for the existing component of a “State’s Tiered Quality Rating and Improvement System” that seems to more closely align to group or program settings.

ITCA is concerned about the statement that these funds may not be spent on “direct delivery of health services.” The package does not include a definition of health services and ITCA recommends this be reconsidered and rephrased. Developmental services could be included in the definition of health services. There may be appropriate instances in which a state allows the use of these funds for services.

Thank you for the opportunity to comment.

Kim Wedel, ITCA President and Maureen Greer, ITCA Executive Director

Whille the goals are applaudable, the mechanism is not. Speaking on behalf of the nearly 500 churches of the Virginia Assembly of Independent Baptists, I am opposed to requiring children be removed from the home at such early ages. This sets aside the critical influence and oversight that parents have over their children. Parents who desire a private education with a religious emphasis will be affected. This will be a huge overreach of the Department of Education.
Secondly, with such difficult economic times, from where will the money come? From the very parents who are opposed to such intrusion into their families.
Please do not proceed with this initiative.

Comments on Race to the Top – Early Learning Challenge Executive Summary

We strongly support the focus in the Executive Summary of the Race to the Top – Early Learning Challenge Fund description on serving and improving the opportunity for success of High-Need Children. We also appreciate the two references to “culturally appropriate services” and several mentions of addressing the particular concerns of English language learners and children with disabilities. At the same time, if states are to truly address issues of disparity as they develop their Early Learning Challenge grant applications, we believe federal guidelines must direct much more explicit and extensive attention to issues of race, language, and culture throughout the guidelines.

This starts with direction to states on how to define High-Need Children. Clearly, income is one way to make such a distinction, but a married couple in graduate school living in married student housing with an infant may have the same income as a single mother living in a one-room apartment distant from a bus line and with only a high school diploma and two children, working two minimum wage jobs to make ends meet. Particularly when it comes to issues of race, language, and culture, there are issues of “social exclusion,” some borne by institutional and structural racism, that can have devastating educational impacts upon young children, in particular as they develop their own identity and approaches to learning and life. We would recommend that the guidelines require states to define High-Need Children and how they plan to enlist and engage those children and their families and communities, with specific reference to issues of race, language, and culture and the environment in which they live.

This also extends to the guidance states receive in describing how they will demonstrate they:
• incorporate issues of race, language, and culture into early learning standards and quality rating systems and kindergarten assessments;
• include a focus on cultural and linguistic competence and reciprocity in their planning and work related to family support and engagement;
• develop teacher certification and professional development programs and strategies that equip teachers to respond in culturally responsive ways and ensure effective responses to any prejudice or bias that shows up in early childhood settings;
• create a skilled workforce that itself better represents the diversity of languages, cultures, and races within the young child population being served;
• collect and analyze all information in ways that enable them to track progress in closing gaps in these areas by race, language, and culture; and
• involve as part of all planning and decision-making groups representatives who can share the experiences of High-Need Children in terms of race, language, disability, and cultural as well as income backgrounds.

The following offer some specific places within the Executive Summary where attention to these factors could be strengthened.

Page 9: Require states to define High-Need Children in a way that references current known disparities that exist from early childhood to kindergarten entry with respect to income, race, language, culture, adult educational status, and neighborhood characteristics and conditions.
Page 10: Add under A(A)(3)(c) a new: (iii) evidence of broad support across race, language, and cultural groups and from families of children with disabilities or other special needs.
Page 11: Add under B(B)(1)(a): Detailed information regarding what constitutes “cultural appropriateness” in early learning standards and potentially referencing documents that are exemplary in incorporating such cultural standards and suggesting ways that states could develop such standards.
Page 13: Add under B(B)(5) a new: (b) Assure that standards for family engagement and support are culturally and linguistically competent and broaden understanding and appreciation for different cultural practices
Page 13: Add under C(C)(1) a new: (b) Include cultural competence and anti-bias training and proficiency as part of the definition of and measurable aspects of quality
Page 15: Add under D(D)(1) a new: (b) Set of workforce knowledge and competencies to provide appropriate responses to different High Need Children and ensure inclusion and anti-bias
Page 15 Add under D(D)(2) a new: (c) Policies and incentives to produce a race, language, and culturally diverse professional workforce, including innovative as well as traditional career pathways
Page 18: Add under Essential Data Elements definition additional language under: (e)… and Early Childhood Educator’s race and proficiency in different languages
Page 19: Add under High Need Families definition a descriptor of the science and evidence regarding the impact of social determinants of health, toxic environments, adverse childhood experiences, and social exclusion on child outcomes and definitions – and science and evidence on addressing these factors through building resiliency, fostering reciprocity, and strengthening protective factors.
Page 19: Add under High-Quality Plan Performance Measures definition a new: (i) the attention to developing a plan that is inclusive in its response to High-Need Children and ensures cultural competence and counters any biases or prejudices, by race, language, culture, or gender, even where they exist in larger society and may be reflected in the behaviors of children or their families in the early learning setting.
Page 21: Add under Workforce Knowledge and Competencies Definition: …“and strategies for working with families of different language, race, economic, and cultural backgrounds”.

We thank you for the opportunity to provide comments on this important effort to build Early Learning systems within states that ensure all children have full opportunities for healthy development and preparation for success in school.

Submission from members of the BUILD Initiative’s Equity and Diversity Working Group and Voices for America’s Children Equity and Diversity and School Readiness Advisory Groups

Charles Bruner (Child and Family Policy Center)
Eva Marie Shivers (Indigo Cultural Center)
Terrylynn Tyrell (Voices for America’s Children)
Linda Tilly (Voices for Alabama’s Children)
Cyd Oppenheimer (Connecticut Voices for Children)
Mina Hong (Michigan’s Children)

On behalf of our 2.1 million members, The Service Employees International Union (SEIU) thanks the Departments of Education and Health & Human Services for the opportunity to comment on The Race to the Top Early Learning Challenge Draft Criteria. As you finalize The Program Criteria, we urge you to prioritize the following recommendations.

Linking Professional Development to Compensation and Supports

The early care and learning workforce is among the most poorly compensated in the country and often lacks affordable health insurance, leading to serious challenges in recruiting and retaining the stable, high-quality teachers and providers that children and families need. It is widely accepted that children need stable, consistent care to grow and learn, but nationwide, more than one-third of early childhood providers leave the industry every year because of low wages and a lack of health insurance. In order to recruit and retain a well-qualified workforce, The Race to the Top Early Learning Challenge must encourage states to invest in quality improvement and workforce development for this mostly low-income workforce.

We are pleased to see that State commitment to developing A Great Early Childhood Workforce is included in the Selection Criteria for these grants and that States must set targets for improving Early Childhood retention as well as increasing the number and percentage of Early Childhood Educators moving through the progression of credentials. However, in order to achieve such targets, we believe that States must support and additionally reward Early Childhood Educators for improving their knowledge, skills, and abilities. SEIU providers believe that provider preparation is essential for high quality early care and learning services. Unlike other industries, providers who have special skills and/or seek more education and training are rarely compensated appropriately. Supports for education, training, and technical assistance are important aspects of quality improvement. But this will not be enough to retain this very low income workforce in the field once they have completed training and/ or education programs.

In Priority 2 and Sections (C)(2), (C)(3) and (D)(2), we urge you to ask States in their applications to articulate both policies for supports (e.g. training, technical assistance, scholarships) and policies which would reward and retain Educators who have improved their knowledge, skills, and abilities (e.g. tiered reimbursement, higher subsidy reimbursement rates, improved compensation, and/or other financial rewards and incentives).

We support the inclusion of Tiered Quality Rating and Improvement Systems as a priority and are pleased that states will be required to demonstrate that they are supporting programs to improve quality. However, we believe that financial incentives are a vital element for a successful Tiered Quality Rating and Improvement System and should be independently emphasized and evaluated in Early Learning Challenge applications, distinct from the category of provider supports (e.g. training and technical assistance). Financial incentives that accurately reflect the true costs of high-quality care are crucial for encouraging broad and sustained participation in a State’s Tiered Quality Rating and Improvement Systems and for raising the quality of care across the board. Without adequate financial incentives, Tiered Quality Rating and Improvement Systems could exacerbate existing disparities between programs, because only well-resourced programs would be able to reach and maintain the highest levels of quality in such a system.

We urge you to amend the definition of “Tiered Quality Rating and Improvement System” to include financial incentives as a fifth required component—separate from program supports. This is consistent with the National Child Care Information and Technical Assistance Center’s definition. States should be also be required to specify how they will provide adequate financial incentives to programs as they address the priorities and selection criteria; this should be a component of the scoring rubric.

Improving Quality in Existing Early Childhood Programs in All Settings

We believe that The Race to the Top Early Learning Challenge should strengthen and improve existing services for all age groups in all types of programs, including family, friend and neighbor care, rather than primarily shifting children from their current settings into programs that have already achieved high quality. Family, Friend, and Neighbor care is the child care arrangement of choice for many parents, and frequently the only option for families working non-standard hours. These caregivers tend to care for our most high need children. If States wish to increase the quality of care and improve child outcomes for all high-need children, these providers cannot be ignored. Child Care and Development Fund (CCDF) regulations “promote parental choice to empower working parents to make their own decisions on child care that best suits that family’s need” (CCDF, §98.1(a)(2) and §98.30(a)). Efforts to improve quality should not cause the unintended consequence of limiting Family Friend, and Neighbor families’ access to their provider of choice.

We urge you to include specific language encouraging states to design incentive-based quality improvement initiatives which include and support family, friend, and neighbor caregivers. Quality improvement initiatives that are designed to fit the needs and interests of Family, Friend, and Neighbor caregivers can increase the quality of care in exempt settings and can create a pathway to licensing. A State’s past investment in and future plans for quality improvement initiatives in license-exempt settings should be taken into consideration in evaluations of State applications.

Race to the Top Early Learning Challenge Scoring Application and Competition

We believe that the creation of collective negotiation rights for the early childhood workforce is consistent with and has been proven to further the goals of federal child care programs to create high quality affordable and accessible childhood programs. Parallel to original Race to the Top grants, we recommend that scoring rubric should evaluate provider voice and participation in early childhood policy-making. We urge you to include local union affiliates which represent Early Childhood Educators in the definition of Early Learning Intermediary Organization on page 18. In the alternative, letters or actions of support from local union affiliates which represent Early Childhood Educators should be given equal weight as compared to letters of intent or actions of support from Early Learning Intermediary Organizations.