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Aurora Institute

iNACOL’s Public Comments on RTT-D

Education Domain Blog

Author(s): Susan Patrick

Issue(s): Federal Policy, State Policy, Create Pilots and Innovation Zones

On Friday, I submitted the following comments and recommendations regarding the U.S. Department of Education’s proposed ‘Race to the Top’ – District (RTT-D) competition:

I am pleased to submit these comments/recommendations related to the ‘Race to the Top’ – District competition on behalf of The International Association for K-12 Online Learning (iNACOL) and its more than 4,200 members.

It is good to see the Department direct its focus to educational innovation through personalized learning in this latest proposed round of the ‘Race to the Top’ initiative.

While a positive step at its core, the guidelines for the district-level competition suffer from the same vague language that plagued earlier aspects of RTT. Namely, there remains too much wiggle room for LEAs to make promises that can be blocked from effective implementation by policies and legislation beyond their control.

As we have witnessed for decades with existing legislation in place governing our public schools, a lack of precise language can result in an unintended relaxation of execution.  It is in this spirit that I outline here some specific items with the aim to strengthen the very positive intentions of the competition.


Absolute Priority 1, Personalized Learning Environment(s):
A truly personalized learning environment is one that utilizes competency education or mastery-based learning practices to ensure no student progresses in their academic journey without first showing mastery of a concept. This was showcased during your RTT-D kickoff event, but would benefit from including the defining work of CompetencyWorks. To further this, I outline here five key elements of any personalized, competency-based learning program:

1. Students advance upon mastery.
2. Competencies include explicit, measurable, transferable learning objectives that empower students.
3. Assessment is meaningful and a positive learning experience for students.
4. Students receive timely, differentiated support based on their individual learning needs.
5. Learning outcomes emphasize competencies that include application and creation of knowledge, along with the development of important skills and dispositions.

Absolute Priority 2, LEAs in Race to the Top States: An LEA or a consortium of LEAs where more than 50 percent of participating students (as defined in this document) are in LEAs in States that received awards under the Race to the Top Phase 1, Phase 2, or Phase 3 competitions.

Absolute Priority 3, Rural LEAs in Race to the Top States: An LEA or a consortium of LEAs where more than 50 percent of participating students are in rural LEAs (as defined in the document) in States that received awards under the Race to the Top Phase 1, Phase 2, or Phase 3 competitions.

Absolute Priority 4, LEAs in non-Race to the Top States: An LEA or a consortium of LEAs where more than 50 percent of participating students are in LEAs in States that did not receive awards under the Race to the Top Phase 1, Phase 2, or Phase 3 competitions.

Absolute Priority 5, Rural LEAs in non-Race to the Top States: An LEA or a consortium of LEAs where more than 50 percent of participating students are in rural LEAs (as defined in the document) in States that did not receive awards under the Race to the Top Phase 1, Phase 2, or Phase 3.

Comments on Absolute Priorities 2-4: There are some states that are further ahead in innovating on personalized learning, such as New Hampshire and Maine, where districts and schools from the ground up are focused on competency education. Districts pioneering online learning, blended learning and competency education (in some respects already “out innovating” the LEAs in States that received awards in prior competitions) should be eligible and rewarded for embarking on innovative practices — and preferences should be given to them to support scaling and resources to grow and lead further innovation in the field. These may include districts implementing blended learning, personalized learning with customized, competency education or virtual schools that are LEAs.

Focus on Online and Blended Learning:
Blended and online learning should be highlighted and included as a strategy for personalization and accelerating student learning The definition of blended learning is: a formal education program in which a student learns at least in part through online delivery of content and instruction with at least some element of student control over time, place, path and/or pace; and, at least in part in a supervised brick and mortar location away from home (Horn and Staker, 2012).


Digital learning content:
The Department’s definition of “digital learning content” barely moves beyond a PDF. iNACOL would like to push for a more innovative definition of digital content under the “if learning cannot be gauged, learning cannot be claimed” mantra. True digital content is not a conversion, but created natively for the medium with built in formative assessment to ensure mastery, and data collection to inform teachers of progress and/or need. There should be a focus on outcomes data to measure performance in next generation digital content.

Learning materials, professional development resources and other educational resources made possible with these grants and developed with public dollars should be given a priority for open licensing for sharing, collaborating across schools and districts and accessibility.

Definition of mastery: In Policy and Infrastructure there is reference to mastery, specifically, the extent to which LEA’s enable personalized learning through the opportunity for students to progress and earn credit based on demonstrated mastery; and, the opportunity for students to demonstrate mastery of standards at multiple times and in multiple comparable ways. Mastery needs to be included in the section on definitions emphasizing explicit and measurable competencies.

Personalized learning plan:
The Department’s definition portrays a fixed document outlining a student’s trajectory. A personalized learning plan should allow student agency to choose content, applications or learning environments to show mastery along trajectories –consistent with state standards frameworks for college and career ready skills, knowledge and dispositions. A personalized learning plan supports multiple “systems of assessments” including adaptive assessments to highlight mastery, e-portfolios, performance-based assessments, formative assessments, moderating assessments that validate assessments from the ground “up”. A true personalized learning plan is a flexible plan that allows a student some choice in how they learn, what pace they learn and that adapts to a student’s progress as they master content – with assessment for validating and demonstrating learning.

Student attendance: The section on student attendance is inputs focused, and a relic of the factory model of batching students, rather than student learning outcomes focused for next generation models of learning. This section is problematic as it validates old models of relying on seat time as a measure or form of progress. Student progress should be measured on proficient learning and demonstrating mastery, not time.

Graduation rate:
This section on graduation rates focuses on an arbitrary measurement based on time, not mastery or accomplishment.

On a final note, to see that blended, digital and online learning practices are defined throughout the initial guidelines without being explicitly identified in association with those terms, indicates a missed opportunity. For years, innovative districts from California to Kentucky have implemented inspired online and blended learning programs and competency education models that break the one-size-fits-all mentality and harness the individual learning needs and speeds of their students regardless of background. At their core, they are redefining traditional terms such as “teacher”, “classroom”, “progress”, and “school” for millions of children (and adults). These new learning models should be held up as examples of what a district (or school) can accomplish when a student-centered approach initiates a student-focused process and outcome. Only then will our schools be able to say that they are preparing each and every child for college and/or a career.

Susan Patrick
President & CEO
iNACOL (International Association for K-12 Online Learning)