PNI Feedback on 2011 Proposed Priorities

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1 Memorandum To: Jill Staton From: Policy Link, Harlem Children’s Zone, and The Center for the Study of Social Policy RE: Comments on Promise Neighborhoods Proposed Priorities Date: April 11, 2011 PolicyLink, Harlem Children’s Zone (HCZ) and The Center for the Study of Social Policy jointly support the work of Promise Neighborhood grantees through technical assistance at the Promise Neighborhoods Institute. We welcome this opportunity to comment on Promise Neighborhoods Proposed Priories and do so from both that global vantage point as well as each organization’s experiences in this field. We wish to take this opportunity to compliment the Department of Education (DOE) on creating an effective grant structure in the first year of planning grants. It successfully structured the grant and the review process to produce a terrific group of grantees. In addition, the transparency of the review process enabled others to see the tremendous interest and highly competitive nature of the field. The chart below makes recommendations for this year’s Proposed Priorities, in areas we believe can be further clarified, strengthened or supported, building on the excellent components already included. Content Area Analysis or Comment Recommendation Funding Issues 10% of matching funds must be cash or in-kind contributions from the private sector. This may be particularly challenging for rural and tribal communities. Reduce this threshold to 5% for rural and tribal communities. The majority of implementation funding is to be spent on administrative capacity such as managing partnerships, integrating funding streams and supporting the data systems. The majority of funding for solutions would come from existing funding sources. It is critical for communities to build this capacity. At the same time, communities have variation in their funding sources that may already be restricted so more flexibility here would be helpful. While a significant portion of a grant may be spent on administrative capacity, it is also expected that communities will need significant dollars to ensure program quality and to create innovative programs where no current public funding exists. Institutes of Higher Education typically have indirect rates well over 20% that may not go directly to the PN work, but rather to general university support. Change this to ensure communities can spend significant dollars on direct services as well as administrative capacity. Limit the indirect rates that Institutes of Higher Education can receive to 20% or less. Goals and Indicators Best Available Evidence to support selection of programs. DOE requested comments on this language. This language is very good. We have no edits.

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PNI publically comments on the Department of Education's proposed priorities for the Promise Neighborhoods FY 2011 grant.

Transcript of PNI Feedback on 2011 Proposed Priorities

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Memorandum

To: Jill Staton

From: Policy Link, Harlem Children’s Zone, and The Center for the Study of Social Policy

RE: Comments on Promise Neighborhoods Proposed Priorities

Date: April 11, 2011

PolicyLink, Harlem Children’s Zone (HCZ) and The Center for the Study of Social Policy jointly support the work of

Promise Neighborhood grantees through technical assistance at the Promise Neighborhoods Institute. We welcome

this opportunity to comment on Promise Neighborhoods Proposed Priories and do so from both that global vantage

point as well as each organization’s experiences in this field.

We wish to take this opportunity to compliment the Department of Education (DOE) on creating an effective grant

structure in the first year of planning grants. It successfully structured the grant and the review process to produce a

terrific group of grantees. In addition, the transparency of the review process enabled others to see the tremendous

interest and highly competitive nature of the field.

The chart below makes recommendations for this year’s Proposed Priorities, in areas we believe can be further clarified,

strengthened or supported, building on the excellent components already included.

Content Area Analysis or Comment Recommendation

Funding Issues

10% of matching funds must be cash or in-kind contributions from the private sector.

This may be particularly challenging for rural and tribal communities.

Reduce this threshold to 5% for rural and tribal communities.

The majority of implementation funding is to be spent on administrative capacity such as managing partnerships, integrating funding streams and supporting the data systems. The majority of funding for solutions would come from existing funding sources.

It is critical for communities to build this capacity. At the same time, communities have variation in their funding sources that may already be restricted so more flexibility here would be helpful. While a significant portion of a grant may be spent on administrative capacity, it is also expected that communities will need significant dollars to ensure program quality and to create innovative programs where no current public funding exists. Institutes of Higher Education typically have indirect rates well over 20% that may not go directly to the PN work, but rather to general university support.

Change this to ensure communities can spend significant dollars on direct services as well as administrative capacity. Limit the indirect rates that Institutes of Higher Education can receive to 20% or less.

Goals and Indicators

Best Available Evidence to support selection of programs.

DOE requested comments on this language.

This language is very good. We have no edits.

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Content Area Analysis or Comment Recommendation

Implementation includes annual policy goals

This is a terrific goal, but it can also be distracting to the short-term work that needs to happen on the ground.

This could be a long-term goal in a 10-year strategic plan, but not a short-term goal.

Explain how each child in the neighborhood will receive appropriate services from the continuum.

This is again a terrific aim, but we have found it terribly difficult to achieve 100% of any goal. For example, HCZ has set this particular goal at 65% of its catchment area for children aged 0-23.

Organizations should state the number and percentage of kids in their community that they expect will need and receive services over time in each age group of their pipeline of services, with a strong emphasis on growth.

Timing Ultimate success will include both short and long term goals which should be clarified if feasible.

Add clearer language around short and long term goals and expectations.

National Evaluator Is there going to be a process for determining a national evaluator?

If feasible, provide more information about a potential national evaluator. Ensure that any evaluator will work collaboratively with grantees.

Academic indicator that focuses on the # and % of students who graduate with a regular HS diploma and obtain post-secondary degrees, vocational certificates, or other industry-recognized certificates or credentials without the need for remediation.

This is a tremendous goal. However, children and youth will enter continuums at different ages. If a 16 year old joins an after-school program and he or she is 2-3 years behind academically, it is unlikely that the after-school program can close that gap in two years. The student should still go to college, but may continue to need remediation. Communities should get acknowledgement for the hard work required in getting such a student through college. As it stands, this may be a disincentive to invest in the college success of less-prepared students.

Add another indicator that captures the # and % who achieve those benchmarks with remediation. This way the indicator captures both successes, but also recognizes the higher goal.

Academic Indicator that calls for 3 year olds and kindergarteners to demonstrate age-appropriate functioning.

Ensure that programs can fund evaluation expenses with this grant, as in particular, this will be an expensive, but critically important outcome to measure. Add 4 year olds to ensure annual measures.

Family and Community Supports Indicator regarding the # and % of parent or family members who report reading to their child 3 days a week.

Is there a reason that this does not start at birth?

Start this measure at birth, not six months to encourage good habits from the very start.

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Content Area Analysis or Comment Recommendation

Family and Community Supports Indicator regarding the # and % of children who participate in at least 60 minutes of exercise and eat five or more fruits and vegetables per day.

Each of these two goals is individually tremendous and incredibly important, but difficult to achieve.

Split this indicator into two indicators so that communities would get credit for achieving changes in food, fitness or both. Allow communities to offer a progression towards the goals. For example, in Year 1, X% will exercise at least 60 minutes 3 x a week with a longer term goal of 7x a week.

Indicators of need and/or Family and Community Supports regarding Child Welfare

To encourage communities to tackle this challenge, use an indicator in this field as one of your sample potential Family and Community Supports indicators.

Implementation applicants are to explain how they have linked their longitudinal database to school-based, LEA and State data systems.

Given the laws protecting student data, such linkages are very difficult to accomplish. While some may have achieved this goal, for others it may still be a work in progress.

Allow applicants to explain how the linkage process is progressing if they have not yet completed it.

Continuum of Solutions and partners

School definitions Recognizing that the goal is to focus on the most challenged schools, these definitions may exclude some very challenged rural or tribal communities who have only one school in their community and it may not fit this precise definition.

Broaden the language around eligible schools to 10% of lowest performing and/or schools with data on specific challenges.

Applicant is asked to implement interventions in the schools.

Clarify what qualifies as an intervention to ensure that the applicant, if not a non-profit school themselves, would have the authority themselves or through partnership to implement interventions at the school.

Implementation grant applicants are to indicate solutions for a) early learning and b) pre-school to 12.

This excludes programs that would help youth matriculate in and graduate from college.

Add a section where communities would indicate their solutions for helping young people through college and career. Continue this type of language throughout the document.

MOUs should include partners financial and programmatic commitment

Some partners, such as schools, may only be able to contribute in-kind resources such as space.

Indicate that in-kind resources can also be included.

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Content Area Analysis or Comment Recommendation

Proposed Implementation Priority for communities to submit a plan for a comprehensive early learning network from birth to third grade.

This priority is terrific. Given that these are two very distinct time periods (Birth-pre-school and K-3) it might be helpful for communities to address this in stages over time.

Permit communities to break this goal into two stages so that they can achieve each stage and then link them over time.

Proposed Implementation Priority regarding juvenile justice.

Amend the language to “or” among the options since an applicant may not be able to do all of it but could still accomplish significant work.

Mandatory community of practice

Indicate to communities that in their budgets, they may wish to set aside funds to participate in a community of practice so they have advance knowledge and can allocate resources accordingly.

Contact Information

PolicyLink

Judith Bell, President, [email protected]

Michael McAfee, Ed.D., Director, Promise Neighborhoods Institute at PolicyLink, [email protected]

T: 510-663-2333; www.policylink.org

Harlem Children’s Zone

Kate Shoemaker, Director of Policy, [email protected]

T: 212-360-3255; www.hcz.org

The Center for the Study of Social Policy

Lisa Cylar Miller, Senior Associate, [email protected]

T: 202-371-1565