Race to the Top Comments

August 27, 2009 | Click here to view PDF (516 KB)

RE: Comments Related to Race to the Top Fund; State Fiscal Stabilization Fund Program; Grant program for Statewide Longitudinal Data Systems;

Notice of Proposed Rulemaking
Docket ID ED-2009-OESE-0006
Program Authority: American Recovery and Reinvestment Act of 2009,
Section 140006, Public Law 111-5
Comment Deadline: August 28, 2009

Submitted by: The Public Education Network
601 Thirteenth Street, NW, Suite 710S
Washington, DC 20005
Wendy D. Puriefoy, President

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

Dear Secretary Duncan:

Introduction:
Public Education Network (PEN) thanks you for this opportunity to submit comments related to the Notice of Proposed Rule Making (NPRM) for the Race to the Top competitive grant program, Federal Register August 29, 2009.¹

PEN is a national network of 76 local education funds (LEFs) that advance public school reform in low-income communities across our country. LEFs serve 12 million children in 33 states including the District of Columbia and Puerto Rico. In addition, PEN has expanded its work internationally to include members in Mexico, Peru, the Philippines, South Africa, and Tanzania.

If Race to the Top and other education stimulus-generated reforms are to be transformational, PEN believes an active, vocal constituency at all levels of government is the key to support, fund, and sustain those changes for children in low-income and minority communities, whether those be urban or rural. Because local education funds represent a broad range of community interests at the school district and community level, they are well positioned to bring together the various community stakeholders and citizens in demanding high performing public schools for all students. In addition, they can build the civic capacity in advocating for equity, demand public accountability based on meaningful and "deeper" data, close the achievement gap, implement and support best practices, and prepare students who are college and career ready.

Among the functions that LEFs perform are:

• creating momentum for innovation
• building community capacity and school infrastructure
• generating knowledge
• utilizing data
• building models for high school reform and college access
• developing teacher and principal leadership programs such as urban residency initiatives
• creating community learning centers
• promoting school climate and whole child initiatives such as Life Skills, and
• partnering in programs such as STEM, parental involvement, Trio, Gear-Up, and Full Service Community Partnership efforts

At the heart of the Network's future work is a commitment to:

Increase the rate of low-income minority students graduating from public schools ready for college and a career over the next five years based on a set of Network-wide measures in the communities that PEN LEFs serve.

Since local education funds view education reform as a community and public enterprise, they do not take a cookie-cutter approach to change.² Rather, they apply a deep knowledge of local context, data driven decision making, accountability for results, research, local needs assessment, funding, and constituency building to change, transform, and sustain improvement efforts. As PEN comments on Race to the Top proposed rules, our lens will focus on a number of elements that cut across all aspects of change and improvement that, if not addressed, would greatly diminish the Race to the Top efforts to improve the most difficult schools, and increase the number of students that are career and college ready.

These include functions of capacity, qualified teachers and principals, local level partnership and flexibility, community and family engagement, shared accountability based on continuous progress and multiple measures, and an improved and expanded data system:

• increased capacity at the state and local level to provide the needed school, staff, and student supports in achieving Race to the Top objectives, especially for schools that are identified as low performing or struggling
• recruitment, retention, and development of the most highly qualified teachers and principals to lead the most difficult and struggling schools
• greater federal support and leadership in areas of research and identification of best practices and coordination of federal research such as the labs, centers, comprehensive technical assistance agencies, and the PIRCs
• increased allowance for local flexibility that recognizes community, school, and student differences, and coordination of categorical programs that lead to more efficient and effective use of resources based on student needs
• an accountability system that is research-based with multiple measures and a focus on incentives, rather than prescriptive and is shared among the various stakeholders at all levels
• a richer and deeper pool of data that not only focuses on test scores, but other measures that contribute to the academic success of students, along with the more effective uses of that data
• community engagement that serves as an integral part of school district transformation and reform, that builds the civic capacity and ownership to demand change, holds schools accountable, shares responsibility for quality public schools, and sustains efforts
• family connections and engagement is critical to closing the achievement gap, contributing to increased academic achievement, and holding schools accountable, regardless of parents' education level, ethnicity, or socioeconomic background^{3 4}

In our view, these elements constitute the pathway of addressing the conditions of getting students where they currently are to assuring that they graduate college and career ready. We believe in the four assurances, but do not believe that the strategies outlined in the rules will necessarily achieve the Race to the Top objectives. Effective school reform needs to be a "bottom-up" as well as a "top-down" enterprise. In others words, district and state level policy need to be developed to support change. At the same time, schools and districts need to demonstrate how reform improves school life and student outcomes. But these roles need to be coordinated, well-defined, and based not solely on state compliance, but on local trust.

General Comments:

PEN recognizes and appreciates the intentions of the Administration and Congress to confront fundamental education issues that we know create obstacles for many of our children and families from experiencing the full benefits of citizenship in a democracy, and to use Race to the Top, as well as other stimulus monies to further "stimulate" state and local reforms addressing the achievement gap, high school dropout, college access, teacher quality, school capacity, quality preschool, and funding.

However, PEN is very concerned, that with the exception of very few mentions of community engagement and family involvement, that Race to the Top is out of balance, topheavy, and needs to recalibrate the relationships between state and local, between the top and the bottom, between compliance and flexibility, and between the regulators and practitioners. In a few words, the public is missing, and there needs to be a stronger working role at the state level linking the participation, needs, and context of local school districts, families, and the community. On the other hand, PEN recognizes that states need to build their own capacity in order to more effectively support the needs of LEAs and struggling schools.

While community and families are referenced in the guidelines, they are not fully coordinated and integrated into the Department's reform and innovation strategy. Such framing is essential in our view if our schools are to do their job - improving academic achievement, and if the many community partners are to do their job - helping to create all the conditions for learning necessary for our most vulnerable students in our struggling schools. There needs to be a seamless relationship between Race to the Top and the Innovation programs (the rules yet to be announced), and a partnership between the state, local school districts, and community that should be defined in the rules and enable the LEA working with their community, whether they be urban, suburban, or rural, based on their own particular needs.

We commend the Administration for proposing Promise Neighborhoods,⁵ and this model would be much more closely tied to the coordinated efforts that we believe needs to exist for the Race to the Top changes to be stimulative. A Declaration of Interdependence needs to be declared within communities, between the LEA and the states, and inter-and intra-agency integration at the federal level. Cultivating "bottom-up" collective pressure through the stimulus rules means educating and mobilizing the public through learning communities, public outreach, dialogue, and understanding of the data -- far more consequential in scaling up and providing systemic reform than increasing the number of charter schools or voucher programs.⁶ PEN is supportive of the four assurances, but the public needs to be as well.

Race to the Top and the four assurances provide an unprecedented opportunity to rally the public around change and reform. Without public support and ownership being an integral part of the reform paradigm and Race to the Top, the nation misses a real opportunity to involve its citizens evolving new shared purposes, shared change, shared accountability, and shared achievements. In a recent presentation, U.S. Secretary of Education Arne Duncan said about the Race to the Top, "We will not invest in communities that don't collaborate -- we just won't do it -- it all has to be done in partnership."⁷ PEN supports the Secretary's partnership commitment and has added the community voice in a number of strategic provisions of Race to the Top.

Timing of Applications and Awards

Recommendation:
We agree with the inclusion of community supporters as one of the parties from which the States would be encouraged to receive commitments, but we would also add families to the list of parties. Short of a mandate, we would add that the states be STRONGLY ENCOURAGED to involve and receive commitments from community level organizations and citizens, and should be incorporated as an "absolute priority" as in Proposed Priority 1.

Proposed Priority 1
Absolute Priority -Comprehensive Approach to the Four Education Reform Areas

Recommendation:

Add:
PEN recommends that for each of the core areas, when the States submit their application, they must demonstrate how and to what extent both the state and the LEA have involved community organizations, community stakeholders, and groups that have been traditionally left out of reform decision-making; and/or the state and LEAs demonstrate they will increase their capacity and infrastructure to partner with community and families, especially related to struggling schools. Additional points should be given to those applications which meet the above recommendations and focus on building community in conjunction with the building the capacity of the school system.

Section I Proposed Priority 5
School-level Conditions for Reform and Innovation
(v) Providing comprehensive services to high-need students (e.g. Through local partnerships, internal staffing and contracts with outside providers)

Recommendation
PEN calls for this Priority to be upgraded from "Invitational" to "Competitive." Positive changes in school climate, the creation of strong community, family engagement, successful perception of safety of a child's school, the welcoming nature of a school, and the feeling by students that the teachers care about them need to be acknowledged as "progress."

Proposed Priority 3-
Expansion and Adaptation of State Longitudinal Data Systems

Recommendation:
PEN strongly supports the creation of a comprehensive data system that integrates data on many factors related to student achievement and improvement that this priority suggests. This expansion of data would provide a comprehensive picture of:

• individual student performance
• school performance
• includes both academic and non-academic indicators
• reports information on the school and school district's opportunities for learning that guarantees student success in moving toward achieving the standards, and
• provides for the assistance necessary for educators, parents, and the community to appropriately understand and utilize data that serves to drive change and improvement

By moving from an overwhelming reliance on standardized tests in just several subjects to using multiple indicators that are related to student progress, this provides a deeper and richer picture of both student and institutional linkages to student success. PEN believes that this data needs to be based on high quality assessments and systemic data collection that is reliable and valid. In addition, new assessment systems should include the use of locallybased evidence of student learning, in addition to state level exams. Further, state evaluations of "student achievement" need to incorporate additional data, such as high school graduation rates. (See PEN recommendation: (E) (4) Raising achievement and closing gaps (iii) Graduation Rate)

New systems also need to help teachers develop and use classroom-based "formative assessments." These provide teachers with prompt feedback on what their students do and do not understand, and they enhance teachers' skills in adjusting instruction accordingly to meet the needs of individual students.

It would be a missed opportunity if states collected annual data only on student academic achievement, as these data represent too narrow of a view of student success. States should strive to get as broad a picture as possible of the multiple factors known to affect student achievement. In many cases this information is already being collected; but, the agencies collecting the data are not sharing the information with each other or the school's external partners and do not use the data to drive performance and decision-making. In other cases, community-based partners, universities, and hospitals can help schools gather and analyze data to coordinate programmatic responses.

Recommendation:
PEN proposes that the title of this section be changed to: Expansion, Adaptation, and Appropriate Utilization of State Longitudinal Data Systems

Recommendations:
Education equity attorney Mike Rebell recommends that the federal government hold schools accountable for factors other than test scores.⁸ Schools need the overt support from U.S. DOE that positive school climate is absolutely essential to academic success. History has proven that without such overt support, that schools revert to focusing on just what is measured. PEN recommends that these additional factors could include:

• school climate and development of school climate standards to demonstrate how schools can improve climate as demonstrated by the new National School Climate Standards that Ohio will vote to adopt in December 2009
• student progress over time
• social and emotional health
• health indicators such as immunization rates and vision and hearing screening
• parent engagement
• attendance (including early chronic absenteeism)
• early childhood education screening and intervention data, and
• participation in out-of-school time programs

Recommendations:
PEN recommends that state and local school districts report on the following community engagement data:

• How did the local education agency involve the community, (including any existing Local Education Fund, P-16 Council, and similar entities) in setting priorities for use of Stabilization Funds, Race to the Top fund (as well as use of Title 1, IDEA funds, and other education stimulus funding)?
• How did the state and local education agencies disseminate and explain the data to the community (i.e. through community forums, internet, telephone, handouts, and other means)?
• How did the local education agency receive and integrate community input in developing a plan of action to improve schools based upon the data disseminated? In what ways will the community continue to provide meaningful input into implementation of the plan of action going forward?
• In what ways did the community act upon this information (e.g. by adopting a report card or other evaluation system) regarding the use of Stabilization funding?
• What is the percent of community stakeholders taking individual and/or collaborative action on behalf of struggling schools?

Recommendations:
This also applies to (B) Data Systems to Support Instruction State Reform Conditions Criteria

(B) (2) Accessing and using State data, and
(B) (3) Using Data to Improve Instruction
Most importantly, how data is used as a diagnostic tool to improve achievement and instruction is key, not only to policy makers, but especially to educators and the public. Data should not be used to penalize schools, but should be used as tools to propose and implement strategies for school improvement. For data to be effective, a school must use the data in order to determine what works, improve on practices, and create new avenues to address barriers to learning and teaching. PEN recommends that this section not only include provisions on the expansion of data, but also in assuring that educators and community possess the skills in properly using data linked and aligned with the data expansion strategies. PEN recommends the following as states apply with their LEAs for Race to the Top funding:

• Based on state and local need, a portion of the Race to the Top funding should be used to increase educator and community understanding in order to effectively utilize data for schools identified as low performing or in need of corrective action.
• Encourage states and local school districts to employ professionals who are part of the instructional division, possessing both assessment and instructional expertise, to support and assist schools and educators in effectively utilizing the data.
• The state should provide technical assistance to school districts in the effective use of data to improve teaching and learning.
• As part of the state plan, evidence must be shown that proves the district has developed an effective communications plan that demonstrates it is able to reach deep into the community with information about school quality.
• Provide technical assistance to teachers and administrators in how to effectively use data and communicate school data to families and the public leading to meaningful change and improvement.

Recommendation:
That states provide an "Opportunity to Learn Index,"⁹ which would track data about the quality of state and local education systems. Before we can say that all students can achieve at proficiency, or that they will be college and career ready, we must also assure that all students have access to the educational resources public schools need for this aspiration to be attained. Race to the Top should seek states that are interested in combining their learning standards and academic expectations to the capacity of schools to be able to attain those expectations. In other words, 1) data on what conditions are necessary for students to succeed, and 2) information about the institutional, resource, and instructional gaps that place some students at an educational disadvantage over other students. A similar framework should be used to assure that the community, business, charter schools, corporations, funders, and families are meeting their responsibility for assuring quality schools. To this end, PEN has produced the Civic Index for Quality Public Schools which can be used in conjunction with the "Opportunity to Learn Index."¹⁰

Under the heading 'Proposed Priorities
Add 'Proposed Priority 6
Invitational Priority-
Adoption of Proven Programs

Recommendation:
The Secretary encourages applications in which States granting Race to the Top funds will award a competitive preference for programs that have been demonstrated effective through rigorous research. They must demonstrate not only improved academic success, but also improvement in school climate to assure students a safe, caring, violence-free school environment; and one that is conducive to learning and promotes the education of the whole child. States will identify resources for LEAs, including the existing federally supported research and development and technical assistance infrastructure, to identify best available empirical evidence for specific problems of practice.

II. A. Eligibility Requirements
Proposed Eligibility Requirements

Recommendation:
PEN is concerned about the eligibility provision that requires a state "not to have any legal, statutory, or regulatory barriers linking student achievement or student growth data to teachers for the purpose of teacher and principal evaluation." For local school districts in states that do have barriers, this serves to have an unintended consequence of penalizing local school districts and communities, especially those who have a high number or high percentage of struggling schools, or in states that have made progress in raising achievement. PEN requests that the U.S. Department of Education revise this provision so that schools and students are able to be served by Race to the Top funding.

Recommendation:
Within subheading B 'Applications Requirements', part (d), PEN recommends a change to read: "The State must describe its statewide support from stakeholders, community members and organizations, families and LEAs, including the federally supported research and development and technical assistance infrastructure, including the PIRCs, and public charter schools identified as LEAs under State law."

Proposed Priority 4: Invitational Priority -
P-20 Coordination and Vertical Alignment

Recommendation
Many of PEN's local education funds are active participants of their state P-20 Councils, and find them effective vehicles in not only aligning the various transition stages of a seamless education program, but also horizontally aligning the school and community levels to integrate the assets of all the sectors to support student success.

Two excellent examples are Ohio and Tennessee, which have P-20 Councils in every county, and in each state. The Councils serve to effectively bring together a range of partners that otherwise would find it difficult to collaborate, including public and private agencies, community-based organizations, higher education, businesses, and civic groups concerned with student achievement, as well as coordinating with federal categorical programs.

Horizontal alignment at the school and community level also is important to ensure that students have access to the array of opportunities and services they need that are beyond the capacity of the school itself to provide. Proposals focused on the P-20 approach should demonstrate purposeful results-focused partnerships among key institutions that will realize the necessary alignment.

The principle of partnership also should be more explicitly incorporated here, and the value of not only aligning the top and the bottom, but also aligning across the reform and civic spectrum with a focus on the local level is essential.

Proposed Priority 5-Invitational Priority-
School-level Conditions for Reform and Innovation

Recommendations
PEN views this priority as one of the engines that will drive Race to the Top. However, PEN would recommend that the Department consider a more integrated and comprehensive approach to local level innovation and reform planning, especially as this provision focuses on struggling schools. It is this priority that serves as the nexus for bringing together the standards, the academic and developmental data, research, teacher and principal leadership and quality, funding, NCLB improvement plans, family involvement, and community engagement -- all knowledge that converges to inform the school district and the community about the transformational changes that need to take place for all children to succeed.

We are pleased that the rules reference the importance of expanded learning time, local partnerships, and comprehensive services for high needs students. But "piece-mealing" this priority may discourage states and local communities from thinking broadly. They should use the data to inform individual school district and school needs, to integrate various state and local level student supports, to experiment with various family involvement models integral to student success, and most importantly, to engage the public in school improvement and equity solutions.

In addition, the guidelines overall, do not speak to the conditions that are necessary for student learning; rather they focus primarily on institutional behavior. This omission leaves the guidelines with an insufficient focus on students in struggling schools and what they need to succeed. Taken together, this would send a signal to states and LEAs about the Department's interest in what the Secretary has called "schools as centers of community," also known as community schools, community learning centers, or full service community schools. These kinds of schools work with community partners to mobilize school and community assets toward a common set of results. In addition, they would position well schools, districts, and community based organizations for the set of stimulus strategies incorporated in the Innovation funding:

• giving schools autonomy in selecting staff
• providing high quality, engaging curricula and instruction that focus on real world problem solving
• implementing new structures and formats for the school day or year that expand learning time, including flexible use of school facilities
• placing budgets under the schools' control and involving teachers and families in budget decisions
• using research and data to drive decisions related to school improvement plans and decisions
• employ a community and family coordinator for the school to build or strengthen community and family engagement, with the involvement of community members and family organizations, in areas of communications, decision-making, understanding of data, school program evaluation¹¹
• awarding credit to students based on student performance instead of instructional time
• providing comprehensive learning supports to high-need students (e.g., through local partnerships, internal staffing, and contracts with outside providers), and integrating federal categorical programs based on local need
• implementing strategies to effectively engage families and communities
• involving families and the community in developing local improvement plans and develop strategies of effectively keeping the community informed of school improvement decisions
• leveraging resources from other state agencies and local partners
• increasing the use of research based instructional improvement systems (as defined in this notice) to drive innovation, and that provide teachers, principals, and administrators with the information they need to inform and improve their instructional practices, decision-making, and overall effectiveness in their efforts to meet all essential developmental needs of the students; the academic, as well as the social, emotional, and creative dimensions of the learning of children

(B) Data Systems to Support Instruction
(B) (3) Using Data to Improve Instruction

Recommendation:
Add: iii to read:
Increase the use of research based instructional improvement systems (as defined in this notice) to drive innovation, and that provide the public, community, families, teachers, principals, and administrators with the information they need to inform and improve their instructional practices, decision-making, and overall effectiveness in their efforts to meet all essential developmental needs of the students; the academic, as well as the social, emotional and creative dimensions of the learning of children.

( C ) Great Teachers and Leaders
State Reform Conditions Criteria

Comments:
Providing the support that teachers and administrators who are in struggling schools involves more than "putting the heat on the school or on the teachers." It also involves changes in the structures, culture, and polices that determine the way teachers are supported, prepared, inducted as beginning teachers, developed, compensated, recruited, and assigned. Changes need to occur at multiple levels: the policy level, within schools of education, state departments of education, and at the district and individual school level.

PEN believes that using the teacher urban residency model, now being supported and led by PEN's LEF in New York, Boston, Philadelphia, Houston, San Francisco, and Denver, as well as elsewhere in the nation, provides the transformational model that can turn around difficult and struggling schools, and meet the objectives of Race to the Top. Teacher urban residency programs focus on teacher effectiveness, and not on a minimum and arbitrary standard of "qualified" as in NCLB. These supports also recognize the importance in developing qualified administrators to create school environments that attract and retain the most qualified teachers in high needs schools.

Recommendations:

• Federal funds should be allocated to create a national teacher and education leadership corps that will create special opportunities for new and existing teachers and administrators to receive the leadership and teaching skills necessary to teach in high needs schools and work with high needs students. Through a competitive grant process, 25 schools of education would be identified as providing effective teacher education programs for educators in high needs schools. These schools would then enter into partnerships with local school districts and community-based organizations to provide both pre-service and in-service programs for schools and school districts that have the greatest needs. Both administrators and teachers would be granted special certification.
• States should be encouraged to expand teacher education programs that produce effective teachers and have the features of effective programs, rather than expanding alternative certification programs in an undifferentiated way.
• Teacher evaluation should be based on measures of practice, performance, and varied evidence about student learning, rather than merely state test scores.
• Use multiple measures (similar to those used for students) to identify teacher effectiveness in meeting the needs of the whole child.
• Identify the school conditions necessary for teachers to be effective.
• Require a portion of Race to the Top resources be used to train principals and other school administrators to better assess teacher effectiveness.
• Provide incentives to districts and states that provide leadership opportunities for highly effective teachers to share their practice and expertise with other teachers.
• Increase resources to study and research teacher effectiveness and to make this research available to schools and districts.
• Provide loan forgiveness and other financial incentives to attract and retain the best and the brightest students into the teaching profession.
• Provide incentives (research) grants to districts, in partnership with their community and with local education funds that want to experiment with more performancebased definitions of teacher effectiveness.
• Require that districts ensure that Title I schools have the same proportion of qualified and effective teachers as all schools in the district.

(D) (2)
Reform Plan Criteria
State Reform Conditions Criteria
Turning around struggling schools
Increasing the supply of high-quality charter schools

Recommendation:
PEN is concerned about the provision "to the extent to which the State has a charter school law that does not prohibit or effectively inhibit increasing the number of charter schools ....or otherwise restrict student enrollment in charter schools." For local school districts in states that do have barriers, this serves to have an unintended consequence of penalizing local school districts and communities in states that have charter caps, and who have a high number or high percentage of struggling schools, or in states that have made progress in raising achievement.

The Race to the Top guidelines call for increasing the supply of "high-quality" charter schools. If it were so easy to mandate quality, one could simply require states to increase the supply of "high-quality" traditional schools as well. Research and experience have shown that a liberal charter sector is no guarantee of improved outcomes, and often results in poorer school performance.12 Here again, we recommend that the Department of Education not impose this policy on states applying for Race to the Top Funding. PEN is not in opposition to charter schools, but requests that the U.S. Department of Education relax this provision so that schools and students are able to be served by Race to the Top funding, and so that additional research is conducted on "quality" charter schools before charter schools are indentified as a scalable reform.

Recommendation:
(D) (2) (ii)
PEN appreciates the Department's concerns about assuring that when public charter schools are employed as a struggling school intervention, that the state develops quality statutes and guidelines to assure public charter school quality. PEN recommends that under (ii), there be specific requirements that charter schools under this provision will adhere to the same accountability criteria and regulations as do the traditional non-chartered struggling schools.

(D) (3) Reform Plan Criteria
Turning around struggling schools

Recommendation:
PEN supports the Department's focus on persistently low-performing schools and the references to extended learning time, community-oriented supports, enrichment activities, and family and community engagement in the final bullet. The guidelines, seemingly inadvertently however, suggest that some of these kinds of opportunities should only be provided in schools that choose the fourth restructuring option. Of greater concern is the fact that the guidelines suggest that the fourth option is not as desirable as the others. We would argue that there should be four restructuring options, and that all struggling schools, regardless of the structure of reform they pursue, should work to provide the additional learning opportunities and supports referenced in the fourth bullet. In many districts and states, these opportunities are already fully integrated into turn-around strategies. The guidelines should encourage - not detract- from the integration that is already taking place.

Second, PEN urges that the State require that any time a school is designated as a turn around struggling school, the LEA must:

• notify families and the community about the status of the school in a format and language that families are able to understand
• develop a school improvement team charged with developing a school improvement plan (under the Race to the Top criteria) that must include families of the turn around school and community members
• families of the turn around school must be informed of the school improvement plan, and the changes that are being proposed
• each turn around school must have as one of its strategies a meaningful parent involvement program based on research and current best practice models. Data about the family involvement program shall be reportable data under Accessing and Using State Data, (B) (1), and
• the state should be required to provide technical assistance to the turn around schools related to model parental involvement programs

Lastly, we also believe that the terms used here should be consistent with those referenced in what is now Invitational Priority 5. We encourage the Department to use comprehensive learning supports (rather than community-oriented supports which is not a common term in the field). We also encourage ED to separate the terms family engagement from community engagement; while these terms are now often combined because engagement has become so important, they are different stakeholders requiring different strategies.

(E)(5)
Building strong statewide capacity to implement, scale, and sustain proposed plans

Recommendation:

• require that families, parent organizations, and community-based organizations be included in the development, implementation, and evaluation of state plans

Recommendation:
The extent to which the State has a high-quality overall plan that demonstrates how it has, and will continue to build and sustain the capacity to --

• add: families to "other state and local leaders" and change community to "community-based organizations, individual community members, and community stakeholders"
• coordinate, reallocate, or repurpose education funds from other federal, state, and local sources to align with the State's Race to the Top goals, as outlined in its plans; the Department should seek input in state proposals on how other ED categorical funding streams can be brought into alignment with state reform and innovation goals
• coordinate with other state agencies with funding and capacity to help schools and communities provide expanded learning time, comprehensive learning supports, enrichment, family and community engagement, and other opportunities and services that will increase student achievement

Reform Plan Criteria
(E) (4) Raising achievement and closing gaps
(iii) Graduation Rate

Recommendations:
PEN recommends that the following data be collected on a longitudinal basis to measure and report performance on college and career readiness:

• percent and number of additional low-income/minority 9th graders who graduate college and career ready in 4 years
• percent increase and number of additional low-income minority students on-track to be college and career ready
• percent increase and number of additional low-income/minority students being taught by effective teachers
• new assessments should be used to inform high school curriculum rather than high school exit requirements, pursuing better learning opportunities, rather than often counterproductive exit exams

Definitions

Recommendation:
Include a definition of "Community Engagement" as follows:
Community engagement to improve public education refers to purposeful, systemic and sustained efforts by the school system to collaborate with parents, members of school communities, the public and a broad range of stakeholders outside of schools, including those who have traditionally not participated. To increase student achievement and promote student growth, community engagement is an integral civic and instructional element in developing a shared responsibility between the school system and community for exploring the needs of their students, developing plans that will assure a quality education for all students; holding the public and its schools accountable, and deepening the community-wide commitment to student success. Community engagement can be measured by both the school and civic policies and practices adopted within a community supported by the public, the breadth and depth of involvement of stakeholders, and the public's knowledge about its public schools that leads to change.

Include a definition of "Family Engagement" as referred to in Selection Criteria D (3) in the definitions section of this Notice. The FSCE Working Group defines family engagement as:

a shared responsibility of families and schools for student success, in which schools and community-based organizations are committed to reaching out to engage families in meaningful ways and families are committed to actively supporting their children's learning and development. This shared responsibility is continuous from birth through young adulthood and reinforces learning that takes place in the home, school and community.
(from comments submitted by the National Family, School, and Community Engagement Working Group)

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Like you, PEN believes that Race to the Top offers a unique and strategic opportunity to frame and implement innovation, improvement, and experimentation in public education. It is also an opportunity to engage in a national conversation with local school districts and communities about reasons for education change, and the chance to involve the public in a discussion about the kind of education systems America needs for all children to economically compete and civically thrive in the 21st century.

But this is not just a responsibility for our public school system, but a collective responsibility that requires all of our communities working together with a sense of shared purpose and vision. Developing that purpose is a function of leadership at all levels and we believe that the demand for high quality education at the local level is far greater than the supply. Race to the Top should encourage the States and school districts to try new approaches and to implement existing strategies with a strong evidence base behind them.

Robert L. Hughes, president of New Visions for Public Schools, and one of PEN's members talks about his experiences turning around struggling schools, "You need to have an accurate diagnosis of why each of those 5,000 schools [to which U.S. Secretary of Education Arne Duncan refers] are failing. It's crucial. Sometimes you need a two-by-four to get change. Other times you need a scrapple."¹³ In our view, Race to the Top should not single out "programs" as the single best reform for every school district, but seek comprehensive restructuring and transformation based on institutional and school system capacity, competencies, public will, and trust in the democratic process.

Public Education Network and its members welcome the opportunity to speak more with you or your staff about how we can help you reach your goal for accomplishing the Race to the Top objectives.

Sincerely,
Wendy D. Puriefoy, President and CEO
Public Education Network

¹ Public Education Network also supports comments submitted before August 22, 2009 by: Coalition for Community Schools; National Family, School, and Community Engagement Working Group; and United Voices for Education

² "Taking Responsibility: Using Public Engagement to Reform Our Public Schools," Public Education Network, 2004.

³ We cannot emphasize enough that the terms family engagement from community engagement be used separately; While these terms are now often combined because engagement has become so important, they are not necessarily synonymous and constitute different stakeholders requiring different strategies, even though parents should always be included as citizens and an integral part of community engagement. (See definition section)

⁴ Henderson A. and Mapp, K. (2002). A New Wave of Evidence: The Impact of School, Family, and Community Connections on Student Achievement. Southwest educational Development Laboratory. Houtenville, A. and Conway, K. (2008). Parental Effort, School Resources, and Student Achievement. Journal of Human Resources, XLIII, 2. Pp-437-53.

⁵ $10 million dollars has been appropriated for this measure by the House Appropriations Committee in the 2010 Federal Budget.

⁶ "A Critical Analysis of Bringing Equity Back: Research for a New Era in American Educational Policy, edited by Janice Petrovich and Amy Stuart Wells, New Visions for Public Affairs, Volume 1, Spring 2009.

⁷ Presentation at the ACT and America's Choice Conference, August 20, 2009, Park Hyatt Hotel, Washington, DC.

⁸ Rebell, Michael. "Reauthorizing NCLB: A Summary of Recommendations." Washington: Campaign for Educational Equity, 2008

⁹ "Lost Opportunity: A 50 State Report on the Opportunity to Learn In America," Schott Foundation for Public Education, 2009.

¹⁰ Civic Index for Quality Public Schools," see www.PublicEducation.Org and www.civicindex4education.org

¹¹ Keeping Parents and Communities Engaged (PACE) Act.

¹² "Multiple Choice: Charter School Performance in 16 States," Center for Development of Education Outcomes," Stanford University, 2009

¹³ "Call for Transforming Struggling Schools Stirs Debate," Education Week, August 12, 2009, p 18.