August 28, 2009
Office of Elementary and Secondary Education
Dear Secretary Duncan:
The Aspen Institute’s Commission on No Child Left Behind appreciates the opportunity to comment on the Department’s proposed regulations on the Race to the Top Fund (RTTT) under the American Recovery and Reinvestment Act (ARRA). RTTT has already motivated some states to remove or weaken barriers to educational opportunity and improvement in order to meet the anticipated requirements of these regulations. If implemented well at every level, RTTT could spur a great deal more such activity and demonstrate to the nation what is possible with leadership, determination, and a relentless commitment to results for students.
We are pleased that the Administration’s draft reflects a strong commitment to accelerating progress toward what we believe are the right goals for education reform—higher academic achievement, improved graduation rates, and narrowed achievement gaps. Indeed, the policy priorities at the heart of the proposed RTTT requirements—the four education reform “assurances” required under ARRA—mirror those set forth in Beyond NCLB, the Commission’s 2007 ESEA reauthorization blueprint: stronger academic standards and assessments, more sophisticated use of data to drive decisions, improved teacher effectiveness, and aggressive action in low-performing schools. By requiring states to demonstrate significant progress in all of these areas—which our research and experience have shown to be mutually reinforcing and critical to improving education—the Department is setting a much higher bar for state applications under RTTT than is typical of competitive grant programs.
The Commission is also pleased that the draft includes a requirement for states to improve academic standards by participating in a consortium with other states to develop and adopt common core standards by 2010. When the Commission released our initial ESEA recommendations more than two years ago, the creation of model national standards was one of our highest priorities. We are hopeful that with support from the Administration and key partners, states can develop and implement high-quality common standards, which will ultimately provide a more rigorous and globally competitive education to students no matter where they live.
The emphasis on data throughout the proposed regulations is an important and needed step forward for education reform. We particularly support the draft’s focus on incorporating student growth data into decisions regarding evaluation, compensation, and support of teachers and principals, as the Commission has recommended. Ensuring that teachers receive timely and constructive feedback and targeted professional development—rooted in, though not limited to data—is critical to improving teacher effectiveness, quality of instruction, and ultimately student achievement.
While these and other provisions of the proposed regulations are strong, the Commission has several important concerns detailed below.
Clarify the Importance of Continued Strong Accountability
The Commission urges the Department to remove from the “Reform Plan Criteria” the “ambitious but achievable” standard for states’ annual performance targets, which will incent states to set a low bar and weaken current ESEA accountability provisions. Without clarification, the regulations could encourage the creation of an alternate accountability system pegged to “ambitious but achievable” RTTT goals and thereby dilute ESEA’s focus on reading and math proficiency. States should be required to include in their RTTT performance reporting the extent to which they have met or exceeded their current Adequate Yearly Progress targets.
Strengthen Student Options
While the draft’s provisions regarding turning around struggling schools are generally strong, the Commission believes more must be done to promote options for students in those schools. Specifically, the Department should specify that a state will lose application points if it fails to effectively implement ESEA’s current requirements to provide public school choice and supplemental educational services for children attending low-performing schools.
Given the amount of funding at stake and the temptation on the part of states and districts to use ARRA funding to fill budget gaps and maintain the status quo—their application rhetoric aside—the Commission believes that increasing transparency is critical to effective RTTT implementation. By posting all initial and approved state applications and progress reports online in a timely manner, the Department can help interested groups maintain pressure on states to meet their stated goals.
Set the Stage for ESEA
As you know, how well RTTT is implemented will have major implications for ESEA reauthorization. We are very concerned that poor state or local implementation could not only waste funding, but also jeopardize support for and progress on RTTT priorities in the reauthorization of ESEA. In addition to increasing transparency as noted above, we encourage the Department to withhold funding from states that fail to meet their RTTT commitments. It is our hope that with aggressive oversight from the Department and the public, states and districts receiving RTTT funding will become models from which to build and learn in ESEA.
The Commission recently announced a series of public hearings to inform updated ESEA recommendations that reflect the many changes in the education landscape since the release of our 2007 report. The topics on which our hearings will focus align with the RTTT priorities, all of which are central to strengthening ESEA. We will be certain to share our findings from the hearings and the lessons they may hold for implementation of RTTT and ARRA.
Thank you for consideration of our views. The Commission looks forward to working with you to advance our shared education reform priorities during the implementation of RTTT and ARRA, as well as the reauthorization of ESEA.
Commission on No Child Left Behind