Tuesday, November 3, 2009

Opportunity to Shape Federal Policy: Comment on Education's Innovation Fund Before November 9th, 2009

Hi all -- There is a great opportunity to shape federal policy and the types of innovations that are selected through the US Department of Education's Innovation Fund (often referred to as I3). The Notice of Policy Priorities (NPP) is now out and we can influence it by coordinating our responses and organizing a heavy influx of comments. Whenever possible, ask people to co-sign a comment submission so that we do not make the administration's job more difficult. In addition, it will demonstrate that we are coordinate.

I have prepared some background information for you to make it easier for you and your networks to respond. See below.

You will see when you read the NPP that advocates for vulnerable youth have already had substantial influence. In your comments, please include a recognition of the Department's leadership by including the following policies in the Innovation Fund:

Page 52221: The definition of high needs students includes " students who are far below grade level, who are over-aged and under credited, who have left school before receiving a regular high school diploma, who are at risk of not graduating with a regular high school diploma on time, who are homelessness, who are in foster care, who have been incarcerated, who have disabilities, or who are limited English proficient."

Page 52218: Under Absolute Priority 4- Innovations that Turn Around Persistently Low-Performing Schools: " Creating multiple pathways for students to earn regular high school diplomas (eg. transfer schools, awarding credit-based on demonstrated evidence of student competency, offering dual enrollment options." Multiple pathways are critical to support youth in child welfare and juvenile justice as they are likely to have been held back in previous years, entering high school "over-aged". In addition, multiple pathways should offer high quality, student-centered schools that provide adequate enrichment, counseling and support services to help young people overcome other barriers that are making it difficult to stay engaged in school.

Please do not hesitate to contact me if you want to talk about any of these comments. Or if you have other ideas that you would like circulated, I will add them to my blog http://metisnet.blogspot.com/

Chris Sturgis

Directions for Submitting Comments:

1) Click here to get to the website for comments on government regulations. Or cut and paste the following url into your web browser:

2) You can download a copy of the Notice of Policy Priorities on the US Department of Education Innovation Fund. I am sure as you read it you will see other ways to strengthen it in addition to the items I have listed below.

3) Towards upper right you will see "Submit a Comment". Click on that and then fill out the information requested

4) On the right you may type your comments or upload a file (or both).

The Most Important Comment That We All Should Make (you can cut and paste...but I encourage you to add your own two cents so that they aren't all exactly alike)

1) Add a competitive priority for youth who are over-aged and under credited, who have left school before receiving a regular high school diploma, who are at risk of not graduating with a regular high school diploma on time, who are homelessness, who are in foster care, who have been incarcerated.

First let me commend the Department of Education for including youth who are over-aged and under credited, who have left school before receiving a regular high school diploma, who are at risk of not graduating with a regular high school diploma on time, who are homelessness, who are in foster care, who have been incarcerated as part of the definition of high needs students. Yet, I (we) believe that we need to do more than include them in the high needs group, we need to make them a priority for our nation, our states, our districts and our schools.

There are many reasons to include this group as a priority in the Innovation Fund. The most important reason is that in developing and expanding our capacity to serve this group of students we will also open the door to the greatest innovations. As Harvard Business School professor Clayton Christensen has pointed out, disruptive innovation theory suggests that it is within under-served markets that we have the most room for innovation. Rarely do LEA's make this group of students a priority -- thus there is more room for innovation. As the administration knows well, the needs of the off-track students, whether they are still in school or have disengaged, is also the segments of students that will directly benefit from the innovations of customized learning, competency-based instruction, assessments and credits as well as more modularized ways of structuring learning. Second, the needs of this group must be addressed in order to increase our graduation rates. By developing and expanding high quality opportunities for this group of students, the knowledge will be acquired to finally bring our high schools into the 21st century.

It is also important to include this group as a priority because it will shape the thinking of the innovations with the four absolute priorities. Each of the four absolute priorities are based upon assumptions of the current system of delivery of teaching and learning. By identifying this group of students as a priority, we can begin to see the type of intra-agency and inter-agency partnerships that lead to systemic reforms across our public sector. Finally, by identifying this group as a priority, it is more likely that you will see competency-based innovations that are crucial for moving our system beyond the constraint of the Carnegie unit.

This new priority should include innovations in delivering literacy for high school age students performing at elementary school level regardless if they should be served by the LEA, through adult education, or developmental education at the community college. The growing pool of youth that cannot take advantage of GED, youth employment or community college are often ignored in conversations about college-readiness as they are so far from even high school readiness. This new priority can give room to educational challenges that face our cities and rural areas alike.

Suggestions for Points You May Want to Include

1) Add a definition of transfer schools. (p. 52218, Absolute Priority 4)

The term transfer school is unique to New York City. It is important that you add a definition of transfer school so that others not familiar with there model or that term understand the priority. The priority should not be limited only to the transfer school model of partnerships between community-based youth organizations and the district as many communities do not have the richness of the cbo community, especially in rural communities. The definition of transfer school might include: small, student-centered, designed for students to get a diploma but may include GED options as well, offers a range of services including counseling, work experience, service learning, tutoring, and includes a future focus that broadens students' horizons for career and college awareness and transition.

2) Explicitly expand partnerships beyond LEA to include other institutions of education.

The expectation that applicants must be working in partnership with LEA is restrictive when it comes to innovation related to off-track, out of school, and students that have been under the child welfare and juvenile justice systems as well as other students with high mobility. First, LEA's by nature often fail to educate off-track youth, in or out of school. To require the LEA without alternatives for partners immediately reduces the likelihood that off-track youth will benefit from innovations or innovations that address the needs of this group of young people will be able to meet the requirements. Second, in the cases of students with high mobility, there is often a different type of partner that is not as limited by geography needed as students move between facilities, placements, and schools. Community colleges or county education institutions can be valuable partners in innovations that serve these populations.

3) Explicitly state that innovations include developing and expanding college-ready GED programs .

Given that high needs students include those who are over-aged and under credited, who have left school before receiving a regular high school diploma, who are at risk of not graduating with a regular high school diploma on time, who are homelessness, who are in foster care, who have been incarcerated that the issue of the GED will arise. At a minimum, innovations serving this group of students should acknowledge that some portion of the students will choose to complete a GED rather than a diploma.

Although we all would like to see our high schools perform such that young people would not need to look towards a GED as an option, the fact of the matter that the GED is currently recognized as equivalent to a diploma. Certainly we can agree that the GED is not preparing our students for college, but neither is a diploma. It is important that the innovations shaped to serve the students that are falling off-track to graduation be fully grounded in the dynamics of what is meaningful to students. For some students, a GED is the more meaningful pathway and that choice needs to be available. In addition, in order to meet the President's goals, we are going to need to develop GED to college pathways.

Again, it is important that the innovations add to our knowledge of how to improve the K-12 system and increase our high school graduation rates. Yet, it is equally important, that we ensure that students have choices and that multiple pathways are designed to meet a full spectrum of needs.

4) Absolute Priority 1 Should Encourage Broader Methods to Deliver High Quality Content

Although it is critically important to improve the effectiveness our teaching force, for high school students in rural communities, in small schools, in transfer (alternative) schools, and in detention, it is unlikely that they will have teachers prepared to offer high level college-ready curriculum across all the disciplines. Simply, there are structural constraints that are beyond how we prepare, support, and evaluate teacher performance. Thus, it is important that this priority give some recognition that we need alternative approaches, especially as they relate to STEM disciplines.

5) Absolute Priority 2 Should Include District-Level Data Analysis including Segmentation of Entire Cohort and Planning for Portfolio of Options

The district is the primary unit of change for increasing graduation rates. Thus, the role of the district in addressing the dropout crisis must be encouraged. As the cities that are working to increase their graduation rates through multiple pathways (NYC, Chicago, Mobile, Philadelphia, Portland, Boston, Brockton) have learned, the data analysis of segmentation to understand the dynamics underlying their dropout crisis and the planning for providing adequate educational programming to meet the needs of students that have fallen off-track is a critical step.

6) Proposed Competitive Priority 6 College Access and Support Should Include GED to College

The focus on students in K-12 system means that those program providers that offer educational pathways to off-track students through adult education and GED may not apply for innovations. Given the scope of the dropout crisis in our largest cities and the disproportionate degree that our young men of color bear the burden of our failed systems, it is critical that we allow innovations to develop in the pathways funded through adult education managed by the Department of Education and youth programming managed by the Department of Labor.

7) Add "flexibility" under Absolute Priority 4 (b) (1)

We agree that it is important to add more learning opportunities. But it is equally important to have greater flexibility in how students take advantage of core academics, enrichment, and support services. For some older students, less may be more, in that they can blend work and learning.