Absolute priorities describe items that a State must address in its application in order to receive an award. States do not write directly to the absolute priorities; instead, reviewers determine if the priorities are met after evaluating a State's response to all of the Selection Criteria. We consider for funding only applications that meet the absolute priorities. A competitive preference priority describes an area of particular interest for which an applicant may earn additional points. States may respond to the competitive preference priority throughout their application, as appropriate, as well as through a summary of the State's approach to addressing the priority. This priority is evaluated in the context of the State's entire application. Invitational priorities signal areas the Department is particularly interested in; applicants may choose to address one or both invitational priorities. Applicants who meet an invitational priority do not earn extra points and are not given preference over other applications.


A commitment to expanding quality early learning education programs to poor, disadvantaged or underserved children and communities, including rural or isolated communities, should be a competitive preference priority. This priority would give an advantage to states that demonstrate a commitment to strategies or innovations that benefit poor, disadvantaged or underserved children, such as investments in Early Head Start, Head Start, high-quality prekindergarten programs, expanded childcare assistance, free public full-day prekindergarten, and, in general, greater availability of full-day, full-year programs for working and poor families.

Mandatory half-day or full-day kindergarten attendance should be an invitational preference priority. Currently, some states do not require children to attend kindergarten or even that school districts offer kindergarten. Other states require children to attend half-day kindergarten; a few states require children to attend full-day kindergarten. We believe that states with some form of mandatory kindergarten are in the best position to take advantage of early childhood education funding designed to improve pathways to kindergarten. The NEA supports federal efforts to foster mandatory full-day kindergarten attendance for all children; the designation of at least half-day mandatory kindergarten attendance as an invitational priority would signal to states the importance of public kindergarten for all children.

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

The RTT-ELC properly focuses on building comprehensive, birth-to-five early learning systems, and the proposed absolute and competitive priorities properly place significant emphasis on the importance of high-quality early learning standards, assessments, and quality rating systems. However, the elements included as invitational priorities will also play an important role in successful state plans, and we feel their importance is currently understated and could be given more prominence, including moving them to competitive priorities.

For example, with regard to Priority 4, Sustaining Program Effects in Early Elementary Grades: integrating with K-12 education (particularly K-3) in the RTT-ELC effort is not just vital to sustainability in early grades, but also to the planning and execution of birth-to-five reforms. The draft provides some important steps to integrate birth-to-five early learning with K-12 education, particularly in the standards context. We offer additional options, which are not mutually exclusive. One option is make this invitational priority into a competitive priority, maintaining the Challenge’s core focus on birth-to-five but assigning extra points for tighter integration with K-3. A second option is to incorporate elements of the current draft invitational priority (such as enhancing K-3 standards and ensuring transition planning) into the selection criteria (such as (B)(1) and (B)(3), respectively). A third option is to more clearly address the integration of key K-12 stakeholders into the RTT-ELC planning and implementation process, which could be done in (A)(3)(c).

Thank you for the opportunity to comment on the Race to the Top – Early Learning Challenge (ELC). As a statewide parent-led, parent-staffed, family-serving organization, SPAN understands that this is a tremendous opportunity for states to improve the quality and continuity of education for young children and their families. Sadly, while there are many positive aspects of the proposed priorities, the MOST IMPORTANT priority is missing - the priority related to engaging families from the beginning at all levels in the early childhood enhancement system. SPAN agrees that state birth-to-five systems must become better organized and of higer quality; in addition, there must be more strategic linkages between and aligning of birth-to-five systems and K-2/3 programs, both in terms of direct services to young children and in terms of partnering with their families. The most effective way to do this is to involve informed families in the process of developing and strengthening these linkages and alignment. Specific comments follow:

Governance, Funding, and Data Efforts
• Regardless of which agency a governor designates to manage a state’s ELC effort, both the state Early Childhood Advisory Council and Department of Education (including special education, Title I, and bilingual divisions/programs) must be involved in planning and support of the planned activities, to encourage appropriate connections with state efforts to improve K-3 education. If the state’s early childhood advisory council does not include parents of young children and/or representatives from parent-led organizations that support parents of young children, the US DOE must require involvement of parents and/or representatives of parent organizations in planning and support of planned activities.
• Reward states that include the FULL RANGE of stakeholders, including not only school district superintendents, school board members, elementary school principals, and K-3 teachers, but also parent leaders (such as parents from PTAs, District and school Title I parent groups, and District and school special education parent groups), and other leadership from K-12 education as key partners in their ELC planning.
• Reward states whose plans involve school districts that currently invest (or have plans to invest) Title I dollars in early learning programs, particularly districts that have strong collaboration with parent leaders and opportunities for meaningful parent involvement at all levels.
• If states plan to use ELC resources to improve the quality and use of data, require states to link early childhood data (e.g., data on young children; early learning programs and program quality; and the early childhood workforce) with longitudinal state education data systems, and reward states the engage families in discussions and decisions about what is important early childhood data that the systems should collect, analyze, and report on - and how to report on the data in ways that are meaningful to stakeholders, including praents.
Standards, Assessments, and Program Improvement
• Reward states for aligning their early learning and K-3 standards, including standards for parent involvement at all levels; encourage states to set research-based expectations for children of all ages in all key areas of child development including cognitive (literacy/communications, mathematics, science, and social studies), social, emotional, and physical development and to implement effective strategies to ensure that parents are aware of these expectations and how they can be partners with their children’s educators in enhancing their children’s development. Do not reward states that focus on "drill and kill," developmentally inappropriate standards or assessments in the early years!
• As states improve the use of child assessments to improve teaching and learning and report on the overall status of young children, birth to age 5, encourage collaboration with related state efforts to assess children in K-3 classrooms and implementation of strategies to engage parents of young children in understanding assessments and their implications.
• Reward states that build partnerships between early learning and K-3 teachers and administrators and parents of young children as well as parent-led organizations to review and make joint plans to act on the implications of data.
• As states develop tools and systems for assessing and improving program quality, reward states that work with parents and parent-led organizations to develop quality rating and improvement systems, share information from quality rating and improvement systems with elementary schools, school districts, families and family organizations, and that extend the use of research-based tools for assessing the quality of instruction, teacher-child and teacher-parent interactions, and learning environments into K-3 classrooms.
Professional Development
• Reward states that create systems of professional development that include and engage administrators, teachers and parents from both the early learning system (e.g., program directors, child care and home visiting staff, pre-k teachers, community providers) and K-12 systems (e.g., elementary school principals, K-3 teachers).
• Reward states that show a commitment to improving their teacher preparation programs and licensure structures to ensure that teachers not only in pre-k but also in kindergarten and the early grades are well prepared to teach young children and to partner effectively with parents and parent-led organizations at all levels, from the individual child and family level through program and system decision-making.
• Require states to commit to engaging families in the life of early childhood programs and schools at all levels, from the individual child and family level through program and system decision-making, including the use of transition and ongoing programs that help families be active partners with their local elementary schools.

I will here build on my comments in response to the opening section of this draft statement of “requirements” and address priorities 1-4 here, rather one at a time.

RE: Priority 1.

In addition to the quality of any assessment(s) a state employs (which I address in my response to the Department’s opening comments), the uses of the results are vitally important. There is a peculiar looking-backward to the proposal: that assessments given in kindergarten entry are to be used to improve a vast array of early children services and programs. While good assessments can tell a lot about a child’s current situation, they cannot say much about the actual trajectory that led a child to her/his current status on any of the multiple dimensions of interest. For example: A child who does not score high may have been in an excellent program but have very poor home circumstances; or have a healthy home environment but have been in an overly academic program that stunts personal and social development, or a program that does little to establish development appropriate pre-requisites for more formal academic learning.

That is, the presumed capacity of the assessment to enable a proper parsing out of contributing factors to any individual or in general is likely a false presumption. The danger is that in assuming the assessment can do these things, sanctions are likely to ensue, in the guise of “accountability,” or “improvements” are likely to be undertaken that are not supported by adequately comprehensive and sophisticated evidence. Such sanctions or “improvements” are likely to be administered inaccurately, and the consequences are likely to be disastrous as, in response, programs attempt to “beat the test” at the expense of the quality of the program. If the evidence does show widespread weaknesses in some areas of development or among some populations, then attention could be paid, but the attention must first include studies to determine causation. No assessment by itself is likely to provide sufficient information to ensure healthy program changes.

RE: Priority 2

Here our concern is that assessment evidence will become too much of the evidence of program success while consideration of other factors will be minimized. Per my comment to Priority 1, a good program serving especially needy children could be determined to be a poor program, and vice versa. The same problem pervades NCLB.

It is certainly possible to gather information in appropriate ways to track each child’s learning and development across the spectrum, but that seems beyond the scope of what this RTTT program will support. (Work Sampling System, for example, can track children from ages 3 – 8, if the center/program/school uses it; this is different from using a one-time version to assess kindergarten readiness.)

Improving program quality is necessary, but assessment and evaluation can be dangerous tools: they can lead to damage in the guise of “improvement.” Thus, any tiered system that is approved must ensure the ratings are based on a balanced assessment and evaluation system, and that unwarranted conclusions from assessments of students are not used to unfairly rate programs.

RE: Priority 3:

The capacity to evaluate all programs will require significant resources, though it is a valuable goal. The dangers will be that in the absence of adequate resources or a misplaced confidence in limited instruments, policymakers employ formulaic evaluation tools that produce both frequent mis-identification and efforts by programs to “beat the evaluation” by gaming the evaluation tool, much as teaching to the test has clearly produced inflated state test scores (c.f., esp., the work of Daniel Koretz on this point.)
I do not see an indication that there are any means or procedures by the Department to forestall these dangers.

RE: Priority 4:

Determining whether programs have lasting positive effects makes great sense. However, as one other commenter said, what really needs to change is the larger K-12 system which has been greatly reduced to test preparation programs focused on narrowly constructed measures in reading and math. The danger is that the academic or pre-academic components will become one-sidedly emphasized to “prepare” students for the forthcoming high-stakes standardized tests. A great deal of evidence exists regarding the push-down of inappropriate instructional practices to lower and lower grades. This raises the risk that rather than developmentally appropriate, full-spectrum assessments of older children resulting from this effort, younger children will become subject to inappropriate instructional practices, as too many already are.

Therefore, to determine the comprehensive effects of early childhood programs into elementary schooling will require a similarly comprehensive evaluation of children’s overall development in elementary school. This, practically, runs counter to the one-sided emphasis on two academic subjects imposed by ESEA/NCLB. Unless the emphasis in ESEA/NCLB changes, then the clear danger is that the only program effects considered will be on the two academic subjects. Over time, in turn, that is likely to induce a misguided and imbalanced over-emphasis on preparation for those two subjects. Selection Criterion B.1.b. (linking to academic standards in “early literacy and mathematics”) is likely to reinforce this potentially dangerous development.

Monty Neill, Ed.D.
Executive Director
National Center for Fair & Open Testing (FairTest)
Boston, MA

Hopefully states that have some comprehensive services planned for supporting infants, toddlers and their families will be considered a high priority. We know from the research that if this age group receives quality care the benefits are enormous. This is our country's first, real opportunity to make a our youngest citizens a priority.

From the rationale for the early childhood challenge and from the daily challenges in delivering great early childhood learning it seems that one area that needs to be included directly the priorities is the role that human capital (for childcare, for teachers, for directors of programs and centers) plays in ensuring an excellent learning environment for children. While the policy changes are necessary they, on their own, seem unlikely to be sufficient and deliver a better outcome. States need to be pushed to include great people directly and via providers and other organizations if we are going to achieve these important objectives.

What are the priorities criteria for Tribes? Tribes have the highest poverty rates in the Nation and should be given special interest by the Department.