In June 2012, TCTA submitted the following comments on the federal Race to the Top district program criteria:

Eligibility Requirements

Regarding the signature requirements in Eligibility criteria, the proposal states that the Required Signatures for the LEA or lead LEA in a consortium are the Superintendent/CEO, local school board, and local union/association president (where applicable). Clarification is needed regarding what the requirement is when there is more than one teacher group in operation in a given school district.

Regarding the proposed Eligibility criteria that requires applicants to demonstrate a track record of commitment to the four core education assurance areas from RTTT including that: “The LEA has, at a minimum, designed and committed to implement no later than the 2014-15 school year — i. a teacher evaluation system (as defined in this document); a principal evaluation system (as defined in this document); a LEA superintendent evaluation (as defined in this document); and a LEA school board evaluation (as defined in this document)," the requirements for the teacher evaluation system are highly objectionable.

The proposed definition of Teacher evaluation system contains the requirement that it includes as a significant factor data on student growth (as defined in this document) and that it will be used to inform personnel decisions.

“Student growth” is defined as “The change in student achievement for an individual student between two or more points in time, defined as — For grades and subjects in which assessments are required under ESEA section 1111(b)(3): (1) a student's score on such assessments and (2) other measures of student learning, such as those described in the second bullet, provided they are rigorous and comparable across schools within an LEA.

For grades and subjects in which assessments are not required under ESEA section 1111(b)(3): alternative measures of student learning and performance, such as student results on pre-tests, end-of-course tests, and objective performance-based assessments; performance against student learning objectives; student performance on English language proficiency assessments; and other measures of student achievement that are rigorous and comparable across schools within an LEA.
 
The requirement that teacher evaluation systems includes as a significant factor data on student growth on state standardized tests (in addition to other measures of student learning, which are effectively precluded by virtue of the requirement that they be rigorous and comparable across schools) and that they be used to inform personnel decisions not only results in an increased emphasis on high stakes testing, but is inappropriate and unsupported by the bulk of research related to this topic.

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Finally, the prescriptive requirement that evaluation systems be used to inform personnel decisions represents a significant federal intrusion into dictating employment practices, an area traditionally within the province of states and its political subdivisions

Definitions

Regarding the proposed definition of principal evaluation system, there no requirement for such systems to be based on educator feedback, whereas there is such a requirement for superintendent and school board evaluation systems. As the instructional leader of the school, it is imperative that principal evaluation systems be informed by educator feedback and this requirement should be included in the definition.

Regarding the proposed definitions for superintendent and school board evaluation systems, why is permissive terminology used that the evaluation rating “should” reflect ... rather than mandatory terminology as is used in teacher and principal evaluations? This terminology should be consistent among all four categories of evaluation systems.

Selection Criteria

Regarding the Performance Measurement component under District capacity and success factors, one of the proposed measures is “The extent to which the applicant has established annual ambitious yet achievable annual targets for: ... The number and percentage of participating educators who complete a survey on working conditions;”

There is also a measure described as “The number and percentage of participating students who complete a student survey (as defined in this document).”

However, unlike student surveys, which are incorporated into other provisions of the RTT-D proposal, there is no mention, nor incorporation of, working condition surveys anywhere else in the RTT-D proposal. We strongly support completion of working surveys as a performance measure, but suggest that it also be incorporated into other provisions of the proposal to strengthen its relevance and connection to the overall proposal. For example, it could be included in the superintendent and school board evaluations, as both these categories of individuals have a great deal of influence over working conditions in a given school district.