Defining “Effective” and Other Keys to a Successful RTTT Application



By 11/23/2009

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One way to conduct a Race To The Top competition would be to issue the following solicitation:

A substantial academic achievement gap exists between well-defined groups of American students.  In addition, international comparisons show that there is a notable gap between the academic achievement of American students and students in many other countries.  From an overall fund of $4.5 billion, the Department of Education will award grants to individuals, organizations, schools (public or private) and colleges and universities who demonstrate they can do something to close those gaps.  Depending on the quality of applications, the Department might award less than $4.5 billion.

There would be forms to fill out.  Successful applicants would be subject to audit requirements.  Evaluations would be needed to assess results.  Most importantly, the Secretary of Education would need great discretion in making awards.  He should not be constrained by a scheme that personifies the stifling bureaucratic process for which American education is noteworthy.  Unfortunately, an argument can be made that Arne Duncan has fallen prey to just such a system.

Consider the voluminous RTTT information posted here.  On reviewing it, one could be excused for thinking that the editors of The Onion have hacked into the Education Department’s website.

What most stands out is the palpable disconnect between the RTTT process and what actually occurs in the many charter schools and private schools that have made real progress.   If a random selection of administrators at such schools were asked to review the process, the response likely would be a collective laugh.

For example, describing a change to the original RTTT application, the department explains, “The term persistently lowest performing schools has been changed to persistently lowest-achieving schools.” Thankfully, that’s been clarified.  Elsewhere, the department explains that the definitions of “rapid-time” and “student achievement” have been modified. Whew.

While that might seem like nit-picking, arcane bureaucratic definitions are central to the RTTT process.  Among the 100+ pages of instructions and guidelines — part of the RTTT application states must submit — nearly five pages are devoted to definitions.

Meaningless nuance rules.  There are “effective” teachers and principals and then there are “highly effective” teachers and principals.  There are “high-need” LEAs, not to be confused with “involved” LEAs or “participating” LEAs.  And on and on.

Then there are “assurances” required of applicants.

One of several:

The State will comply with all applicable assurances in OMB Standard Forms 424B (Assurances for Non-Construction Programs) and to the extent consistent with the State’s application, OMB Standard Form 424D (Assurances for Construction Programs), including the assurances relating to the legal authority to apply for assistance; access to records; conflict of interest; merit systems; nondiscrimination; Hatch Act provisions; labor standards; flood hazards; historic preservation; protection of human subjects; animal welfare; lead-based paint; Single Audit Act; and the general agreement to comply with all applicable Federal laws, executive orders and regulations.

And this:

The State will comply with all of the operational and administrative provisions in Title XV and XIV of the ARRA, including Buy American Requirements (ARRA Division A, Section 1605), Wage Rate Requirements (section 1606), and any applicable environmental impact requirements of the National Environmental Policy Act of 1970 (NEPA), as amended, (42 U.S.C. 4371 et seq.) (ARRA Division A, Section 1609).  In using ARRA funds for infrastructure investment, recipients will comply with the requirement regarding Preferences for Quick Start Activities (ARRA Division A, Section 1602).

Or how about this?

The State and other entities will comply with the Education Department General Administrative Regulations (EDGAR), including the following provisions as applicable:  34 CFR Part 74–Administration of Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations; 34 CFR Part 75–Direct Grant Programs; 34 CFR Part 77– Definitions that Apply to Department Regulations; 34 CFR Part 80– Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments, including the procurement provisions; 34 CFR Part 81– General Education Provisions Act­–Enforcement; 34 CFR Part 82– New Restrictions on Lobbying; 34 CFR Part 84–Government-wide Requirements for Drug-Free Workplace (Financial Assistance); 34 CFR Part 85–Government-wide Debarment and Suspension (Non-procurement).

“[N]o honeymoon lasts forever,” opined the New York Times recently.  Its editorial, headlined “The ‘Highly Qualified Teacher Dodge’,” suggested that recently issued RTTT guidelines amounted to a cave-in by Education Secretary Arne Duncan.

The Times did not go far enough.  It’s simply not possible to sort through the RTTT morass and conclude that anything positive will result, except by chance.




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