U.S. Department of Education
400 Maryland Avenue, SW, Room 6W231
Washington, DC 20202
Docket ID ED-2017-OS-0078
Dear Ms. Bell-Ellwanger:
I am writing to provide the comments of Chiefs for Change on the Secretary’s Proposed Supplemental Priorities and Definitions for Discretionary Grant Programs, as published in the October 12 Federal Register. Chiefs for Change is a coalition of 26 state and district education Chiefs dedicated to excellence and equity for all students. Chiefs for Change members lead education systems serving 5.3 million students, 330,000 teachers, and 10,000 schools. We advocate for the policies and practices working for students, facilitate peer-to-peer advising among our members, and develop and support a pipeline of the next generation of Chiefs. We are guided by a set of shared beliefs that are grounded in the vision that all American children can lead fulfilling self-determined lives as adults.
Chiefs for Change supports the thrust of the 11 supplemental priorities put forward by the U.S. Department of Education (the Department), such as those that would support better opportunities for historically underserved populations; improvement in science, technology, engineering, and technology (STEM) education; stronger teaching and school leadership; and education as a vehicle for expanded economic opportunities. Particularly, we strongly support the priorities and subpriorities focused on pathways for teachers to lead both in and outside of the classroom and those related to innovation, efficiency, and reducing burden, as we have numerous members who have been leading promising initiatives in those areas.
Chiefs for Change members have invested in teacher leadership as an important way to elevate the impact of educators while supporting them to remain in the classroom. Over two thirds of our members are former teachers and know firsthand the impact that effective educators can have in supporting policy and practice. Numerous Chiefs for Change members have developed promising models for this work, as we describe in a recent policy brief. Specifically, Louisiana, Tennessee, and New Mexico have all developed robust teacher leadership models that empower effective educators to provide expertise and leadership on key issues around curriculum, instruction, professional learning, and other important policies and practices. We commend the Department for recognizing the importance of this work, and encourage the Department to think expansively about the programs in which this subpriority can be applied.
In addition, Chiefs for Change has been a national leader in encouraging and bringing to the forefront innovative models for expanding educational choice within the public K-12 system, and thus we agree with the Department’s proposal to make expansion of choice one of the Secretary’s priorities. Because of our particular interest in and experience with choice, we offer the following more detailed comments on that proposed priority.
In May, Chiefs for Change released our statement on school choice, which emphasized that school choice initiatives have the potential to dramatically expand opportunity for disadvantaged children and their families and that a meaningful amount of school choice is an essential ingredient for any system to stay innovative, vibrant, and responsive to the families and communities it exists to serve. We are pleased to see the definition of “educational choice” in the proposed priorities is one that includes instructional choice for students, including through programs such as accelerated learning, dual enrollment, and career preparation. We believe that there is tremendous opportunity to advance this type of instructional choice through Direct Student Services (DSS) and have developed numerous tools and resources to help states take advantage of this opportunity to expand choice. We are excited that Louisiana and New Mexico have committed to implementing this program as part of their ESSA plans.
Further, the experiences of our states and districts in implementing a wide variety of school choice initiatives have demonstrated that certain common elements must be in place in order to catalyze the expansion of quality school choices and provide for their sustainable management and governance at scale. Our members at both the state and district level have demonstrated leadership on this across the country, including in Louisiana, Denver, Indianapolis, and DC.
The first of these common elements is that there must be an assurance of fairness in admissions and enrollment. Students from low-income families, students with disabilities, English learners, and other members of historically underserved populations must be given clear and unambiguous rights to enroll in all schools, and schools should be obligated to serve them and held accountable for serving them well. Toward that end, we recommend that either Proposed Priority 1 (Empowering Families to Choose a High-Quality Education that Meets Their Child’s Unique Needs) or the accompanying definition of “educational choice” be amended to ensure that any grant competitions making use of the priority support schools and programs that serve all student populations and are held accountable for doing so.
Secondly, school choice programs must have an assurance of quality. We believe the goal of school choice programs is not simply choice; it is improved access to high-quality schools, and this goal will not be achieved if policy-makers do not provide incentives and supports to ensure that educational choice options are high-quality. In addition, we believe a positive choice context must also provide clear information to policymakers and parents to allow them to know how students are learning in ways that are transparent, unambiguous, and comparable from one school to the next. The Department’s proposed “educational choice” definition provides that a choice program must give students the opportunity to create a learning path that “where possible, incorporates evidence-based activities.” This is an acknowledgement of the need for educational interventions of proven quality, but we further recommend the Department give the highest priority to applications that demonstrate the strongest evidence of quality (and not just for certain activities to be carried out as part of a program, but for the program in general). Additionally, when the Department makes use of Proposed Priority 1 for a particular competition, all grantees receiving that priority should measure student learning and other outcomes using common metrics that enable comparison both across the grants and with matched schools not implementing comparable interventions.
Finally, our third principle is that school choice initiatives must include an assurance of equitable distribution of resources across participating schools, with those schools serving students with the most intensive needs receiving resources proportionate to that challenge. Again, we recognize that educational choice initiatives will take many forms, so we are not proposing strict mathematical calculations that might dissuade states and districts from undertaking promising innovations. But we do recommend as an addition to Priority 1 that any choice initiative funded under the priority include a funding mechanism, such as weighted student funding or a similar procedure, that ensures equity in the distribution of resources.
Thank you for the opportunity to comment on these important priorities. If Chiefs for Change can be of any assistance in formulating the final version of the priorities, please do not hesitate to contact me.
ABOUT CHIEFS FOR CHANGE
Chiefs for Change is a coalition of state and district education Chiefs dedicated to excellence and equity for all students. Chiefs for Change members lead education systems serving 5.3 million students, 330,000 teachers, and 10,000 schools.