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NEA's Response to Race to the Top

On August 21, the National Education Association submitted comments to the Department of Education regarding Race to the Top, a $4.3 billion grant intended to reward innovation in education. Below is the text of NEA's letter accompanying the comments. (Read the full comments here.) 


August 21, 2008

Secretary of Education Arne Duncan
c/o Offica of Elementary and Secondary Education
Attn: Race to the Top Comments
U.S. Department of Education
400 Maryland Avenue, SW, Room 3W329
Washington, DC 20202

Re: Race to the Top Fund [Docket ID ED-2009-OESE-0006]

The National Education Association appreciates the opportunity to comment on the Notice of Proposed Priorities, Requirements, Definitions, and Selection Criteria published in the July 29, 2009 Federal Register regarding the Race to the Top Fund.

On Friday, July 24, 2009, the Department of Education unveiled a package of proposals and priorities designed to invite comment on ways to reform the public education system in this country—the Race to the Top proposal subsequently was published in the Federal Register. It is clear that this Administration cares about students and it is clear that NEA and this Administration share the same goal: to dramatically transform the public education system so that every public school is a center of excellence and all students gain the skills and education they need to become lifelong learners and healthy, productive citizens in this global society.


Admirable Goals

NEA appreciates that the Obama Administration is speaking out about a crucial truth:  The current system is failing many students.  If nothing changes, up to half of America’s school children who are poor and minority will not graduate from  high school—a situation that  is not only deplorable, but criminal as well. 

NEA applauds the Obama Administration for keeping its commitment to deliver resources to support and improve the public education system. Earlier this year, the American Recovery and Reinvestment Act (ARRA) was enacted, and in July, the Administration unveiled $4.35 billion of those funds as part of the Race to the Top competitive grant program. With the other grant funds described that day, the federal investment will be close to $10 billion. NEA applauds the Obama Administration’s commitment to students at risk—the grant funds are targeted to schools in the highest poverty areas.

NEA applauds the fact that the RTTT grant applications require the support of teachers and other school staff—for far too long the voices of educators have been ignored.

NEA applauds the fact that the RTTT grant competition will require states to adopt internationally recognized high standards, as well as better tests and more comprehensive tracking of multiple lines of evidence of student achievement.

NEA applauds the fact that the Obama Administration continues to emphasize the importance of teacher quality in student success, and that schools that face the toughest challenges must have the most talented, qualified people available.


Proposal Misses the Mark

Up to this point, the NEA has been a vocal supporter of the Obama Administration’s plans to transform public education by being “tight” on goals, but “looser” in how you achieve them. We were in total agreement with the sentiments expressed by Secretary Duncan in a speech at the National Press Club on May 29, 2009 when he said: “You know, when I was in Chicago, I didn’t think all the good ideas came from Washington. Now that I’m in Washington, I know all the good ideas don’t come from Washington. The good ideas are always going to come from great educators in local communities. And we want to continue to empower them.”

Given the details of the July Race to the Top grant proposal, NEA must now ask: Where did that commitment to local communities go?

The details of the RTTT proposal do not seem to square with the Administration’s earlier philosophy. The Administration’s theory of success now seems to be tight on the goals and tight on the means, with prescriptions that are not well-grounded in knowledge from practice and are unlikely to meet the goals. We find this top-down approach disturbing;   we have been down that road before with the failures of No Child Left Behind, and we cannot support yet another layer of federal mandates that have little or no research base of success and that usurp state and local government’s responsibilities for public education.

Instead of focusing on strengthening enforcement of civil rights laws to promote access and opportunity for students, the Administration has chosen the path of a series of top-down directives that may discourage rather than encourage productive innovation in classrooms and schools across the country. Despite growing evidence to the contrary, it appears that the Administration has decided that charter schools are the only answer to what ails America’s public schools—urban, suburban, exurban, and rural—and all must comply with that silver bullet, despite the fact that charters have often produced lower achievement gains than district-run public schools. [See recent report on Chicago’s Renaissance 2010 initiative: Young, V.M., Humphrey, D.C., Wang, H., Bosetti, K.R., Cassidy, L., Wechsler, M.E., Rivera, E., Murray, S., & Schanzenbach, D.W. (2009). Renaissance Schools Fund-supported schools: Early Outcomes, challenges, and opportunities.Menlo Park, CA: Stanford Research International and Chicago: Consortium on Chicago School Research.]

We urge the Administration to step outside of this narrow agenda and embrace the diversity of choices available to students, parents, school districts, and states across the country. Well-designed charters are not the only way to innovate, and we need to embrace and champion other models such as magnet schools. 

Assessing student learning is another area where we need more and better options. What is being proposed is simply tweaking the current top-down, federally mandated insistence on hewing to standardized test scores. We know that model is not working, so basing even more educational decisions on these same test scores is counterproductive and counterintuitive. Enough is enough.

If we want better results for students: 


  • We should not continue the unhealthy focus on standardized tests as the primary evidence of student success.

Achievement is much more than a test score, but if test scores are still the primary means of assessing student learning, they will continue to get undue weight. This is especially problematic because the tests widely in use in the United States, since NCLB narrowed the kinds of tests in use, typically focus on lower level skills of recall and recognition measured with multiple-choice items that do not adequately represent higher order thinking skills and performance.  These are unlike the assessments that are used in high-achieving nations that feature essays, problem solutions, and open-ended items and more extensive tasks completed in classrooms as part of the assessment system.  The rules proposed here are likely to lock in these kinds of measures of lower level skills rather than opening up the possibilities for more productive forms of assessment.  Furthermore, achievement must also take into account accomplishments that matter in the world outside of school, such as:  Are you prepared for college or trade school? Can you form an opinion about something you read and justify your opinion?  Are you creative? Are you inventive?  Can you come up with a variety of solutions when you’re faced with a problem?

We should not use data inappropriately in the educational system.

It is inappropriate to require that states be able to link data on student achievement to individual teachers for the purpose of teacher and principal evaluation. Such evaluations are local school district functions; therefore, requiring statewide linkages does nothing to further the  goal of producing a high quality, reliable system of educator evaluation based on student performance and could lead to another unreliable way to hold schools accountable based on a “snapshot” of test score results. Furthermore, by requiring teacher evaluations based on test scores as a condition for receiving RTTT funds, the federal government again attempts to interfere with collective bargaining laws and with contracts, memoranda of understanding, and other agreements already in place in thousands of school districts that provide for negotiation of evaluation procedures.

Significantly, the most prominent research organizations in the United States have confirmed that test-based measures of teacher “effects” are too unstable and too dependent on a range of factors that cannot be adequately disentangled to be used for teacher evaluation, much less for teacher preparation program evaluation. These include the non-random assignment of students with different characteristics, student attendance and parent support, differentials in school and classroom resources, the specific tests used, and the influences of other teachers.  The use of these measures can also create disincentives for teachers to work with the neediest students—such as special education students and English language learners—whose learning might not validly be assessed on traditional grade-level tests. Test scores are affected by many, many factors outside the teacher’s control, but good teachers will use all their skills and resources to give kids what they need.  Some students will need more support and intervention than others, and some students will need more time to reach their goals.  Teachers who work with disadvantaged students should not be “evaluated” as ineffective because their students do not hit a particular test target on a particular timeline. And we certainly should

not primarily base additional compensation on whether students meet particular testing targets on a particular day. We need to offer incentives so that our best teachers teach the students most in need of assistance, not necessarily teach the students most likely to score highest on a standardized test.


  • We should not continue to support initiatives that ignore the skills necessary to be an effective educator.

NEA supports alternative routes to licensure, including high quality alternative certification programs.  We know of many programs that do require evidence of excellence in the content area taught and have a carefully designed program of required course work in pedagogy and work with a mentor teacher. 

In most alternative certification programs, however, the candidates are not fully certified for two years.  And in one particular program, Teach for America, candidates are scheduled to leave teaching just as the two years are completed. 

We agree that the Race to the Top programs should be focusing on the most challenging schools. And the research is clear that a highly qualified and stable workforce is necessary for true reforms to take hold. Experience, stability, content knowledge, access to induction and mentoring programs, and preparation for teaching diverse learners (cultural, linguistic and students with unique needs) will be key to the most qualified staff in high priority schools.  Plans should be designed to attract and retain the best prepared, fire-tested, career individuals who plan to be there for the duration.  Alternative certification candidates should be the last ones assigned to schools targeted for real reforms.

We should not continue to narrowly focus on charter schools as the only model of reform for schools worthy of serious attention. 


There are good charter schools and there are very bad charter schools.  It all depends on how well they are designed and how they are held accountable.  Charter schools were originally started as places where educators, communities, and parents who wanted to try something out of the box—such as scheduling or curriculum or parental involvement or ways to motivate students and could experiment—in the hopes that if we found something that worked well, we could scale it up to other public schools.

Putting a cap on the number of charters in a state makes sense so that states can put good systems in place to approve, monitor, evaluate, and hold these charter schools accountable. Among the states that have had the most egregious examples of corruption,  mismanagement, and incompetence in charter schools is Arizona, a state that has very lax rules on design and accountability and, not surprisingly, no limit on the number of charter schools that can be established in that state.

Where charters are working well, they are highly accountable, non-selective public schools where public school employees are given unprecedented freedom to experiment with success models that can be scaled up.  Taking the caps off charter schools means LESS accountability as monitoring agencies would not have the time and resources to ensure that every charter school would be held to high standards.

Furthermore, the RTTT proposal insists on states adopting a charter school law that “does not…effectively inhibit increasing the number of charter schools in the state…” The “effectively inhibit” language is overbroad and vague, providing ample opportunity for federal interference with state authority to determine how and under what standards charters are authorized and monitored.

Additionally, there are 11 states that do not have charter school laws for varying reasons.  For example, Washington State’s citizens have had votes at least three times, and overwhelming majorities voted charters down. When the people of a state speak in this democratic union, the government should listen. Creating a proposal that focuses its efforts for innovation primarily on charters violates that principle and ignores the other kinds of innovation and creativity happening in the public school system—such as magnet schools, academies and any number of innovative programs from which parents can choose.

In some states, like Montana, the administration’s proposal on charter schools is unconstitutional. It isn’t just unworkable—it is unconstitutional. Under Montana’s standard of accreditation, which was recommended by the State Superintendent and adopted by the Board of Public Education, charter schools are permissible—but none have been chartered. Requiring the opening of charter schools in one of the most rural states in the nation does not make sense.

The proposal also would usurp Montana collective bargaining rights, statutory rights, and local school board governance. The Montana state legislature would be involved in school governance, something MEA-MFT has successfully fought for decades.

If education reform is to be done with teachers and their representatives, instead of to us, it is important that the administration understand what is working already. Montana has a strong public education system. It can be improved, and it is committed to improving education, especially for Native American students, but not at the expense of its state constitution, and not at the expense of members’ statutory and collective bargaining and rights.

Lastly, we urge the Administration to start highlighting models in addition to charters. For example, magnets promote racial and socioeconomic integration more effectively than charters, while offering the same advanced academics and unique courses that make both models popular among parents, according to a 2008 report from the Civil Rights Project at University of California, Los Angeles. The report found that magnets embody a key advantage over charter schools, namely, integration: Magnets promote it, while charter schools can exacerbate racial isolation.


Focus on What Works

Instead of continuing with some of the failed policies of the past, we encourage the Administration to base its recommendations on research and on what works.

To meet the challenges of the 21st century, we must transform the system by demanding sweeping changes that changes the dynamic—significantly higher student achievement and significantly higher graduation rates for all groups of students.

Here are some lessons we draw from the past 40-year history of education:


  • It’s time we take parental and community engagement as seriously as we take curriculum, standards, and tests. Through more than 125 initiatives in 21 states, NEA’s Public Engagement Project is demonstrating the essential role of school-family-community partnerships in student achievement. Our findings echo those of a six-year-long study of multiple data sources conducted by the Annenberg Institute for School Reform at Brown University: such partnerships contribute to increased student attendance, improved performance on standardized tests, higher high school graduation rates, and college-going aspirations. 
  • Investments in teachers’ and leaders’ knowledge and skills are essential to all other reforms, and pay off in higher achievement.  Strong preparation, mentoring, and professional development, as well as collaborative learning and planning time in schools, are the building blocks of any successful reform.
  • Curriculum and assessments must focus on higher order thinking and performance skills, if students are to meet the high standards to which we aspire.
  • Resources must be adequate and equalized across schools.  We cannot expect schools that lack strong and prepared leaders, well-qualified teachers, and high-quality instructional materials to improve by testing alone.
  • Incremental changes yield incremental results. We must be bolder. A legislative tweak here or a regulatory toggle there will not lead to the fundamental and transformative changes in education we all seek.
  • When we address change, we have to focus on significant and sustainable improvement in the rates of achievement for all students, but especially poor and minority students. The NEA Foundation is doing this with its Closing the Achievement Gaps initiative, and we are starting to see positive results.


Different Actions to Achieve Different Results

NEA advocates a significant and positive improvement to the public educational system that is sustainable.  We must focus on turning around struggling, priority schools of all regions of the country that serve diverse groups of students. At the same time, we must be bold enough finally to address the inequities ever-present in the public schools across the country.

NEA wants different results, and we are willing to do things differently because the status quo is not acceptable.  

Turning Around Priority Schools

To reach a different and significantly better result for the public education system, NEA proposes that the Race to the Top grant program focus aggressively on states and local school districts working to implement proven school improvement strategies to help close achievement gaps, such as:

ü  A dedicated funding stream for school turnaround teams and school improvement. 

ü  Literacy and mathematics coaches who work with students who are struggling in these subjects and with educators to improve their instructional skills.

ü  Incentives to bring more experienced, more qualified teachers, including National Board-certified teachers, to these schools.

ü  Training for school principals in school leadership and improvement, along with incentives to attract expert principals to high-need schools.

ü  Other school system improvement measures focused on high-need schools, such as the provision of plentiful, high-quality learning materials—textbooks, libraries, computers, and science labs—as well as class size reduction and extended learning opportunities for students.


In addition, educators may have a need for professional development focused on the needs of poor and/or culturally and linguistically diverse students.  If that is the case, NEA’s publication, C.A.R.E. (Culture, Abilities, Resilience, Effort):  Strategies for Closing the Achievement Gaps (3rd ed, 2007) is a good resource (   It offers four lenses through which to view diverse learners and four cornerstones of school improvement:  1) school organization; 2) curriculum, instruction and assessment; 3) staff development, and 4) community, family and school engagement. 

The central premise of C.A.R.E. is that  effective teachers of poor and/or culturally and linguistically diverse students: 1) connect school to their students’ everyday lives (Culture); 2) acknowledge unrecognized abilities, integrate multiple abilities, develop higher order thinking skills, and foster autonomy (Ability); 3) support their students to build both academic and personal resilience (Resilience - the ability to bounce back from adversity); and 4) build on student’s experiences, and knowledge to motivate and engage them in their learning (Effort).

There are not sufficient resources for school districts and states that want to address these strategies in a comprehensive way designed to bring about sustainable change to improve the educational system for students. The Race to the Top grant program would be a superb vehicle to ensure their success.

To adjust the current proposal’s language under the Reform Criteria for (D)(3), we would recommend that the strategies for turning around schools feature the school transformation model as the primary option or at a minimum, considered prominently and on equal footing with the other options, rather than described as a last resort if it is not possible to: change leadership and staff; convert to charter status; or close the school and move the students. Comprehensive school transformation is superior to the other three options when looking at the chances for sustainable success, and therefore, should be the primary option for local school districts, not a last resort.

The Department should explicitly state that all of these items must be locally negotiated by the collective bargaining representative and that nothing in these requirements shall be construed to alter or otherwise affect the rights, remedies, and procedures afforded school or school district employees under Federal, State, or local laws (including applicable regulations or court orders) or under the terms of collective bargaining agreements, memoranda of understanding, or other agreements between such employees and their employers. In non-collective bargaining states, these items should be adopted only with the support of the majority educator representative or a vote representing the support of the majority of affected educators.


Address Inequities

To reach a different and significantly better result for the public education system, NEA proposes that the Race to the Top proposal require states, as part of their application for the competitive grant funds, to develop “Adequacy and Equity Plans.” The process of developing the plans should bring together stakeholders within the state to devise a plan to meet adequacy and equity goals, and for the first time significant federal resources could serve as a powerful incentive that spurs action on this issue.

Through these plans, states will demonstrate where among districts and schools there are disparities in educational tools and services, opportunities, and resources. The states will outline steps under way or planned to remedy the disparities. This effort will help elevate the commitment to all students and build a shared understanding of what it will take to support them.

These applications should undergo a rigorous, independent peer review by a representative panel of experts including educators to assess the plans for feasibility, legitimacy, and sufficiency. States and their local school districts will be responsible for complying with their own approved plan. The Education Department will include as part of its current monitoring process a review of whether states and local districts are meeting the provisions of the Adequacy and Equity Plan (in addition to the other components of the state plan).

The federal process should be one that sensibly supports adjustments and flexibility as states pursue their goals and work to eliminate disparities, without ever losing sight of the fact that the richest country in the world can afford to provide every student with a quality education. Indeed, it cannot afford to do otherwise.


Achieve Great Public Schools for Every Student

By focusing on these two initiatives—turning around priority schools and addressing inequities—this country will be taking enormous strides toward the goal of great public schools for every student. There will be resources and tools available that are necessary to bring about the type of systemic, sustained transformation necessary to positively alter the lives of affected students. And this country will focus on those factors that will truly help schools become centers of excellence.

Our vision of what great public schools need and should provide acknowledges that the world is changing and public education is changing too. Fulfilling these Great Public Schools (GPS) criteria require not only the continued commitment of all educators, but the concerted efforts of policymakers at all levels of government. These criteria will prepare all students for the future with 21st century skills; create enthusiasm for learning and engaging all students in the classroom; close achievement gaps and increase achievement for all students; and ensure that all educators have the resources and tools they need to get the job done.

The criteria are:

ü  Quality programs and services that meet the full range of all children's needs so that they come to school every day ready and able to learn.

ü  High expectations and standards with a rigorous and comprehensive curriculum for all students.

ü  Quality conditions for teaching and lifelong learning.

ü  A qualified, caring, diverse, and stable workforce.

ü  Shared responsibility for appropriate school accountability by stakeholders at all levels.

ü  Parental, family, and community involvement and engagement.

ü  Adequate, equitable, and sustainable funding.

Not every school will need to address all of these criteria, but for those willing to tackle the tough work of systemically transforming public education for the better, they provide a framework for change.

In addition to these overall comments, we have provided detailed comments below on several priority issues.

Thank you in advance for your consideration of NEA’s comments and we look forward to discussing this matter with the appropriate staff. I can be reached via telephone at (202) 822-7946 or via email at


Kay Brilliant, Director

Education Policy and Practice Department




Read NEA's complete comments regarding the Race to the Top Fund.