First of all kudos to the Dept. of Education staff for putting out these regulation and largely sticking to a reform agenda while making reasonable adjustments. While some technical details caught my attention like the myopic calculation of ensuring that education is a funding priority, I found myself agreeing with most of the priorities the regulations lay out. Here are several unconnected thoughts on them.

Most Funding Should Go Out in Round 2. I had expected the Department to message that only the very best states will get funding in the first round to give states time to enact the difficult reforms included in RTT. But, maybe that messaging comes later, after states have put in the difficult work to apply for the first round. States need time to make the changes that this type of program requires, and only 10 state legislatures have been in session over the period since the draft regulations were released at the end of July. Most state legislatures will be back in session in early Jan, but that will be too late to get something done by the round 1 deadline. And 10 states will not be in session until after the Jan 19^th deadline. Now some of these policies can be implemented administratively, but many can not. Legislatures will need time to pass the type of laws that would make a state competitive. And certainly you would want the legislature involved in “articulating the state’s reform agenda” and ensuring that a state is headed in a strategic reform direction. So, you would hope that the department would only give funding out to a few outstanding states, and send a serious message to states about what they needed to get done by round 2 so that they were evaluated on their policy changes instead of their proposals. 

Common Standards Have Timing Problem. 70 points (14 percent) will be awarded for committing to the adoption of common standards and related assessment work. Unfortunately, the applicants will likely be asked to commit to these standards without much of a chance to even take a look at them beforehand. Now everyone has had a look at the draft of the college and career standards (what kids will need to know by the end of high school). And, maybe these will be revised by Jan 19^th, but I would not count on it. And, just last week (Nov 10^th) Common Core announced its working group to put together the K-12 (grade-by-grade) draft standards that will explain how states would have to move students through each grade. There will need to be a lot of discussion about how specific these are, and whether any particular area of instruction would need to be covered exactly as these standards suggest. Anyone who has been involved in or observed a standard adoption process will know that to get this work done in two months will be next to impossible (Won’t be much of a Christmas or Hanukkah for the staff or the working group of this project).  And, given that if adopted, states will be living with these standards for the next 6 to 10 years, I say take your time and get them right. Unfortunately the timeline doesn’t work too well for RTT. States will likely have to demonstrate their commitment to the new standards likely without having a chance to do much more than a quick look at the first draft. This is another reason to put most of the money out in Round 2 at which time states will have been able to compare these new standards to their current ones and really understand what they are committing to. 

How Many States Get the Money Depends on Big 4. I tried to figure out how many states would likely get these grants to figure out how fierce the competition would be. Or would the administration be forced because of politics to spread it around. It seems that around 35 percent of states would get grants based on the non-binding ranges of grants that the department set. But the wildcard is the four big states – California, New York, Florida and Texas. If all of these states get grants then over half of the funding will be gone leaving little for the remaining states. Now Florida seems a shoe in, but the other three are up for grabs. California is working hard, and has changed their data system to become eligible, and has a bill in a special session to make additional changes around low performing schools, choice and charter schools. However, there approach seems a little bit of this and that and not very focused, and so far the ed community is in strong opposition. New York continues to have difficulty even qualifying because their data system does not allow unfettered linkages of teacher and student assessment data. And, New York City would be well positioned applying for the funding, the rest of the state may drag it down. Perhaps NYC should consider trying to go it alone like LA has proposed (although the dept did not respond to LA request). Texas is not playing ball on common standards which would cost them as much as 70 points (14 percent), but is in reasonable shape on some of this other stuff. So, CA, NY, and TX will be the political testing points of how serious the department is at keeping a high bar, or whether these states are just too big and politically important to squeeze out of the funding.     

No linkage to meaningful comparability commitment. States will soon have to start reporting some better data on how they ensure that Title I schools receive “comparable” levels of state and local resources as non-Title I schools. Without this protection, districts play shell games with Title I funds – sending Title I funds to the schools serving at risk populations, and then shipping  more local funds to the more affluent schools in the district. This is all allowed under NCLB because of a huge loophole that allows districts to measure comparable resources using average salaries instead of actual salaries at a school which basically translates into schools need to have similar student teacher ratios instead of similar quality. The right long term solution is to require districts to report school level accounting information about how actual dollars are distributed. A first step is at least being able to determine and ensure that the salary level at each Title I school site is comparable to non-Title I schools. States that make the changes in their accounting systems to make comparability real should be rewarded in Race to the Top. Instead, the department might have to rely on the ARRA regulations that requires districts to report the data (a process for which I would expect to hear a lot of excuses for why their state can’t report this data at this time).

So Begins the Era of the Highly Effective Teacher. The term “highly effective teacher” has been thrown around as the heir apparent for the highly qualified teachers requirements of NCLB. Now this somewhat semantic change is an important one – moving from concentrating on the qualifications that a teacher has (most of which research tell us have no impact on student achievement) to measuring how well a teacher actually teaches as the measure of quality.  Now for the first time to my knowledge there is an actual definition of what it means. A highly effective teacher means a teacher whose students achieve high rates (e.g. one and one-half grade levels in an academic year) of student growth. Now this takes the Lake Wobegon effect to a new level. Instead of all students being above average, all teachers need to be one and half times above average, even presumably the teachers that do not have students for which a student growth measure can be calculated. Getting states and school districts to have meaningful measures of teacher quality is the single most important part of the Race to the Top, and if states can actually make real progress in this area of measurement, then the $4.3 billion will have been well spent. Time will tell what they come up with here. 

Too Little Weight on Ensuring that Plans Get Implemented. I expect the plans to be truly impressive with the level of investment that Gates is making in helping states develop the plans. But education is full of well written plans that then become shelf art. I have written some of that wonderful shelf art myself. But, putting in place mechanisms to ensure that a state and its school districts live up to the plan that they have written does not seem to get much attention in this process. What is the governance and accountability process that states will use to ensure that the state plan is actually implemented with some integrity, and that this is not just a plan written to get funding, and then spend the funding to do some good stuff. There is room for ensuring that there is internal oversight and evaluation as part of the state success factors, but in my opinion this should have gotten a lot more emphasis than it did. In this area the application graders will truly have their work cut out in determining who is really serious about school reform, and who is just blowing smoke.