B. District Capacity and Success Factors

Reform Conditions.
The extent to which each LEA has demonstrated evidence of—

  1. A clear track record of success in the past four years in advancing excellence and equity, including a demonstrated ability to—

    1. Improve student outcomes and close achievement gaps (as defined in this document), including by raising student achievement, high school graduations rates, and college-going rates;
    2. Achieve ambitious and significant reforms via implementation of one or more of the four intervention models (as defined in this document) in its persistently lowest-achieving (PLA) (as defined in this document) or low-performing schools (as defined in this document); and
    3. Make student performance data (as defined in this document) available to students, educators, and parents and use it to inform and improve instruction and services.

  2. Increased "transparency" in LEA processes, practices, and investments, including making public, by school, actual school-level expenditures that are associated with regular K-12 instruction, instructional support, pupil support, and school administration. At a minimum, LEAs must report the following four categories of school-level expenditures from State and local funds:

    1. Actual personnel salaries at the school level for all school-level instructional and support staff, based on the Census Bureau's classification used in the F-33 survey of local government finances;
    2. Actual personnel salaries at the school level for instructional staff only;
    3. Actual personnel salaries at the school level for teachers only; and
    4. Actual non-personnel expenditures at the school level (if available).

  3. Meaningful stakeholder engagement and support, including:

    1. A description of how families, teachers, and principals in participating schools (as defined in this document) have been engaged in the development of the proposal and, as appropriate, how the proposal has been revised based on their engagement and feedback; including,
      1. For teachers in LEAs with collective bargaining representation, evidence of direct engagement and support for the proposals from teachers in participating schools (as defined in this document); or
      2. For teachers in LEAs without collective bargaining representation, at a minimum, evidence that at least 70 percent of teachers from participating schools (as defined in this document) support the proposal.
    2. Letters of support from such key stakeholders as parents and parent organizations, student organizations, early learning programs, the business community, civil rights organizations, advocacy groups, local civic and community-based organizations, and/or institutions of higher education (IHEs).

  4. A high- quality plan for:
    Developing LEA capacity and supporting school-level implementation of the applicant's proposal, including a description of—

    1. The LEA's approach (e.g., schools, grade bands, or subject areas) to implementing the reform proposal in the LEA(s), including
      1. a list of the schools that will participate in grant activities, or a description of the selection process that the LEA will use to select schools to participate to ensure that at least 40 percent of the participating students in the participating schools must be, on average, from low-income families; and
      2. the number of total participating students, participating high-needs students (as defined in this document) and participating educators.
    2. How the LEA central office, or the consortium governance structure (as defined in this document), will be organized to support and provide services to all participating schools;
    3. The State context(s) in which the LEA or consortium will be lawfully implementing the proposal, including a description of how the State affords participating LEAs and schools sufficient autonomy to implement the personalized learning environment(s) called for in the application; and
    4. How the implementation plan will translate into meaningful reform and support district-wide change beyond participating schools, and help the LEA reach its improvement goals (e.g., the applicant's logic model or theory of change of how this approach will improve student outcomes across all schools in the LEA).

Comments

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My comment addresses the following RTTT-D criteria 3. ii.

Meaningful stakeholder engagement and support, including:

You write - "For teachers in LEAs without collective bargaining representation, at a minimum, evidence that at least 70 percent of teachers from participating schools (as defined in this document) support the proposal. "

A significant component of this grant is addressing teacher culture. It rightly implies that teacher culture needs improving. It is therefore my belief that a 70 percent of teacher agreement is unrealistic. I recommend and make request that a simple majority is a more realistic choice for the set of students/teachers to be served by this grant (40% free/reduced lunch). Thank you for the opportunity to offer recommendations!

It is critical that parents of students with disabilities be involved and encouraged to provide meaningful engagement and support. Therefore, the National Center for Learning Disabilities requests that the Department include a specific requirement regarding involvement of parents of students with disabilities, organizations representing parents and students with disabilities, and the state’s Parent Training and Information Center.

Comprehensive System of Support: There is too little attention to districts providing a comprehensive system of support so that students receive timely, differentiated support based on their learning needs. The CCSSO Innovation Lab Network calls for a comprehensive system of support (academic, health and social-emotional). The definition of competency education calls for timely and differentiated supports.

Without a comprehensive system of supports, personalized learning can results in some students falling behind, off-track and out of school. These supports need to be organized and ready to be allocated -- not something that is left to the last minute or to fall on teachers' shoulders.

Although not defined in this document, we can only infer that the "four intervention models" stated in Section 1.b are the turnaround, restart, transformation and school closure models required under the original RTTT state-funded program. The requirement that LEAs have a four-year track record of success implementing one or more of these models decidedly skews the competition in favor of LEAs from states that have received RTTT funding, even though ED expressly states that there will be no competitive preference, one way or the other, among LEAs from RTTT and non-RTTT states. Also, this requirement limits competition to LEAs that serve persistently lowest achieving schools, by federal definition, rather than the broader span of LEAs that would otherwise be eligible based on enrollment and poverty measures. And finally, this requirement is inconsistent with the RTTT-District's goal of innovation and creativity in the development of personalized learning environments by narrowly prescribing the structure in which these environments are implemented. We urge the US Department of Education to remove this requirement from the RTTT-District selection critera.

Don't see a definition of the "four intervention models (as defined in this document)"; can we assume it is the "turnaround strategies" used for SIG?

Must hold schools accountable for working out of the box with parents to enhance students success in the indicated areas. Again can't be accomplished without parent and the community stakeholders outside of the school system