It's official: The comment period is now closed (as of 5 p.m. Friday) on the U.S. Department of Education's proposed rules for the nearly $400 million Race to the Top for districts competition.
So far, the department has received hundreds of comments, from the big organizations representing governors, state schools chiefs, and state and local school board members to well-known think tanks, like the Center for American Progress, and random interested folks who just go by their first names, Madonna-style. UPDATE:The department estimated Saturday that there were between 450 and 500 comments.
Here's a sampling of what's being said so far:
• Three big-deal groups representing state lawmakers and education officials—the National Governors' Association, the Council of Chief State School Officers, and the National Association of State Boards of Education—put out a joint critique that says, basically, "Don't Tread On Me."
Okay, the language is a bit fancier than that. "We do not support directing limited federal funds to a district-based competition driven by prescriptive priorities," the groups write. Instead, they want to be sure that district applications are consistent with state laws and regulations. In fact, they think state attorneys general should have to sign off on the applications.
The groups also say giving states just five days to review and comment on district applications isn't going to cut it. Instead, they want at least 30 days. And they point out that district support was big component in which states scored high in other rounds of Race to the Top. They think states should get the same consideration this time. They also don't want to see district applications impose new requirements on states.
• The first recommendation from the National School Boards Association, which represents local districts? Eliminate the whole school boards evaluation requirement in the framework. Also, eliminate the requirement that state officials and mayors get a chance to comment on applications. The competition is supposed to be school district-led, NSBA argues, and the group sees this requirement as just a bureaucratic and burdensome step for applicants. Plus, the group says, local government officials may not have the education policy expertise to fairly review applications. And states, NSBA says, shouldn't need to comment because they're not responsible for education at the local level.
• The American Federation of Teachers has a bone to pick with the department on that whole school board evaluation thing, too.
"It is not lost on us that while teacher evaluations must include student growth measures, including state standardized tests if they are available, evaluations for [school boards and superintendents] must only include an undefined 'student outcomes performance.' The difference in treatment is striking," AFT writes.
•The American Association of School Administrators is seeking clarification on the idea of "personalized learning plans." These are the name of the game since all applicants must make them a central part of their plans. AASA has some questions about what exactly the department has in mind.
"The definition within the criteria is vague and not common in the school/educator community," AASA writes. The group wants to know how these plans are actually different from techniques such as differentiated learning, Response to Intervention, or individualized instruction. It has asked just who is responsible for reviewing and updating the personalized learning plans and how often that has to happen. The group also is wondering if schools will have legal liability for personalized learning plans, like they do for individualized education programs for students in special education.
• The Association for Career and Technical Education and the National Association of State Directors of Career Technical Education Consortium want to see more focus on student employability and technical skills, as well as applying academic knowledge in a real world setting.
• The Los Angeles School District, widely considered a prime candidate for a grant, thinks the proposed budget numbers are way too low and unfairly penalize large districts. It wants a new tier of grants, for districts with more than 50,000 students, which could be eligible for grants of $40 to $50 million. The district is also a bit mystified by the whole school board evaluation idea, since its school board members have to face public elections. And the Los Angeles district is not sure it will be able to meet the requirement to have a data system that can track students P-16 outcomes, since some students go to college out of state.
• The National Association of Public Charter Schools says that a lot of charter schools might get left out of the competition because the threshold for participation is way too high. In fact, less than 2 percent of charters organizations are able to meet the 2,500-student minimum, the group points out.
• The Education Trust, which looks out for poor and minority students, thinks districts should be judged on equity, including whether high- and low-poverty schools have equal access to money, good teachers, rigorous classes, and similar discipline practices.
• The Center for American Progress, a progressive think tank, found a lot to like in the guidelines, but wonders if a 40 percent poverty threshold is high enough to make sure the new grants are really targeted to disadvantaged students.
• A bunch of entrepreneurial organizations, including the NewSchools Venture fund, want the department to make sure nonprofit organizations can partner with district applicants. And they want a bigger focus on applicants working with teacher-training programs that can help prepare educators to serve in personalized learning environments. Way more here. And the Huffington Post has a good analysis of this.
• A number of experts on early-childhood education, including the New America Foundation's Lisa Guernsey, point out that the guidelines are really seeking systemic changes on K-12. The department needs to do a better job of getting districts to align those changes with early education. For instance, applicants that focus on the early years should get extra points for expanding access to high-quality pre-kindergarten, as well as full-day kindergarten.
• Members of Congress from Guam, American Samoa, the Commonwealth of the Northern Mariana Islands, and the U.S. Virgin Islands want their districts to get in on the competition.
•Tons and tons of commenters were really disappointed there wasn't more of a focus on physical education in the rules. The best is from Richard Simmons of "Sweatin' to the Oldies" fame.
"Good health, high self-esteem, and the energy and focus to do our best ... come from being fit and living healthy," he writes. (This isn't his first foray into education policy.)
The department has said it will take comments into consideration when crafting the final applications, which will be available in mid-July. Districts will apply in October. The money itself has to go out the door by the end of December.