Innovation Fund Comments

November 8, 2009 | Click here to view PDF (216 KB)

RE: Comments Related to Investing in Innovation Fund;
Notice of Proposed Rulemaking
Docket ID ED-2009-OII-0012
RIN 1855-AA06
Agency: Office of Innovation and Improvement, U.S. Department of Education
Program Authority: American Recovery and Reinvestment Act of 2009, Section 140006, Public Law 111-5
Comment Deadline: November 9, 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 proposed priorities, requirements, definitions, and selection criteria for the Investing in Innovation competitive grant program, Federal Register October 9, 2009.¹

PEN is a national network of 76 local education funds (LEFs) that advance public school reform and improve student achievement   in low-income communities across our country through public engagement.  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. 

Obviously, PEN supports the concept of Investment in Innovation that encourages the partnership of the school districts, local education funds, philanthropy, and community-based organizations in developing and scaling research-based innovative practices that lead to increased academic success for students.  If the Investing in Innovation fund 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, research demonstrates they can build the civic capacity in advocating for equity, demand public accountability based on meaningful and "deeper" multiple measures of data, close the achievement gap, implement and support best practices, and prepare students who are college and career ready.²³

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.⁴  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 Investing for Innovation 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 innovation objectives in improving 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. 

In our view, these elements constitute the pathway of addressing the conditions   necessary to move students where they currently are to assuring that they graduate college and are career ready.  Our focus will be on a variety of issues including:

1. An additional Absolute Priority pertaining to community engagement is critical to successfully addressing the innovations related to the other six Absolute Priority areas.  This is not about just dialogue, or advancing a point of view, but broadening the diversity of those who are involved in critical change decisions that produce action oriented student outcomes based on the data and research including parents, educators, stakeholders, business, students and especially those whose voices are underrepresented in the civic process.   We know from experience that building "relationships" and an engaged public is essential to advancing the rigor and the relevancy about which the Gates Foundation often reminds us. Unless public will and engagement does not run through each of the I-3 Priorities, the innovations that I-3 is attempting to develop and scale will cannot be accomplished in a public vacuum.⁵ The history and success of our local education funds are replete with research and evidence that when families and the community are engaged in meaningful ways, innovative things happen for children and academic progress is achieved.
2. PEN's concern is that the proposed rules are so overly complex and prescriptive that smaller and rural school districts and non-profits will be discouraged from applying, despite possibly having innovative initiatives that would qualify under the Investing for Innovation funds. 
3. A competitive grant writing process often favors those non-profits and school districts with a sophisticated development process that are most able to compete.  In our estimation, having all of the Investing in Innovative funding under a competitive framework, without providing assistance or allocating part of the funding as discretionary, weighs at a disadvantage to those having the least sophisticated development process and staff, usually in low-come and rural communities, but the fiscal crisis has also diminished the capacity of many larger urban school districts as well.  Competition might work if there is a level playing field, but since there is not, the Investing in Innovation process fuels inequities, possibly bypassing innovations and models that would be eligible for I-3 consideration, excepting those as a result of geography, poverty, capacity, or experience.
4. Integration of academic and the non-academic supports that students need to achieve, especially the integration of categorical federal and state programs with a focus on needs-based partnering, as opposed to the rigid firewalls that "silo" programs and children.  This means a greater emphasis on school climate, social and emotional learning, the arts, and the whole child as an integral part of any innovation plan. 
5. Wherever "student growth" is mentioned in the proposed rules, change to "student academic and developmental growth."
6. Overall, the proposed rules do not speak a lot about the conditions that are necessary for student learning. The Investment in Innovations funds can not only transform schools, but they can also transform NCLB, and change it from a deficit model policy (one that focuses primarily on students who fail) to an asset policy focused on what capacity the system requires at all three levels for students to be successful.  As part of the development of quality assessments that the Department is committed to, this is an opportune time to begin to develop school, climate, whole child as well as whole school, and community and parent standards--a range of multiple measures that serve to build equity and opportunity informing educators and the public about what conditions are necessary for children to do well on the new common standards.  It is easy to write standards; it is far more difficult to implement them.

General Comments
PEN commends the Administration for recognizing the important roles that non-profit organizations play in partnering with and supporting the academic and instructional roles of the local school districts.  Community-based organizations are mentioned over 30 times in the proposed rules, and PEN believes that schools cannot meet academic expectations of our students without the help of the entire community, including non-profit organizations and local education funds.  In addition, we commend the Department for recognizing the importance of a positive school climate in reaching the goals of Investing in Innovation, as well the Priority areas as articulated in the proposed rules.

However, PEN is very concerned, as with the proposed Race to the Top rules, that there are very few mentions of community engagement and family involvement.  The public is missing.  To pursue innovation without including families and community as a critical instructional component is short sighted, and a missed opportunity to not only sustain innovation, but to start at the community level in assuring that parents, community, and educators "own" the changes that results from innovations.  There is no guarantee that including non-profit organizations as eligible fiscal agents and partners will include families or promote community engagement including those that are most underserved, unless there is a requirement to do so.⁶

While community and families are referenced in the guidelines, they are not fully coordinated and integrated into the Department's reform and innovation strategy.  To this organization, they appear to be at the margins, if recognized at all.  There needs to be a seamless relationship between the community stakeholders of education, the local school district, and the non-profit partners.  We know that this is not intentional, and that the Department care about the involvement of parents and the community, but we are at a loss to understand why it is that community and families have not played a more prominent role in the Race to the Top proposed rules, and now the Investing in Innovation fund proposed rules. 

We commend the Administration for proposing Promise Neighborhoods,⁷ 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.⁸ 

Purpose of Program: Competitive Grants
(P.  52215)
Recommendation
With the understanding that while districts and non-profits may have innovative programs that would qualify under the I-3 framework, they may be unable to "compete" and apply because they lack the capacity to meet the application criteria.  This usually applies to smaller and more rural school districts and non-profits that often get shut out of federal competitive grant making.  PEN's recommendation is to set aside funding that is discretionary or formula-based to meet these needs, and/or offer special accommodations and personal assistance in helping smaller communities in meeting the logistical prescriptions in applying for I-3 funding.  There is much to be learned as both low-income urban and smaller rural districts can pursue their own innovative pathways.  Size, geography, culture, history, and context can have an impact on everything from effect size, conditions for learning, opportunities, funding, and equity. 

Purpose of Program
(p. 52215, end of first paragraph)
Recommendation:
Add to "as well as to promote school readiness, close achievement gaps, decrease drop-outs, increase high school graduation rates, and improve teacher and school effectiveness" strengthen family engagement, increase community involvement, and require community partnerships demonstrated to have an impact on student achievement and sustaining change and reform.
We also recommend that these additions be incorporated as an "absolute priority" in Proposed Priority 1.  Later in this proposal, we will recommend metrics and outcomes related to college and career readiness.  We also propose to add this language to p. 52216, under "Overview of the Three Types of Grants," 1) Scale Up Grants, end of first paragraph, and 2) Validation grants, end of paragraph.

Purpose of Program
(p. 52215, last paragraph)
Recommendation:
Add as (4), promote the integration of federal and state categorical programs as an innovative strategy.

Overview of the Three Types of Grants
p. 52216, 1. Scale-up Grants, end of second paragraph
Recommendation
Add local education funds to the examples of partners that can work with LEAs and states pursuant to scaling up.

Overview of the Three Types of Grants
p. 52216, 2. Validation Grants, third column, second paragraph, evidence of capacity
Recommendation:
Under examples of capacity, add: coordination and effectiveness of education and community partnerships, ability to utilize data, and manage a research construct.

PROPOSED PRIORITITES

Types of Priorities
Recommendation:
PEN recommends that for each of the core areas, when the I-3 applications are submitted, applicant(s) must demonstrate how the school district(s) have increased their capacity and infrastructure to partner with community and families, especially related to struggling schools; and to what extent local education funds, community organizations, community stakeholders, and groups that have been traditionally left out of reform decision-making demonstrate they will increase their capacity to partner with the school district.  Additional points should be given to those applications which meet the above recommendations and focus on building broad based community engagement in conjunction with building the capacity of the school system to meet the needs academic and developmental needs of students. 

Across the country, we know that when schools become centers of community, student achievement goes up.  But in many cases, school districts and community organizations either do not have the resources, the skills, the will or the capacity to build effective community partnerships.  By prioritizing both family engagement and community building, this would provide the development, implementation, research, and evaluation to take the I-3 priorities to scale. 

Proposed Absolute Priorities
Proposed Absolute Priority 1--Innovations that Support Effective Teachers and School Leaders
Recommendations:
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.  Innovative 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 Investing in Innovation Fund.  Another example is Humanitas model employed by the Los Angeles Education Partnership which focuses on transforming the school to create more effective teaching and learning, producing amazing results related to the Department's Priority Areas. 

Community partnerships such as Humanitas and teacher urban residency programs focus on teacher effectiveness, and not on a minimum and arbitrary standard of "qualified" as in NCLB, or "effective" as in the I- 3.  Humanitas focuses on transforming schools to create more effective teaching and learning environments, connecting parents and communities to schools to overcome learning barriers, building relationships with higher education and universities, and disseminating best practices about what was learned.  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.

As U.S. Secretary of Education, you made similar observations in a speech on teacher education at Teachers College, Columbia University: You said, "as you know, teacher residency programs follow a medical model of training, with residents placed in schools with extensive induction and support during a year-long apprenticeship.  In Chicago, I was lucky to work with the Academy for Urban School Leadership program, one of the nation's top residency programs.  The U.S. Department of Education recently announced $43 million in grants for 28 Teacher Quality Partnership programs that went to colleges of education and high-need school districts, with more than half of the five-year grants supporting residency programs."⁹ 

Recommendation:
Statement of the Proposed Absolute Priority, Under Absolute Priority 1, last sentence
p. 52218
Insert in the sentence "that the measures should be designed with teacher involvement," the words with "parent, local education fund, and community involvement" to read: the measures should be designed with teacher, parent, local education fund, and community involvement."

Add the following recommended criteria:

• 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.
• Employ such strategies as small learning communities, small schools, instructional coaching, and development of community schools.
• Build a data system, that measures student success and informs teachers and principals how they can improve their practices.
• Identify the school conditions and climate necessary for teachers to be effective. 
• Require a portion of I-3 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 performance-based 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.

PEN is concerned that ED does not add a requirement that to qualify for the I-3 funds, that a state "not 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 and non-profits in states that do not permit student data to be linked to teacher evaluation, 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.

For the I-3 grants, it should be a local decision if communities wish to innovate with a teacher and principal evaluation system that links student data to teacher performance.  Clearly, research is sparse, if nonexistent, related to how and if student test scores relate to teacher performance.  On the other hand, school districts wishing to use I-3 funds to research this and more effective teacher evaluation models should do so with the involvement of teachers, principals, local education funds, community based organizations, and other stakeholders. 

Proposed Absolute Priority 2-Innovations that Support Data
p. 52218
Recommendation:
PEN proposes that the title of this Priority be changed to:
Innovations that Improve the Utilization of Data to Improve School and Classroom Instructional Practices, Decision-making and Overall Effectiveness

Statement of the Proposed Absolute Priority
p. 52218, first paragraph
Add "community members" to the list of people who should be receiving the student achievement and growth data.

Add another section to the Statement of Absolute Priority 2
Recommendations:
PEN commends the Department for including multiple measures as a way of expanding the data set and information that we know about both school and student success.  Education equity attorney Mike Rebell recommends that the federal government hold schools accountable for factors other than test scores.¹⁰  Schools need the overt support from ED 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.  See¹¹
• student progress over time
• social and emotional health
• inclusion of the arts, civic education meaningful service learning
• 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

 
Recommendation:
Add to read:
Increase the use of research based instructional improvement systems 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. 

Proposed Priority 3--Innovations That Complement the Implementation of High Standards and High-Quality Assessments
p. 52218
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.  It also supports the Department's emphasis on the development high quality assessments and information building toward college access and career readiness.  PEN also supports the expansion of data to 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
• develops information and data on college access and career readiness

 
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 locally-based 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. 
  
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.  As Chicago's public school CEO, you had numerous initiatives partnering with your district that served to enhance the academic success of your students.  For example, one of those organizations that you know well is the Healthy Schools Campaign where families, students, community members, individual citizens had a voice in decisions that affected the school environment, and that empowered the community to take action.¹² This is a campaign that shares information it collects with other school external partners as permissible and uses 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:
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 LEAs and local partners apply for Investing in Innovation:

• Based on state and local need, a portion of the I-3 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. 
• I-3 monies should be used to find innovative means of providing 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.
• Translate effectively the information from the standards and assessments to families, community members, community-based organizations, the media and other stakeholders about the meaning of the data, how it can be used to improve instruction, and increasing the understanding about what changes and interventions need to be undertaken based on the data. 

Recommendation:
That states develop an "Opportunity to Learn Index,"¹³ 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 local school districts 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 Education, which can be used in conjunction with the "Opportunity to Learn Index."¹⁴

Proposed Absolute Priority 4-Innovations That Turn around Persistently Low-Performing Schools
p. 52218
Comments
PEN supports the Department's focus on persistently low-performing schools and the references to extended learning time, integrating student supports to address non-academic barriers to student achievement.  These are to be commended and PEN supports these elements as important to turning around struggling schools. 

Recommendation:
Statement of Proposed Absolute Priority 4
p. 52218
(b) 2
Recommendation:
Add to the list: (4) building partnerships between the school, district, and non-profit partners to enhance communication and engagement of families; translate data into understandable information; develop a school improvement team charged with developing a school improvement plan that must include families of the turn around school and community members; and connecting families and schools to overcome learning barriers.

In addition, PEN proposes that additional points be given to applicants who include innovation proposals under (a) whole school reform.  By focusing on the whole school, this priority should reward school districts and local communities who think 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, such as

• 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, and school program evaluation¹⁵
• 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.

 
While research may be sparse on providing guidance about how to turn around struggling and difficult schools, PEN recommends that any innovative proposal needs to confront culture, structure, policies, personnel, time, coverage, and instruction as a whole.  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, school climate, 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.  The challenge of making the school better where the students are at seems to be a more productive strategy than sending students to another school or shutting the school down.

Proposed Competitive Preference 6--Innovations That Support College Access and Success
p. 52219
Comments:
As stated at the outset, PEN has just recently finalized a major Network goal that strives 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 local education funds serve.  PEN supports this I-3 priority, and commends the Department in adding it as a priority.  Yes once again, we know that the community and parents need to be essential partners with their school district and schools of higher education early in a student's educational; career.¹⁶

Statement of proposed Competitive Preference Priority 6
p. 52219
Recommendations:
Based on our local education fund experiences and research, PEN proposes to add to the list of strategies, practices or programs that must be addressed the following:

• tracking comprehensive outcomes with frequent benchmarking of students progress on the road to college or a career;
• involve families and parents early in a student's career about college and career pathways, course mandates, and consistent data about student progress; 
• build parent and community will and commitment to staying the course;
• employ research validated methods or testing innovations aimed at improving college and/or career opportunities; develop knowledge and intellectual community partnerships committed to increasing college and career ready students;
• develop a data system that is able to measure whether students are college and career ready;

Recommendations:
PEN recommends that the following data be collected on a longitudinal basis to measure and report performance on college and career readiness:¹⁷

• percent and number of additional low-income/minority ninth graders who graduate college and career ready in four 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
• on-track metrics such as college preparatory course work in key subjects such as Algebra, GPAs, and credit accumulation; high school graduation rates;
• college acceptance, enrollment, and persistence rates
• student participation in college access, such as counseling, college visits

In addition, PEN recommends that when focusing on college and career readiness, that school districts with community partnership develop metrics, indicators and a report card which tracks the following student information and progress from the early years to college or a career:

1. Preparation for school
2. Every child will be supported in and out of school
3. Every child will succeed academically
4. Every student will enroll in college
5. Every student graduates and enters a career

 
This is based on a project led and coordinated by PEN Network member, STRIVE serving Cincinnati and Northern Kentucky.¹⁸

Definitions
Recommendation:
Clarification:
ED needs to clarify:
How should the sentence "approach has not already been widely adopted" be interpreted?  Does it mean not widely adopted at the level to which it would be scaled up, e.g., for a validation grant, adopted locally but not yet regionally? 

When ED requires that a grant demonstrate "strength of research" and a requirement for the applicant to: demonstrate there are "research-based findings or reasonable hypotheses" that support the project," does this mean that prior results from the program itself can be used as evidence?
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 Investment in Innovation 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.  I-3 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."¹⁹  In our view, Investing in Innovation 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 I-3 objectives.   
 
Sincerely,

Wendy D.  Puriefoy, President and CEO
Public Education Network
 
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1 Public Education Network also supports comments which are interwoven throughout this submission submitted by the Coalition for Community Schools; National Family, School, and Community Engagement Working Group; the National School Climate Council and United Voices for Education.

2 "Organized Communities, Stronger Schools, Annenberg Institute for School Reform at Brown University, March 2008.

3 "A Look at Community Schools," Center for American Progress, Saba Bireda, October 2009.

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

5 "Strategic Interventions for Community Change: Communities at Work," funded by the MetLife Foundation, Public Education Network.

6 Schools, Families, and Community Working Together: Building an Effective Collaborative, Howard Adelman and Linda Taylor
online at: http://smhp.psych.ucla.edu/pdfdocs/buildingeffectivecollab.pdf

7 $10 million dollars has been appropriated for this measure by the House Appropriations Committee in the 2010 Federal Budget.

8 "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.

9 Teacher Preparation: Reforming the Uncertain Profession, October 22, 2009.  Speech by U.S. Secretary of Education, Arne Duncan.

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

11 "The School Climate Challenge: A White Paper," a project of the National Center on Social and Emotional Education, with the National School Climate Council and the Education Commission of the States; see also, Social and Emotional Learning and Student Benefits, National Center for Mental Health Promotion and Youth Violence Prevention, Education Development Center, 2008

12 "Healthy and Ready to Learn:  Lessons from Chicago,"  Healthyu Schools Campaign, March 2009.

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

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

15 Keeping Parents and Communities Engaged (PACE) Act.

16 "Laying the Groundwork:  The Constant Gardening of Community-University-School Partnerships for Postsecondary and Success," Collins, Weinbam, Ramon, and Vaughan, Academy for Educational Development, 2009.

17 Based on PEN's 2010 strategic plan; the work and research of 6 local education funds engaged in a Post Secondary Success Program funded by Citi including the following LEFs: The Education Fund of Miami, FL, Philadelphia Education Fund, Philadelphia, PA, San Francisco Education Fund, San Francisco, CA, Chattanooga-Hamilton County Public Education Foundation, Chattanooga, TN, San Antonio Education Partnership, San Antonio, TX; and the KnowHow2Go Initiative funded by Lumina including the following LEFs: Chattanooga-Hamilton County Public Education Foundation, in collaboration with Tennessee Higher Education Commission Chattanooga, TN, Los Angeles  Education Partnership, in collaboration with Southern California College Access Network, Los Angeles, CA, Alliance for Education, in collaboration with Northwest Education Loan Association, Seattle, WA, Foundation for Lincoln Public Schools, in collaboration with EducationQuest Lincoln, NE, and Hillsborough Education Foundation, in collaboration with University of South Florida, Tampa, FL
 

18 Striving Together: Report Card, A Student Progress on the Roadmap to Success, Cincinnati, Ohio 2009.

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