October 8, 2014
Ms. Elizabeth Ross
U.S. Department of Education
400 Maryland Avenue, SW
Room 3C116
Washington, DC 20202
Dear Ms. Ross:
Knowledge Alliance – a non-profit, non-partisan organization composed of leading education
organizations involved in high-quality research, technical assistance and evaluation – is pleased
to comment on the U.S. Department of Education’s proposed rules for the School Improvement
Grant (SIG) program, as published in the September 8, 2014 Federal Register.
Knowledge Alliance finds much to commend in the proposed regulations, including the addition
of three new school turnaround models, the authorization of five-year awards to local educational
agencies (LEAs) and the continued emphasis on high-quality professional development,
evaluation and implementation of research-based practices across all the program models. We
believe that the proposed rules will give states and LEAs useful flexibility in implementing SIG
while maintaining an appropriate focus on doing what works.
We recommend amendments to the proposed regulations in the following three areas.
•
Allow more than a single state-determined intervention strategy, and
provide states more flexibility in developing such models
The proposed rules would permit a state educational agency (SEA) to submit for the
Department’s approval only a single state-determined strategy, even though the appropriations
language authorizing such strategies would allow multiple strategies within a state. Based on the
experiences of our member organizations, such as those that operate the Regional Educational
Laboratories and Comprehensive Centers, in working with SEAs and LEAs on the
implementation of educational reforms, we believe it would be more beneficial to the program to
allow states to seek approval for a menu of strategies from which they and their LEAs could
select based on specific circumstances and needs. Given the diversity of schools and school
populations present within a state, it is unlikely that there will be a single turnaround strategy
that works in every context. We therefore recommend that the Department, in section II.B.1(b),
change “one State-determined model” to “one or more State-determined models.”
For the same reason (that is, in order to permit states and LEAs to tailor interventions to the
particular needs of a school and its students), we also recommend that the regulations authorize
states to seek approval of an intervention model that does not necessarily meet all of the
requirements listed in the propose regulations. Specifically, in section II.B(1), we recommend
inserting a new subsection (c) reading as follows:
“(c) An SEA may also submit one or more State-determined intervention models for the
Secretary’s review and approval that do not meet all of the requirements of (b).”
•
Emphasize the importance of professional development for school leaders
Our member organizations that have worked closely with schools and LEAs on turnaround
efforts have consistently identified professional development of the school principal and other
school leaders as a key element in successful implementation; this is particularly the case if a
new principal is in place, as would be required under three of the models. The same standards
that the Department has identified as essential for the professional development of teachers in
turnaround schools – that it be high quality, job-embedded, aligned with the school’s
comprehensive program, and specifically designed to support implementation of the turnaround
strategy – are also essential for the development of principals and other school leaders.
Yet the proposed rules do not call specifically for school leader professional development as a
mandatory element of the turnaround models. Instead the rules require “staff” professional
development, which schools and LEAs might interpret as not necessarily including training for
the principals. Because we believe that turnaround efforts are unlikely to succeed if the principal
and other school leaders do not receive professional development and support, we recommend
that “Provide staff ongoing, high-quality job-embedded professional development” be changed
to “Provide teachers, the principal, and other school leaders with ongoing, high-quality, jobembedded professional development” under the Turnaround model (section I.A.2(a)(1)(D)), the
Transformation model (section I.A.2(d)(2)(A)(iii)), and the Early Learning model (section
I.A.2(f)(8)). In addition, regarding the requirements for the state-determined intervention model,
we recommend that section II.B.1(b)(2)(C) be revised as follows:
“(C) Providing teachers, the principal, and other school leaders with job-embedded,
ongoing professional development informed by the school’s teacher and school leader
evaluation and support systems and tied to teacher, school leader, and student needs;”
•
Strengthen the language on evaluation
The SIG program will likely not attain its full potential unless there is careful evaluation of the
implementation and impact of turnaround strategies, with the objective of determining not just
what works but why. Under the proposed regulations, SEAs would be authorized to reserve up to
five percent of their formula allocations for administration, evaluation, and technical assistance.
Because of the competing demands for administration and technical assistance, it seems
uncertain that states will carry out rigorous evaluations of SIG activities using these set-aside
funds. Moreover, under only one of the seven turnaround models (the Early Learning model) is
evaluation a mandated component. In order to address the critical need for evaluation of SIG
activities, we recommend that the Department require LEAs to provide for rigorous, independent
evaluations of their SIG projects, and require that SEAs ensure that local budgets for SIG include
sufficient funding to support evaluation activities. Specifically, we recommend the following
amendments:
•
In section II.A, insert a new paragraph (10) as follows:
“(10) The LEA must provide for the completion of a rigorous independent
evaluation of the implementation and impact of the services and activities
supported with School Improvement Grants in each of its participating schools,
and must include sufficient funding for such evaluations in its budget.”
•
Amend section II.B.(2)(b)(4) as follows:
“(4) Whether the LEA has submitted a budget that includes sufficient funds to
implement the selected intervention fully and effectively in each school it
identifies in its application, as well as sufficient funding for a rigorous
independent evaluation of the implementation and impact of the services and
activities supported with those funds in each such school.”
In addition to making the above recommendations for modifications to the proposed rule,
Knowledge Alliance would like to emphasize the need for careful attention to high-quality
implementation of any of the turnaround models. Our member organizations, in their work with
schools and LEAs over many years, have found that regulatory requirements by themselves do
not drive quality and outcomes. Merely requiring that schools provide for on-going parent and
community involvement does not mean that parents will be meaningfully involved in school
reform efforts or that a school will draw on community resources in implementing its turnaround
plan. A regulation that school staff receive “high-quality professional development” will not, by
itself, ensure that teachers and school leaders receive the support they need in understanding and
effectively implementing a turnaround model. Requiring LEAs to provide for evaluations of their
projects, as we recommend above, will not guarantee that those evaluations are carried out in a
timely and responsible manner. Thus we urge the Department, through its application review,
monitoring and technical assistance activities, to make a strong effort to ensure that SIG projects
are implemented in a manner intended by the regulations and with fidelity to research-based
models.
Timing is a factor that our members have identified as particularly critical. For example,
sometimes we have seen an LEA meet the requirement for replacement of the principal by
putting a new principal in place not until the school year is about to begin, or even later. That
sort of failure in timely implementation almost always has serious implications for the successful
implementation of new reforms. Thus we recommend that the Department pay particular
attention to ensuring that the elements of the individual SIG models are put in place in schools
on a timeline that fully supports successful implementation and higher outcomes.
Thank you for the opportunity to comment on these proposed regulations. Knowledge Alliance
fully supports the SIG program’s objective of dramatically improving the education received by
children attending the nation’s lowest-performing schools. Our member organizations, which
have decades of successful experience is assisting with the successful delivery of school
turnaround efforts, stand ready to support the Department and states in bringing the goals of the
revised program to fruition. Please contact me if we can be of any assistance.
Sincerely,
Michele McLaughlin
President