The Honorable Arne Duncan
Secretary of Education
U.S. Department of Education
400 Maryland Avenue, SW
Washington, DC 20202
RE: Race to the Top Fund proposed priorities, requirements, definitions, and selection criteria.
Docket ID ED-2009-OESE-0006
Dear Mr. Secretary,
On behalf of ConnCAN – the Connecticut Coalition for Achievement Now – I am pleased to submit comments on the draft regulations for dispersal of Race to the Top funds. This program represents an extraordinarily important shift in the relationship between the federal government and the states concerning education reform.
ConnCAN was founded in January 2005 by a group of education entrepreneurs who believed that closing the achievement gap requires not only innovative educational models, but also issue-based advocacy to ensure a policy environment in which effective education reforms secure systemic change.
Today, ConnCAN has a staff of 10 employees working in offices in New Haven and Hartford, and is hailed as one of the nation’s leading state-level education reform organizations.
ConnCAN is now wrapping up our highly successful 2009 state legislative campaign, called ‘Mind the Gaps’. The campaign advocated for three commonsense school reforms closely aligned with the Race to the Top priorities: teacher quality, data transparency, and funding to grow high-performing public charter schools.
ConnCAN believes that the Race to the Top fund creates a unique opportunity to push evidence-based education reform at the state level and we look forward to crafting an advocacy agenda supported by the fund’s objectives.
As a state-based education reform movement with a track record of successful legislative advocacy, ConnCAN is well placed to provide insight into how the Race to the Top can be leveraged to create lasting change in statehouses across the country. Accordingly, we respectfully offer the following suggestions:
Selection criteria: give higher weight to “past state reform conditions” than “future plans”
Most fundamentally, in finalizing the rules for the competition we urge you to uphold the high bar which the draft guidance sets on “past state reform conditions” by indicating that applications will be scored on the following selection criteria based solely on their status at the time the application is submitted:
Developing and adopting common standards (A) (1)-
Developing and implementing common, high-quality assessments (A) (2)-
Fully implementing a statewide longitudinal data system (B) (1)-
Providing alternative pathways for aspiring teachers and principals (C) (1)-
Intervening in the lowest-performing schools and LEAs (D) (1)-
Increasing the supply of high-quality charter schools (D) (2)-
Demonstrating significant progress (E) (1)-
Making education funding a priority (E) (2)-
This feature of the competition is vital for ensuring that states that have not already met these preconditions take urgent action to enact legislative and administrative reforms between now and the application deadlines for Round I and especially Round II. It is also important that the selection process be weighted to give past reform conditions an edge over future plan selection criteria. After all, states that have shown their commitment through concrete reform actions prior to the application deadline are much more likely to stick with the challenging political and policy processes required to successfully implement their future plans.
Time Round I and Round II to maximize state reform activity
We further urge you to space the application deadlines of these two rounds to ensure that the Round I application process has concluded and that winners have been publicly announced no later than February 15th, 2010.
This will enable state legislatures in most states to be informed and inspired by the Round I outcomes as they introduce legislative and administrative changes that could make them competitive for the Round II application process by advancing their record of accomplishment on “past state reform conditions.”
Likewise, we urge you not to set the application deadline for Round II prior to July 1, 2010. This span of time is necessary to ensure that State Boards of Education have sufficient time to meet and implement administrative actions that complement legislative changes that might be made during the 2010 state legislative cycle.
Give extra credit for recent regulatory and legislative reforms under “minimum proposed evidence” as part of the Round II application process
There are currently major disparities between the “state reform conditions” across the fifty states. It is entirely appropriate that the winners of the Round I process be only those relatively few states which are already well ahead of the pack. However, it is sensible to modify the selection criteria somewhat in Round II to allow for states which have instituted comprehensive reform packages addressing every one of their shortcomings under the “state reform conditions” criteria to receive some recognition for this in the selection process. State legislative leaders must not be left in a position to conclude that no matter what good faith efforts they make to compete, they will not be able to successfully “Race to the Top” simply because they were too far back in the pack at the start.
Under the “minimum proposed evidence” for certain selection criteria as proposed, these states won’t be able to receive full credit for their rapid progress despite having made every effort available to them to bring themselves into compliance with a given selection criterion. For instance, a state which previously had no alternative pathways for teachers and school leaders, and which enacts such pathways during its 2010 legislative session will very likely not have time to actually get any teachers or school leaders certified through these alternative pathways prior to the Round II deadline, and will therefore lose points because it has had zero teachers and school leaders certified under its alternative pathways at the time of the application.
Sincerely,
Alex Johnston
Chief Executive Officer
ConnCAN
data to the public – are officially law of the land. Governor Rell has signed both bills into law, which means they can start helping Connecticut kids right away.
