Eligibility Criteria

I support the notion of requiring the commitment to implement evaluation systems for all levels of the organization. I also support the definitions of the evaluation systems and their emphasis on 360-degree analysis of everyone's performance. The use of surveys will be very beneficial.

In regards to “Eligible Applicants”—to ensure meaningful participation of partner organizations and to help facilitate the successful implementation of grants—eligible applicants should include high-quality, non-profit organizations, which have demonstrated success in improving student achievement, in partnership with an LEA or consortia of LEAs. Currently, nonprofit and community-based organizations are utilizing evidence-based practices to partner with schools and districts to improve student outcomes. Nonprofit partners are delivering vital educational supports, such as, targeted and school-wide research-based interventions in literacy, math, attendance and behavior shown to increase student achievement and are providing thousands of hours of additional learning time to millions of students. However, these high-quality organizations are only able to reach a fraction of the students whose lives would be transformed by the individualized attention and support nonprofit partners are able to provide. In high-poverty schools, the majority of students often require intensive support that schools do not have the capacity to provide, creating a gap between the attention students require and the services schools can provide. This grant, however, provides an opportunity for LEAs and nonprofit applicants to scale and sustain partnership designed to improve student achievement and teacher effectiveness.

Eligible applicants should be required to obtain approval (signatures) from non-profit organizations that are participating in the grants as well as from those already required under the proposed criteria (superintendent/CEO, local school board, and local union/association president) to ensure buy-in from all key stakeholders at the outset, increasing the likelihood of a strong partnership and overall success.

Furthermore, regarding assurances, we urge the Department to give as much weight to actual district educational results as to the level of compliance with the assurances. We agree with the idea of requiring districts to put in place the four assurances as a way to foster future reform. But the assurances are just a means to an end, not the end itself. Therefore, we urge support for districts that for the most part establish assurances, and have a very strong record of student achievement; while we would look with skepticism at a district that claims a perfect record on the assurances but also has a high drop-out rate and low proficiency on the NAEP.

Race to the Top funds should be contingent upon the LEA(s) having earned a “Meets Requirements” rating from their State on its latest Annual Performance Report for implementation of IDEA. The criteria used to determine a LEA’s performance is limited to a handful of compliance indicators of the State Performance Plan. Thus, LEAs not able to obtain the level of “meets requirements” should not be considered as eligible to apply for Race to the Top funds. Since one of the primary goals of the Race to the Top grant program is to improve the achievement and graduation rate of all subgroups of students, including students with disabilities, those LEAs not currently able to meet the most basic compliance requirements of IDEA should not be eligible to apply for and receive funds under the Race to the Top District Competition.the National Center for Learning Disabilities requests that a rating of “Meets Requirements” on the LEA’s latest Annual Performance Report of the State Performance Plan be added as an eligibility requirement.

The Children’s Defense Fund (CDF) appreciates the opportunity to respond to the Race to the Top (RTT) draft language for the application for competitive grant funding. CDF welcomes the RTT’s focus on improving the lowest-achieving schools and addressing the needs of children in areas of concentrated poverty. A full-day experience in kindergarten is one of the most critical components of the research-based Pre-K-3rd grade early childhood learning continuum that is critical to later school achievement. Full-day Kindergarten (“Full-Day K”) plays a vital role in children’s educational development, boosting cognitive learning, creative problem-solving and social competence, and promoting positive school outcomes such as faster gains on literacy and language measures, better attendance through the primary grades, and higher academic achievement in later grades. When offered in the context of an aligned, seamless continuum of early learning, Full-Day K is a critical strategy for closing the third grade achievement gap that leaves so many children, particularly Black and Latino children, behind and likely to fail in later grades. Yet too many children are not afforded an opportunity to attend kindergarten for a full school day.

The Early Childhood Longitudinal Study-Kindergarten (ECLS-K) Class of 1989-99 has provided a wealth of data which has been studied over the years. This rich data source, in addition to school-district-based studies, has shown that children who participated in Full-Day K programs when compared to their peers in half-day programs made statistically significant gains in early reading skills. Half-day programs offer as little as 2.5 hours of instruction per day, while full-day kindergarten offers 5 or more hours of instruction per day. Providing only a half day of kindergarten instruction compromises quality early childhood instructional practice and curriculum offerings.

CDF strongly recommends the Department use the RTT to help address inequities in achievement by requiring LEAs to demonstrate their commitment to ensuring children have access to Full-Day K. CDF feels that if Full-Day K is not required for participation in the RTT family of competitive grant opportunities, a critical tool in improving student outcomes will be lost and the intent of RTT compromised.

Specifically, CDF recommends the addition of a new “4(d)” to the Eligibility Criteria to read as follows: (4)(d) The LEA provides all eligible children with equal access to free and publicly-supported full-day kindergarten that is the same length of instructional time as first grade at no cost to the parent(s)/family, or has designed and is committed to implement a plan to provide full-day kindergarten that is the same length of instructional time as first grade at no cost to the parent(s)/family no later than the 2014-15 school year.

The new RTT-D grant provides school districts and important opportunity to engage parents and the community in a discussion about student personalized learning and district accountability.  This important opportunity must build upon the work of State legislatures and community members to empower parents. The process must not undermine, obscure or complicate State Parent Empowerment laws and regulations. To avoid any possible confusion, whether intentional or otherwise, the RTT-D’s “Eligibility Criteria” should require a written assurance, signed by the LEA's authorized legal representative, that the applicant’s program will be carried out in compliance with Parental Engagement State law and regulations.

In order to strengthen RTT to be more inclusive especially those students that are over-age and undercredited, in foster care, juvenile justice or other marginalized students:

After secondary schools, insert “alternative schools and disciplinary school serving over-age and under-credited students”

On behalf of the American Public Human Services Association (APHSA), we are submitting comments on the Race to the Top District (RTT–D) Competition. APHSA is a nonprofit, bipartisan organization representing state and local human service professionals for more than 80 years. APHSA brings the states’ perspective to Congress and the Administration on issues facing the nation’s low-income children and families. Thank you for the opportunity to submit comments on the RTT-D draft criteria.

We are encouraged that the RTT-D would incentivize local education agencies (LEAs) to create bold and comprehensive reforms for students enrolled in elementary and secondary education. The RTT-D would move LEAs beyond the “one-size-fits-all” approach and encourage the use of personalized instruction in schools to improve students’ success based on their individual needs. A critical goal of the RTT-D is to improve teacher quality and encourage collaborative and data-informed strategies, developing a pipeline for students to graduate from college and be career ready. However, to ensure that children are ready for elementary school and beyond, there must be a required early learning component involved in this competition.

The RTT-D draft version of the program’s design encourages but does not require an early learning component. We urge you to include collaboration among early childhood and elementary and secondary education as a criterion for this competition. Such coordination will foster alignment of early learning standards with Pre-K through elementary and secondary education. All children should receive access to high-quality early care and education. Research shows that making early learning investments in children in their early years contributes to their academic success and school readiness. Young children have a wide range of needs and require support and quality early care and education to prepare them for high standards of learning when they enter elementary school. We also know through research that high-quality care and education has a direct return on investment. Not only does it play a critical role in alleviating the economic burden on our country, it also develops human capital—cultivating academic and life skills necessary for children’s success in school and later in life as adults.

Ensuring children’s school readiness is a critical component of the sustained well-being of children and youth outcome area within Pathways: The Opportunities Ahead for Human Services, our members’ recently released policy agenda. Pathways has been developed in coordination with cabinet-level commissioners and health and human service agencies, along with administrators and program directors in states and counties across the country. It presents our vision and overarching action framework for national policymakers and contains a set of detailed policy recommendations for health and human services. Pathways calls for innovation, transformation, and integration at the state and local levels. It also highlights the outcomes we seek. Details are available at www.aphsa.org/policv/pathways.asp

We urge you to include an early learning component as a requirement within the RTT-D competition. We hope to partner with you on these efforts.

Historically, funding has overwhelmingly been allocated to urban districts as tied to failing schools, missing the reality that students in a variety of geographic settings are failing and not solely or simply education bureaucracies themselves. Allowing districts in rural and small-urban settings, where failing students from large urban districts are moving in large numbers, to compete and receive funding before failure is institutionally absolute is perhaps the most encouraging aspect of RTT-D as currently drafted. As the number of students living in poverty significantly increases in rural and small urban districts, so too do racially disproportionate academic proficiency gaps. Whether or not RTT-D funding will indeed be allocated to a diverse geographic mix of districts will be watched very carefully.

Regarding the proposed Eligibility criteria that requires applicants to demonstrate a track record of commitment to the 4 core education assurance areas from RTTT including that--
a. “The LEA has, at a minimum, designed and committed to implement no later than the 2014-15 school year--
i. a teacher evaluation system (as defined in this document); a principal evaluation system (as defined in this document); a LEA superintendent evaluation (as defined in this document); and
a LEA school board evaluation (as defined in this document).”;

These requirements for the teacher evaluation system are highly objectionable.

The proposed definition of Teacher evaluation system contains the requirement that it includes as a significant factor data on student growth (as defined in this document) and that it will be used to inform personnel decisions.
“Student growth” is defined as “The change in student achievement for an individual student between two or more points in time, defined as—
1. For grades and subjects in which assessments are required under ESEA section 1111(b)(3): (1) a student's score on such assessments and (2) other measures of student learning, such as those described in the second bullet, provided they are rigorous and comparable across schools within an LEA.
For grades and subjects in which assessments are not required under ESEA section 1111(b)(3): alternative measures of student learning and performance, such as student results on pre-tests, end-of-course tests, and objective performance-based assessments; performance against student learning objectives; student performance on English language proficiency assessments; and other measures of student achievement that are rigorous and comparable across schools within an LEA.

The requirement that teacher evaluation systems includes as a significant factor data on student growth on state standardized tests (in addition to other measures of student learning, which are effectively precluded by virtue of the requirement that they be rigorous and comparable across schools) and that they be used to inform personnel decisions not only results in an increased emphasis on high stakes testing, but is inappropriate and unsupported by the bulk of research related to this topic. See Evidence about the use of test scores to evaluate teachers, http://epi.3cdn.net/724cd9a1eb91c40ff0_hwm6iij90.pdf; Evaluating Value-Added Models for Teacher Accountability, 2004, Rand Corporation http://www.rand.org/pubs/monographs/2004/RAND_MG1S8.pdf; Using Student Progress to Evaluate Teachers: A Primer on Value-Added Models, Educational Testing Service, Sept. 2005 http://www.ets.org/Media/Research/pdf/PICVAM.pdf

Finally, the prescriptive requirement that evaluation systems be used to inform personnel decisions represents a significant federal intrusion into dictating employment practices, an area traditionally within the province of states and its political subdivisions.

Regarding the signature requirements in Eligibility criteria, the proposal states that the Required Signatures for the LEA or lead LEA in a consortium are the Superintendent/CEO, local school board, and local union/association president (where applicable). Clarification is needed regarding what the requirement is when there is more than one teacher group in operation in a given school district.

A quick note with further input to come. As superintendent of a very small school district or 750 students I support the 2500 student enrollment requirement. This will require that small districts join together in a consortia which in fact will be beneficial in that only such a consortia will have the needed resources to adequately manage and implement this scope of a change project. It will also increase the effective benefit by reducing duplication of the administrative tasks involved with reporting and program evaluation. While I know this will require many small districts to move out of their comfort zone and into greater collaborative mode sacrificing some local control it will in so doing help those very districts stretch beyond the limits of themselves.
Ken

I think the requirement for a minimum of 2500 participating students should be eliminated. This requirement would prevent many rural schools from participating in this program. We need to make sure that we are creating programs that can reach all students and provide all students with an opportunity to grow, and progress in their academics.

I applaud your criteria--------limiting the competition to schools with over a 40% poverty rate. I work with schools that have 80%-100% poverty rate and they have so few resources. Most are in towns with a limited tax base for the suppport of schools and community resources for children and families.

Good morning,

Thank you taking comments. There are two comments I would like to add:

1. The requirements of a minimum 40% free and reduced lunch number really blocks out a lot of schools who are wanting to do innovative work with kids. In truth, most districts have lost significant funds over the past several years and we are ALL reducing staff and cutting programs. The dollars should not be limited to schools that have at least 40% free & reduced. We are in the 30s and have plenty of kids who are disadvantaged and at-risk. Please advocate for them.

2. The requirement of at least 2,500 students in an LEA leaves out many smaller districts like us, who's efforts at substantial reform are hampered only by the lack of funds for professional development. It would benefit the ED to have exemplary school models for small, medium sized, and larger districts. We could be that small district. Also, smaller districts are easier to change than larger districts. The return on investment will be much sooner. Turning a small speed boat in a different direction is much easier and happens more rapidly than turning a cruise ship.

The eligibility criteria limits potential Race to the Top for school district grantees to Local Education Agencies or a consortia of LEAs. We propose expanding the eligibility criteria to include not-for-profit organizations that are filing applications on behalf of an LEA or consortia of LEAs.

If the Department is interested in bringing together reform capacity and innovation, it would be wise to allow not-for-profit organizations to play a lead role in this effort. Other Department programs that invest in innovative reform programs at the local level recognized the opportunity that not-for-profit organizations present and made them eligible under the program. In addition, the Department is seeking a "track record" of reform accomplishments and a capacity to sustain innovative programs three years after full implementation. Not-for-profit organizations will often bring both "track record" and technical assistance to the equation even when the political dynamics for reform hadn't previously existed. So, when partnered with new and forward-looking district leadership, a not-for-profit organization will bring the experience and track record necessary to build relationships necessary for success.

Not-for-profits can play a particularly critical role when a program encompasses a consortia of LEAs rather than just one. In this instance, the not-for-profit can provide effective project leadership across multiple jurisdictions to ensure effective communication during implementation.

Around the country, not-for-profit organizations are agents of change in partnership with local leadership focused on improving student achievement. We understand how not-for-profits may not have had the capacity to deliver on reform plans on the statewide Race to the Top program. In the case of school districts - and consortia of districts - they are well positioned to deliver results. We hope you will consider expanding the eligibility criteria to include them.

Are county offices which serve constituent districts and also directly serve court, community, severely handicapped students, and pregnant teens eligible for RTT-D?

If you would consider lowering the enrollment numbers, this could allow districts that weren't able to get involved with RTT in the first go around to be involved through this opportunity. We are changing our evaluation systems for prinicipals and teachers to be half data based, it would be good to have superintendents and school boards held to the same data criteria. This would have everyone feel the same pressure to improve student achievement across all facets of the district.

As an ealier post rad, I too an once again confused as to why small school are continually left out from the funding. Proportionate dollar amounts could be set for a vrariety of school populations. Please consider size as further resources become available.

The requirement for 2,500 students makes it difficult for rural districts, which often have fewer resources and help, to get funding.

It would be helpful to have the 2500 student limitation eliminated. Our district wouldl ike to participate but has only 1500 students.

Attention is needed to develop guidance that involves the community and local nonprofits in attacking the issues we face in education. The people of the community are ever more watchful of the expenses of public education. We need enlist more community people and groups that are on the front lines who are productive, resilient, creative, and versatile enough with community, culture and pedagogy to find solutions to the many challenges we face in public eduction.

Unfortunately, community groups and nonprofits are closed out of the process by outside consultants and other entities that don't understand the history of the community or the people - rehashed models that don't fit even in high performing settings. Under a watchful eye, we see reformers buldozing their way to the front of the line without any accountability to students, teachers, parents, community.

All communities and neighborhoods want high-quality education, teaching and other services that lead to student achievement, school success and a rewarding teacher career. Let’s enlist local nonprofits and the community who are dealing with the ills of education first hand!

As is typically the case, the money will go to the large school systems. States like Nebraska that have as many or more students attending small rural schools than metro schools, are again left out. If the federal government is going to offer funds to improving education, why is it not something that all schools can apply for? Why discriminate against those schools who serve populations less than 2,500? The community of Ravenna, Nebraska has a population that is less than 1,500. The district educates approximately 450 students. The education of our students is just as important as the education of those in districts of 2.500. It is a pity that in this country, the "bigs" continue to receive the financial support and the small rural schools are ignored. Our school would love to have the opportunity to receive financial assistance. it is equally as hard for us to afford to educate our students as it is for schools in metro areas. When the federal and state governments realize this, perhaps then there will be positive change.

School systems leave out the community and parents in the evaluation process. If we truly want success, expecially in dealing with low income families and academic failure, a measurement must include:
A parent/family evaluation component.

Time after time large school systems leave out the community grassroot programs that interact with families, youth, and children with immeasurable success. School systems look out for themselves and keep all monies among them. Again instead of reaching out to the real community. Even though the small CBO are registered as a vendor.

Disappointed that have to be over 40% f/r lunch to participate. In smallish districts it is hard to put the energy into this without involving all schools/staff. With that said, we have some schools at 60-80% f/r rates, and some at 20%. Overall, only about 15 to 20% of our kids are making it - if a district like ours can't make those kiddos succeed, who can? I would vote for eliminating that criteria, and award districts based on their plan/goal to close the gap because even low poverty districts have a gap...

Because the posted draft did not spell out the evaluation criteria/process for superintendents and school board memebers, it is difficult to evaluate how this requirement will be addressed in those districts that have elected officials. Only the state can remove an elected official and then only for specific actions that violate the law. An unsatisfactory evaluation, based on non-state imposed rules, would have little impact other than to serve as a performance guide for improvement.

Requiring all participating LEAs to have at least 40% of their served population qualify for free and reduced will limit your participants to a very specific type of school district. Although I have a few schools in our district that meet this qualification, we will probably choose to not participate if all schools will not be included. I believe that leaving districts such as ours out of your pool will limit your intake of truly innovative program designs. High poverty, high need schools tend to be forced to follow very prescriptive rules based upon federal and state guidelines. It has been my experience that true innovation is actually occurring in less impacted districts.

In our district, we have implemented a series of initiatives aimed at differentiating learning for all students. Our largest initiative is already in action. We have been using a plan based upon a 1-1 iPad teaching and learning model that has really impacted student engagement and learning. This has been part of a broader initiative aimed at changing the classroom dynamic to a more student centric focus built around problem based learning, global competencies, standard mastery, and defined life skills. We have already changed our board and superintendent evaluation procedures and we have implemented a team based principal evaluation and development system that we have submitted to present at CSBA. I am in discussion with our teacher's association regarding a new teacher evaluation model that emphasizes teacher development for the vast majority and stronger teacher evaluation tools for the few who need those. This is just a snapshot of the work that we are doing that under your guidelines will never become part of your model for improving schools to meet the needs of all learners.