Soliciting Input for the Statewide Family Engagement Centers

[Note: The comment period has expired and comments have been closed.]

The United States Department of Education (Department) recognizes that family engagement in school is an important component of student success. As schools improve their efforts to engage families, we know that some schools, districts and states may need additional support and technical assistance. Through the Consolidated Appropriations Act of 2018, Congress has authorized funding for the Statewide Family Engagement Centers Program.  Title IV, Part E, Sections 4501 – 4506 of the Elementary and Secondary Education Act, as amended by the Every Student Succeeds Act, is intended to provide financial support to organizations to provide technical assistance and training to State educational agencies and local educational agencies in the implementation and enhancement of systemic and effective family engagement policies, programs, and activities that lead to improvements in student development and academic achievement.  The Secretary is authorized to award grants to statewide organizations (or consortia of such organizations) to establish statewide family engagement centers that (1) carry out parent education, and family engagement in education; or (2) provide comprehensive training and technical assistance to State educational agencies and local educational agencies, schools, organizations that support family-school partnerships, and other organizations that carry out such programs.

Because the Department is very interested in your input, we are posting the legislation as part of this blog post.  We encourage all interested parties to submit opinions, ideas, suggestions, and comments pertaining to the Statewide Family Engagement Centers program in the comments section below.  This document will be posted for public comments until 5:00 PM EDT on Friday May 11, 2018, at which time the response section will be closed and we will begin considering input received as we develop the requirements, priorities, selection criteria, and definitions.  Though the Department will not respond to comments, the Department will read and consider all comments in finalizing the Statewide Family Engagement Centers program and competition design.  In early summer, we will publish a notice inviting applications in the Federal Register.

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The fine print

Please understand that posts must be related to the new competition and program, and should be as specific as possible, and, as appropriate, supported by data and relevant research. Posts must be limited to 1,000 words. All opinions, ideas, suggestions and comments are considered informal input. ED will not respond to individual posts, and these posts may or may not be reflected in the policies and requirements of the program. If you include a link to additional information in your post, we urge you to ensure that the linked-to information is accessible to all individuals, including individuals with disabilities. Additionally, please do not include links to advertisements or endorsements; we will delete all such links before your comment is posted.

Again, thank you for your interest in this opportunity to support family engagement in student learning. We look forward to hearing from you.

Department of Education’s linking policy

Department of Education’s disclaimer of endorsement

 

TITLE IV, PART E—FAMILY ENGAGEMENT IN EDUCATION PROGRAMS

 

SEC. 4501. (20 U.S.C. 7241) PURPOSES.

The purposes of this part are the following:

(1) To provide financial support to organizations to provide technical assistance and training to State educational agencies and local educational agencies in the implementation and enhancement of systemic and effective family engagement policies, programs, and activities that lead to improvements in student development and academic achievement.

(2) To assist State educational agencies, local educational agencies, community-based organizations, schools, and educators in strengthening partnerships among parents, teachers, school leaders, administrators, and other school personnel in meeting the educational needs of children and fostering greater parental engagement.

(3) To support State educational agencies, local educational agencies, schools, educators, and parents in developing and strengthening the relationship between parents and their children’s school in order to further the developmental progress of children.

(4) To coordinate activities funded under this part with parent involvement initiatives funded under section 1116 and other provisions of this Act.

(5) To assist the Secretary, State educational agencies, and local educational agencies in the coordination and integration of Federal, State, and local services and programs to engage families in education.

 

SEC. 4502. (20 U.S.C. 7242) GRANTS AUTHORIZED.

(a) STATEWIDE FAMILY ENGAGEMENT CENTERS.—From the amount appropriated under section 4506 and not reserved under subsection (d), the Secretary is authorized to award grants for each fiscal year to statewide organizations (or consortia of such organizations), to establish statewide family engagement centers that—

(1) carry out parent education, and family engagement in education, programs; or

(2) provide comprehensive training and technical assistance to State educational agencies, local educational agencies, schools identified by State educational agencies and local educational agencies, organizations that support family-school partnerships, and other organizations that carry out such programs.

(b) MINIMUM AWARD.—In awarding grants under this section, the Secretary shall, to the extent practicable, ensure that a grant is awarded for a statewide family engagement center in an amount not less than $500,000.

(c) MATCHING FUNDS FOR GRANT RENEWAL.—Each organization or consortium receiving assistance under this part shall demonstrate that, for each fiscal year after the first fiscal year for which the organization or consortium is receiving such assistance, a portion of the services provided by the organization or consortium is supported through non-Federal contributions, which may be in cash or in-kind.

(d) TECHNICAL ASSISTANCE.—The Secretary shall reserve not more than 2 percent of the funds appropriated under section 4506 to carry out this part to provide technical assistance, by competitive grant or contract, for the establishment, development, and coordination of statewide family engagement centers.

 

SEC. 4503. (20 U.S.C. 7243) APPLICATIONS.

(a) SUBMISSIONS.—Each statewide organization, or a consortium of such organizations, that desires a grant under this part shall submit an application to the Secretary at such time and in such manner as the Secretary may require, which shall include the information described in subsection (b).

(b) CONTENTS.—Each application submitted under subsection (a) shall include, at a minimum, the following:

(1) A description of the applicant’s approach to family engagement in education.

(2) A description of how the State educational agency and any partner organization will support the statewide family engagement center that will be operated by the applicant including a description of the State educational agency and any partner organization’s commitment of such support.

(3) A description of the applicant’s plan for building a statewide infrastructure for family engagement in education, that includes—

(A) management and governance;

(B) statewide leadership; or

(C) systemic services for family engagement in education.

(4) A description of the applicant’s demonstrated experience in providing training, information, and support to State educational agencies, local educational agencies, schools, educators, parents, and organizations on family engagement in education policies and practices that are effective for parents (including low-income parents) and families, parents of English learners, minorities, students with disabilities, homeless children and youth, children and youth in foster care, and migrant students, including evaluation results, reporting, or other data exhibiting such demonstrated experience.

(5) A description of the steps the applicant will take to target services to low-income students and parents.

(6) An assurance that the applicant will—

(A) establish a special advisory committee, the membership of which includes—

(i) parents, who shall constitute a majority of the members of the special advisory committee;

(ii) representatives of education professionals with expertise in improving services for disadvantaged children;

(iii) representatives of local elementary schools and secondary schools, including students;

(iv) representatives of the business community; and

(v) representatives of State educational agencies and local educational agencies;

(B) use not less than 65 percent of the funds received under this part in each fiscal year to serve local educational agencies, schools, and community-based organizations that serve high concentrations of disadvantaged students, including students who are English learners, minorities, students with disabilities, homeless children and youth, children and youth in foster care, and migrant students;

(C) operate a statewide family engagement center of sufficient size, scope, and quality to ensure that the center is adequate to serve the State educational agency, local educational agencies, and community-based organizations;

(D) ensure that the statewide family engagement center will retain staff with the requisite training and experience to serve parents in the State;

(E) serve urban, suburban, and rural local educational agencies and schools;

(F) work with—

(i) other statewide family engagement centers assisted under this part; and

(ii) parent training and information centers and community parent resource centers assisted under sections 671 and 672 of the Individuals with Disabilities Education Act (20 U.S.C. 1471; 1472);

(G) use not less than 30 percent of the funds received under this part for each fiscal year to establish or expand technical assistance for evidence-based parent education programs;

(H) provide assistance to State educational agencies, local educational agencies, and community-based organizations that support family members in supporting student academic achievement;

(I) work with State educational agencies, local educational agencies, schools, educators, and parents to determine parental needs and the best means for delivery of services to address such needs;

(J) conduct sufficient outreach to assist parents, including parents who the applicant may have a difficult time engaging with a school or local educational agency; and

(K) conduct outreach to low-income students and parents, including low-income students and parents who are not proficient in English.

(7) An assurance that the applicant will conduct training programs in the community to improve adult literacy, including financial literacy.

(c) PRIORITY.—In awarding grants for activities described in this part, the Secretary shall give priority to statewide family engagement centers that will use funds under section 4504 for evidence- based activities, which, for the purposes of this part is defined as activities meeting the requirements of section 8101(21)(A)(i).

 

SEC. 4504. (20 U.S.C. 7244) USES OF FUNDS.

(a) IN GENERAL.—Each statewide organization or consortium receiving a grant under this part shall use the grant funds, based on the needs determined under section 4503(b)(6)(I), to provide training and technical assistance to State educational agencies, local educational agencies, and organizations that support family-school partnerships, and activities, services, and training for local educational agencies, school leaders, educators, and parents—

(1) to assist parents in participating effectively in their children’s education and to help their children meet challenging State academic standards, such as by assisting parents—

(A) to engage in activities that will improve student academic achievement, including understanding how parents can support learning in the classroom with activities at home and in after school and extracurricular programs;

(B) to communicate effectively with their children, teachers, school leaders, counselors, administrators, and other school personnel;

(C) to become active participants in the development, implementation, and review of school-parent compacts, family engagement in education policies, and school planning and improvement;

(D) to participate in the design and provision of assistance to students who are not making academic progress;

(E) to participate in State and local decisionmaking;

(F) to train other parents; and

(G) in learning and using technology applied in their children’s education;

(2) to develop and implement, in partnership with the State educational agency, statewide family engagement in education policy and systemic initiatives that will provide for a continuum of services to remove barriers for family engagement in education and support school reform efforts; and

(3) to develop and implement parental involvement policies under this Act.

(b) RULE OF CONSTRUCTION.—Nothing in this section shall be construed to prohibit a statewide family engagement center from—

(1) having its employees or agents meet with a parent at a site that is not on school grounds; or

(2) working with another agency that serves children.

(c) PARENTAL RIGHTS.—Notwithstanding any other provision of this section—

(1) no person (including a parent who educates a child at home, a public school parent, or a private school parent) shall be required to participate in any program of parent education or developmental screening under this section; and

(2) no program or center assisted under this section shall take any action that infringes in any manner on the right of parents to direct the education of their children.

 

SEC. 4505. (20 U.S.C. 7245) FAMILY ENGAGEMENT IN INDIAN SCHOOLS.

The Secretary of the Interior, in consultation with the Secretary of Education, shall establish, or enter into contracts and cooperative agreements with, local tribes, tribal organizations, or Indian nonprofit parent organizations to establish and operate family engagement centers.

 

SEC. 4506. (20 U.S.C. 7246) AUTHORIZATION OF APPROPRIATIONS.

There are authorized to be appropriated to carry out this part $10,000,000 for each of fiscal years 2017 through 2020.

90 Comments

  1. NDSC is a member-sustained, nonprofit organization, which works to promote the interests of people with Down syndrome and their families through advocacy, public awareness, and information. We appreciate the opportunity to provide input on the Every Student Succeeds Act provisions for the Statewide Family Engagement Center Program. Specific suggestions based on the legislation are provided below:

    SEC. 4502. GRANTS AUTHORIZED

    SEC. 4502 (a) (1): Clarify that Statewide Family Engagement Centers (SFECs) must build capacity for high-impact family and community engagement that is linked to learning and supports child development, student achievement, and school improvement. We suggest adding a reference to the HHS/ED Joint Statement on Family Engagement in Early Childhood (see https://www2.ed.gov/about/inits/ed/earlylearning/files/policy-statement-on-family-engagement.pdf).

    SEC. 4502 (b) MINIMUM AWARD: We suggest a maximum grant amount of $750,000 to ensure that a minimum of 15 grant awards will be made (with the maximum awards being 20).

    SEC. 4502 (c) MATCHING FUNDS FOR GRANT RENEWAL: We suggest placing NO MINIMUM amount (e.g., percentage of grant) requirement for matching funds for grant renewal.

    SEC. 4503. APPLICATONS.

    We suggest that applications be restricted to, or at least that additional points be provided for, organizations that are physically located in the state they intend to serve (and that such location is their primary place of doing business); and that directly serving families and not just schools or districts be a strong component of the application. We also suggest that priority be given to not-for-profit family engagement organizations that already have a demonstrated statewide presence.

    In addition, applicants should demonstrate their experience working in urban and rural Title I communities with culturally, racially and linguistically diverse students and families as well as families of students with disabilities.

    SEC. 4503 (F)(ii): We recommend that, for the purposes of any awards under this legislation, the applicants/awardees include evidence of work with parent training and information centers and community parent resource centers under the Individuals with Disabilities Education and that this evidence must be through memoranda of agreement (MOAs) and/or subcontracts with parent training and information centers and/or community parent resource centers from the state to be served. These Parent Centers have extensive demonstrated expertise in reaching and serving families (of children with and without disabilities) despite shrinking resources. SFEC applicants must be required to budget for Parent Center(s) for that state to be funded partners in the SFEC, as well as being represented on the Special Advisory Committee.
    SEC. 4503 (G): We suggest language that makes it clear that this program is intended to support and enhance family engagement from the early years through graduation and recommend reference to terms and strategies in the Family Engagement from the Early Years to the Early Grades Joint Policy Statement. (www2.ed.gov/about/inits/ed/earlylearning/files/policy-statement-on-family-engagement.pdf)
    SEC. 4503 (J): We strongly recommend that applicants be required to demonstrate their ability to reach and engage families not previously involved in their children’s education.

    SEC. 4503 (K): Specify that the applicant should be able to demonstrate experience in implementing culturally responsive family engagement.

    Evaluation: Specific program evaluation requirements should focus on outcomes versus solely outputs to ensure that programs are proven to be effective in advancing high-impact family, school, and community engagement. Outcome-based evaluation will also improve opportunities for these programs to be sustainable and scalable, greatly expanding the potential impact of this funding. Additionally, we suggest that grant applicants submit a theory of change and logic model to show the ultimate impact of this work in advancing statewide family engagement policy and practice.

  2. Children’s Aid is grateful for the opportunity to provide input on the Statewide Family Engagement Centers (SFEC) Program authorized by the Every Student Succeeds Act (ESSA). For 165 years, Children’s Aid has been committed to ensuring that there are no boundaries to the aspirations of young people, and no limits to their potential. We are leading a comprehensive counterattack on the obstacles that threaten kids’ achievements in school and in life. We have also constructed a continuum of services, positioned every step of the way throughout childhood, that builds well-being and prepares young people to succeed at every level of education and every milestone of life. Today our over 2,000 full- and part-time staff members empower nearly 50,000 children, youth and their families through our network of 40+ locations—including early childhood education centers, public schools, community centers, and community health clinics—in four New York City neighborhoods: Harlem, Washington Heights, the South Bronx, and the north shore of Staten Island.

    Parent and family engagement is a foundational component of the Children’s Aid mission. For nearly a decade, we have been supporting parents and families through our Ercilia Pepin Parent Leadership Institute in the Washington Heights community. More recently, our federally funded Family Success Network (modeled after the Ercilia Pepin Leadership Institute) has firmly established parent and family engagement in six South Bronx community schools. Four critical elements in our parent and family engagement approach are: 1) Parent Engagement Coordinators, who serve as community leaders and systematically integrate parent engagement into schools; 2) Parent Resource Centers, which help parents develop strong school and community ties; 3) Adult Education through a variety of classes and workshops to help build skills; and 4) Leadership Development opportunities so our parents can become active community members through volunteering, advocacy projects, and lead and/or serve on parent associations. With these four elements at the core of our parent and family engagement approach, we have engaged over 2,500 parents in the two communities combined.

    What has been authorized in ESSA is very strong, and we are encouraged that parent and family engagement is codified in legislation. We would also recommend the following:

    • Define “parent” and “family” broadly and comprehensively (i.e., same gender parents, grandparents, foster parents, uncles/aunts, neighbors, etc.).
    • Include program language that promotes a community of caregivers and role models through intentional community engagement approaches.
    • Address the needs and interests of parents and families through the development of parent leadership and decision-making pathways
    • Ensure family engagement strategies acknowledge a lifelong culture of learning and academic achievement at home through various knowledge and skills attainment opportunities (i.e. adult education, English-as-a-Second Language, children’s executive functioning skills, financial literacy etc.).

  3. Lawyers’ Committee for Civil Rights Under Law Provides Input to U.S. Department of Education on Ensuring the Statewide Family Engagement Center Program Benefits Students of Color and Students with Disabilities

    The Parental Readiness and Empowerment Program (PREP) at the Lawyers’ Committee for Civil Rights Under Law (Lawyers’ Committee) strongly believes that family engagement is a vital component of students’ scholastic success and overall development. Presented with this opportunity to provide feedback to the U.S. Department of Education on the Statewide Family Engagement Center Program, we encourage the Department to focus on providing effective, evidence-based, sustainable family engagement programming for African-American, Latino, and other minority communities.

    The Lawyers’ Committee is a nonpartisan, nonprofit organization formed in 1963 at the request of President John F. Kennedy to involve the private bar in providing legal services to address racial discrimination. Now in its 55th year, the Lawyers’ Committee continues its quest to “Move America Toward Justice.” Since 2010, PREP has been working to improve K-12 student performance, reduce the racial achievement gap, and provide access to equal educational opportunities for low-income and minority children by increasing parental engagement and ensuring that parents become successful advocates for their children. To this end, PREP facilitates workshops and launched a national online platform, which provide parents with legal information from trained volunteers and resources on their children’s educational rights. The statewide family engagement centers funded through this program will be able to provide critical services and supports to the families that PREP serves, strengthening their connections to their children’s schools and building their own capacity to advocate on behalf on their children.

    To ensure that the funded applications for statewide family engagement centers will effectively advance community engagement for students of color and in low-income communities, PREP believes that aspects of the application process should be modified with more targeted requirements. Therefore, we have provided some suggestions for prioritizing applications and refining criteria to be demonstrated by applicants, including:

    • Section 4502(a)(1): This subsection should be modified to make clear that program funding is for statewide family engagement centers to develop successful family and community engagement programs that support scholastic achievement and personal development for students. Programs should also focus on meeting the needs of the vulnerable students who stand to gain the most from improved family engagement, such as students of color, students with disabilities, and English language learners.

    • Section 4503(b)(4): To ensure that programs will include a focus on advancing racial equity and serving the vulnerable families and students who stand to benefit the most from improved parent engagement, we suggest that priority be given to applicants who can demonstrate their experience working in low-income communities with culturally, racially, and linguistically diverse students and families.

    • Section 4503(j): Applications should include a discussion of the applicant’s experience and ability reaching and engaging with families not previously involved with their child’s school. The text’s focus on “sufficient outreach” is not effective if these family engagement centers and their programs do not bring vulnerable families into the fold as engaged educational partners with the capacity and awareness of the ways in which they can support their children and their education.

    • Section 4503(k): This language on “conduct[ing] outreach to low-income students and parents, including low-income students and parents who are not proficient in English” should be amended to further specify that applicants should include a description of their experience implementing culturally responsive family engagement programs. Absent such experience and focus from these programs, the program will fall short on engaging vulnerable families and families of color in their children’s education.

  4. General comments:
    Perhaps some funding could be made available to Community Based Non Profit organizations. This would allow a neutral, third party entity to carry out the family engagement/involvement functions, a voice from outside the education system. Family-run organizations are uniquely qualified to deliver training to parents/caregivers and help them learn to advocate within the schools and at local, state, and federal levels for change. Families are more engaged when they have support partners to help them address educational challenges, advocate for the unique needs of their child(ren) and connect them with resources. This “parent peer support” has been proven to increase parent self-efficacy and empowerment and decrease isolation.

    Families must be meaningfully involved in all of the decision making processes that impact their children, including safety, nutrition, what do to when a child doesn’t have money on a school lunch account, etc.

    In addition to family engagement, we suggest incentivizing Youth engagement. What do youth say they want/need in school? Perhaps this is an opportunity to establish a Statewide Youth Council and platforms for youth advocacy within the LEAs and schools.

    The current language is very specific and limited to education. The reality is that factors outside of public education very much impact student success – it is not a silo. Suggest including expectations around caring relationships, academic standards and achievement, and opportunities for participation and contribution, but expand to include other protective factors: Parental Resilience, Social Connections, Concrete Support in Times of Need, Knowledge of Parenting and Child Development, Social/Emotional Competence of Children. Partnerships with community-based organizations, including peer and family-runs, integrated health agencies, youth development programs, child welfare, and juvenile justice services are critical to family engagement and school success. Perhaps coordination with other systems could be rewarded in the evaluation process.

    Suggest the Statewide Family Engagement Centers utilize an ecological model to see how the community impacts education and the public policy role. Centers could benefit from engaging community-based organizations, particularly family run organizations, as providers of parent education/training and subject matter experts on family engagement. Suggest Centers participate in state or county multidisciplinary service planning (wrap around or child and family teams).

    Specific comments:
    SEC 4502 (a) (2) suggest adding language indicating that “other organizations” include Parent Training & Information and Parent-Run organizations

    SEC. 4503. (b) (3) (B) suggest “or” be changed to “and” to ensure the plan includes both statewide leadership and systemic services for family engagement.

    SEC 4503. (b) (5) suggest a description is included of the steps the applicant will take to target services to students with unstable school attendance/chronic absenteeism. This approach may very well need to address the social determinants of health, a concept broader than just income.

    SEC 4503. (b) (6) (A) suggest clarifying the roles and responsibilities of the special advisory committee. Having a committee alone is not an effective parent engagement strategy. It is not enough to invite parents to the table for conversation. They must have the opportunity to use their perspectives and experiences to influence decisions, resulting in meaningful change. If a different result is desired, schools will need to modify their approach, programs, support, services, partnerships, priorities, etc. Parents of “disadvantaged students” must be instrumental in shaping these new strategies.

    SEC 4503. (b) (6) (A) (i) suggest the representative parents reflect the diversity of the student population, particularly “disadvantaged students” listed in (B) as ELLs, minorities, students with disabilities, homeless, foster care, and migrant students. If these students are the most disadvantaged, then they are most in need of representation in parent empowerment/engagement.

    SEC 4503. (b) (6) (A) (vi) suggest adding representation from Family-Run or PTI organizations

    SEC 4503. (b) (6) (B) suggest being more specific regarding “students with disabilities” to include mental and behavioral health…”

    SEC 4503. (b) (6) (J) suggest adding language about removing barriers to participation

    Section 4503. (b) suggest adding “A description of the applicant’s intention of utilization of peer parent support in the training and education of other parents, in topic areas such as Parental Safeguards and Rights in the Special Education Process, Non-adversarial Advocacy, Parent/Professional Partnerships, Understanding children’s behavior, and how trauma specifically affects a child’s behavior.”

    SEC. 4503. (b) (6) suggest adding “Provide assistance (and Training) to classroom educators on Parent/Professional Partnerships, Family-Driven, Youth-Guided Care, and The impact of trauma on a child’s behavior.”

    SEC. 4504 (a) (1) (A) suggest adding language about stable attendance (in addition to improving academic achievement)

  5. Thank you for the opportunity to provide input on the Statewide Family Engagement Centers program. Please consider the following recommendations to help ensure high-quality program implementation that will build the capacity of SEAs and LEAs to implement systemic family engagement initiatives to improve student achievement, strengthen youth development, and support school improvement.

    Eligible Entities:
    Recommend that the U.S. Department of Education (ED) restrict awards to nonprofit entities, universities, or a consortium of nonprofit statewide organizations for this grant competition.

    Awards:
    To ensure that awards are sufficient in size to match the needs of populations served and ability to implement the scope of work in a high-quality manner, grant awards should fall within the funding range of $650K–$1.2 Million.
    In some states there is minimal organizational capacity to provide these services and these states often have a higher need for capacity building in family engagement. To help ensure availability of services across the U.S., consider awarding multi-state or regional grants.

    Partnerships with SEAs:
    The Statewide Family Engagement Centers (Centers) should be aligned with and work closely with SEAs to help expand their capacity for family engagement. Coordination with SEA priorities and initiatives is essential. Evidence of SEA commitment to the Centers should include (1) MOUs signed by the state chief education officer, (2) annual planning meetings with the SEA and Centers that result in updated annual plans for the grantees, (3) agreement that SEA staff are included in Center advisory committees.

    Priorities:
    Recommend that ED place a higher priority or competitive priority for Centers that “provide comprehensive training and technical assistance to State educational agencies, local educational agencies, schools identified by State educational agencies and local educational agencies, organizations that support family-school partnerships, and other organizations that carry out such programs.”

    Evaluation and Annual Performance Reports:
    Grantees should be required to conduct coordinated and aligned evaluations so that consistent data can be aggregated across projects. A minimum of 5% of funds granted should be dedicated to evaluation. In addition, establishment of Government Performance Results Act (GPRA) measures for grantee Annual Performance Reports (APRs) should be aligned to grantee outcomes (vs. only outputs) and be relevant to grantee objectives.

  6. Thank you for the opportunity to comment on the Statewide Family Engagement Centers. It is important to note that while statewide centers may have the capacity to serve a larger number of families, grassroots agencies have the capacity to serve and are more familiar with those families most in need of services (very often, for a lower cost). Because of this, PARENT POWER proposes that a percentage of funding given to statewide agencies must be shared with grassroots agencies that are (and have been) serving families.

    We do not expect the Statewide Family Engagement Centers to continue to support the status quo and we are hopeful that they will seek innovative ways to engage ALL families in their children’s learning. We expect to seek authentic collaboration between school/district administrators and the families and communities served. We also expect to see some measure of accountability for administrators in schools and districts who choose to exclude family and community members in decision making. Lastly, we would like to see a non-political, grassroots, local and statewide family and community engagement council that is responsible for monitoring effective partnership practices of the Statewide Family Engagement Centers, districts and schools and providing a report card (or some other assessment) for family and community members, schools and districts to compare and contrast what works and what does not .

  7. Thank you for the opportunity to provide feedback on this important piece of legislation. I have a few comments and questions:

    – The text of the legislation uses the word “parent” quite often – for inclusivity, please write include “guardian” or “family member” along with just parent.

    – How will the members of the advisory committed be selected and vetted? This should be specified from the start to ensure a representative and equitable committee is formed.

    – Each applicant should also provide a plan for how to utilize technology to provide resources for families/schools/districts in the state that may not be geographically near the Resource Center. Perhaps each Center should have a corresponding website (and/or social media accounts) with shared resources to reach as many people as possible.

    – Each applicant should also specify how it plans to collect data to inform short- and long-term evaluation. Systems for tracking touchpoints with families, schools, and districts need to be in place prior to the provision of services. Thinking about what information needs to be collected for meaningful reflection on practice must occur during the application phase.

  8. Partners for Each and Every Child Response to U. S. Dept. of Education Request for Comments on Statewide Family Engagement Center Program

    Partners for Each and Every Child (Partners for) is pleased to provide feedback on the implementation planning for Statewide Family Engagement Centers (SFECs). We focus on advancing equity and excellence for all children in the US — i.e. prioritizing high-quality schools and learning opportunities for our most vulnerable students and communities. We believe that families have critically important insight into the needs and strengths of their school, and are most invested in its success. By meaningfully engaging families in decision-making, school communities are strengthened, and students better served.

    There is an urgent need to change inequitable patterns and processes for schooling. Without explicit, fully resourced efforts and the deliberate inclusion of underserved communities, commitments to equity fall short and perpetuate, rather than remedy, disenfranchisement. We recommend five (5) pillars of meaningful engagement as essential for equity. Applicants should demonstrate how they will ensure:

    1. REPRESENTATION: Reach the Unreached —Prioritization of the needs, participation, and leadership of historically marginalized communities and those underserved by political decision-making processes;.
    2. TRANSPARENCY: Show Your Work —Making transparent the process for decision-making, enabling all communities to easily understand when and how to participate, and how their participation is valued and has real impact.
    3. SUSTAINABILITY: Stick With It — Support for family participation in structured, regular ways in the earliest planning stages of policy, continuing throughout implementation, and at all levels.
    4. COLLABORATION: Maximize Your Resources — Collaboration with partners to strengthen engagement efforts through added resources, staff, intellectual capital, and new perspectives.
    5. ALIGNMENT: Double Down — Aggregation and analysis of community feedback from separate and parallel efforts to identify areas of agreement, amplify the voices of the underserved, and build support for reform.

    We believe that well-defined and specific requirements, priorities, selection criteria, and definitions are essential to ensuring that funded applications are able to effectively design and support high-impact family, school, and community engagement for underserved communities.

    Accordingly, we recommend that the Department use and provide applicants reference to NAFSCE’s definition of high-impact family engagement as well as US ED’s evidence-based Dual Capacity-Building Framework for Family-School Partnerships.

    Specific suggestions based on the legislation include:

    SEC. 4502 (1) Partners for believes the current statutory language is too ambiguous regarding the core purpose of the program. We suggest adding language specifically stating that funding for SFECs is to build school and district capacity for high-impact family and community engagement that is linked to learning and supports child development, student achievement, and school improvement. We believe a definition for what constitutes high-impact family engagement should be provided to applicants to guide design and program development. We recommend that funded programs be required to support family engagement that is systemic, that incorporates family engagement strategies across all learning goals, and that is integrated into the fabric of school operations and culture, including educator and principal professional development and evaluation.

    SEC. 4503 (2): Partners for believes that committed and demonstrated support from State Education Agency (SEA) leadership is crucial to the success of the SFECs. Therefore, we suggest that this language be strengthened to require evidence of SEA commitments, including existing programs, staff, resources, and structures to strengthen family engagement policy and practice; demonstrated SEA involvement in program planning; and a sign-off requirement from the SEA Chief to US ED as evidence of SEA’s commitment to meaningful and inclusive engagement.

    SEC. 4503 (b) (4): We suggest requiring applicants to demonstrate their experience in high-impact family engagement with regard to training, support and implementation expertise
    specifically for parents and families of low-income, English learner, homeless and migrant students, as well as students of color, and students with disabilities. This specificity is more likely to ensure programs and services target the most severely underserved communities, are linked to learning and student achievement and/or school improvement, and are supporting equitable educational outcomes. To ensure that programs focus on advancing equity, applicants should demonstrate their experience working in urban and rural Title I communities with culturally, racially and linguistically diverse students and families. We suggest that priority is given to non-profit family engagement organizations with a demonstrated statewide or multi-state presence.

    SEC. 4503 (b) (5): Partners for agrees that it is critically important that applicants be required to explicitly describe their capacity-building efforts to strengthen school and district engagement with low-income students and parents and to explain how they plan to work with other organizations to achieve this goal.

    SEC. 4503 (b) (6)(G): Partners for suggests that capacity-building programs must have a birth through grade 12 approach, to ensure that family engagement is addressed at all stages of child development. To clarify the specific types of educational programs being addressed, we suggest changing “evidence-based parent education programs” to “evidence-based parenting education programs and family engagement in education programs.” The term “parenting education programs” speaks to education focusing on the activity of parenting. “Family engagement in education programs” maintains the focus on strengthening relationships between families and schools.

    SEC. 4503 (b) (6) (J): Applicants should demonstrate their ability to reach families not previously engaged with their child’s school, and/or those representing underserved and underperforming students. The words “sufficient outreach,” alone, will not encourage meaningful and effective practices. Instead, this section should specify that efforts will prioritize greater engagement among vulnerable families.

    SEC. 4503 (b) (6) (K): Partners for recommends requiring applicants to demonstrate their experience with implementing culturally responsive family engagement. We believe the absence of this language will undermine the commitment to advancing equity and opportunity for all students.

    Programs must be effective in advancing high-impact family, school, and community engagement. Program evaluation requirements should focus on outcomes and outputs. Outcome-based evaluation will improve opportunities for programs to be sustainable and scalable, greatly expanding the program’s impact. Additionally, grant applicants should submit a theory of change and logic model to show the ultimate impact of this work in advancing family engagement policy and practice.

  9. The Alliance for Strong Families and Communities would like to thank the Department of Education for the opportunity to share our expertise in helping children, families, and communities across the nation achieve their full potential. The Alliance is a network of nonprofit professionals in the social sector driving to achieve a healthy and equitable society. As a strategic action network, we work alongside our members to ensure that all people have equal access and opportunity to health and well-being, educational success, economic opportunity, and safety and security. Our network’s commitment to educational success includes elevating parent and family voice and engagement in educational settings in ways that enhance and support child well-being and elevate equity.

    Children and families are better able to succeed in school and realize their full potential when educational systems address the full context of their lives, including culture, neighborhood, community, family, social emotional health and wellbeing. Policy efforts to further educational success for children and their families must therefore be embedded in a systems approach, working to align community-based organizations, government agencies, and funding streams across the entire education pipeline to promote evidenced-based interventions. We know every student, family, and community is more likely to achieve their full potential when they have a strong foundation that enables them to thrive, no matter their current situation, socio-economic status, or geographic location. Thus, legislation that strives to move the needle on parental and family engagement in schools, must also address the full context of family and community life.

    Educational disparities are clearly evident for children experiencing trauma, children with different abilities, and children of color. These children are less likely to be performing at grade level, more likely to be suspended or drop out of school, and more likely to be in schools with fewer resources. At the core of these disparities are resource gaps in academic and family supports, a lack of coordination across systems, education systems that don’t incorporate the latest in brain science to support trauma-informed interventions for students, racial bias, and a lack of trust in systems by children and families that need that most support.

    Nevertheless, there are evidence-informed and promising practices for addressing these root causes and closing disparities in academic achievement and family and community involvement. In seeking to promote transformational change the Alliance believes that programs which address the need for increased supports and resources for parental and family engagement should reflect the following:
    • Engagement of student, family, and community voice and assets throughout the policymaking, program implementation, and evaluation process.
    • Advancement of equity by reducing racial and economic disparities in access and opportunity to educational supports within their residing neighborhood. Specifically, parents should be supported in navigating the education system to make the best choices for their child’s academic achievement.
    • Prevention and early response strategies throughout the education pipeline to proactively build on family and community strengths to create a strong foundation for academic success.
    • Implementation of the latest in brain science research so that programs support the whole child and family through trauma-informed interventions and socio-emotional learning that promotes resiliency.
    • Multigenerational supports for children and families that places community context at the center of program design.
    • Systems alignment strategies which incorporate all systems that touch the lives of children, families and communities to remove systemic and structure barriers to the coordination of educational success and engagement of parents and families in academic achievement.

  10. Ideas for Consideration:

    At a federal level serve as a stimulus to encourage economic development at federal, state regional and local levels to address poverty, housing and access to services in rural, inner ring cities and urban areas that will work to close the opportunity gap that occurs prior to school entrance and continues to affect student achievement through high school. Encourage applicants to opt into a cross systems demonstration programs with coordination from federal advisory council.

    Encourage and model collaboration through a federal advisory council among family support systems and organizations such as Center for the Study of Social Policy and the National Family Support Network, education systems (including early care and education services such as Head Start, child care, evidence based home visitation, early intervention), out of school time programs and systems, health systems, research and practice leaders such as NAFSCE and Global Family Research and parent voices represented directly and through PTA, and Parent Information Centers (not and exclusive list; many other resourceful entities exist).

    Recommendations
    Ensure that a statewide center that provides Professional Development and Technical Assistance to the SEA, Regional Education Agencies and LEAs has sufficient resources to also provide direct services to families as suggested by some of the language in the description. The suggested funding levels are not likely to be adequate.

    Clarify definition of family engagement for this work. Parenting education conveys teaching parents how to parent; partnering with parents or family engagement with their children’s education process conveys working together on shared goals. Reaching out and effectively connecting with families who have been underrepresented in school activities and leadership opportunities may have more resonance for them when approached in a way that honors family culture, acknowledges family strengths and invites collaborative participation.

    Encourage SFEC applicants to build on the work of family engagement practices (family-school-community partnerships teams, family-family peer led activities, family friendly reviews, strengthening families protective factors, and other work), research, and recent PIRC experiences as they develop systems and roles for program staff, schools, community partners and family members. Utilize guidance from “Beyond Random Acts” and the “Dual Capacity Framework” emphasizes the shared responsibility for student success, acknowledges the continuity of family engagement (from birth through graduation) and that learning occurs in multiple places (home, community programs, child care, out of school time and more). Focus the work of the SFEC on developing family engagement systems that are integrated into academic subjects and social emotional learning, include accountability measures, and can be sustained.

    Encourage SFEC applicants and provide resources to include evaluation of outcomes of its work including regular feedback from parents/family members in schools/systems directly affected by SFEC work.

  11. Rosazlia Grillier and Felipa Mena, Co-Presidents, POWER-PAC Illinois and Ellen Schumer, Executive DIrector, COFI says:

    Community Organizing and Family Issues (COFI) is a 22-year old Chicago-based nonprofit center for parent leadership development and engagement. Over the years, 4000 parents (across the State of Illinois) have been through COFI training and those parents, in turn, have built POWER-PAC- Illinois, a statewide organization of low-income parents of color united to make their communities, state and nation better for all children and families.

    We appreciate the opportunity to provide feedback on the implementation planning for Statewide Family Engagement Centers (SFECs). We are excited that the Every Student Succeeds Act (ESSA) highlights the need for stakeholder, and particularly parent, engagement in decisions that affect the education of children. COFI and POWER-PAC Illinois believe that the Department of Education’s (US ED’s) implementation of the Statewide Family Engagement Center (SFEC) program should reflect that strong commitment to bringing the voices of parents at the table to advise in the design and roll-out of all family engagement programs. (We point to to Section 4504, part a1C, a1D, and a1E of Title IV of ESSA. This part of the statute requires SFECs to promote families’ roles in systems leadership, program design, and decision-making.)

    As POWER-PAC Illinois members know firsthand, when parents bring their real-world perspectives to the policymaking table, the outcomes for children improve. We ask US ED to apply ESSA’s demands for community and family leadership to the SFEC program. Applicants should be required to show how they parents’ voices and expertise are being tapped in all aspects of their work. Grantees should be required to demonstrate authentic family leadership of their program – and that they are doing so in partnership with parent groups – as part of their evaluation and commitment to equity.

    Additionally, we are concerned that the FY 2018 appropriation is not enough to allow the SFECs’ abilities to live up to their potential. $500,000 is not enough in a state the size of Illinois to meet the goals as proposed. We would hope that the US ED would consider a larger commitment to these Centers.

    We also would like to suggest adding language to clarify that the Centers will have a birth through grade 12 approach to family engagement and leadership to ensure that family engagement is addressed at all stages of child development. To clarify the specific types of educational programs being addressed, we suggest changing “evidence-based parent education programs” to “evidence-based parenting education programs and family engagement and leadership in education programs.” The term “parenting education programs” speaks to education focusing on the activity of parenting versus generalized education for parents. Adding “family engagement and leadership in education programs” maintains the focus on family engagement.

    We also suggest that, in SEC. 4503 (J), applicants should have to demonstrate their ability to reach and engage families not previously engaged with their child’s school. “Sufficient outreach” is not effective to assure that these programs reach the most vulnerable families.
    Here in Illinois, we have played an instrumental role in getting the State of Illinois to pass a new framework on parent engagement and to commit to creating a new Family Advisory Committee (currently aimed at informing Illinois’ early childhood development programs and policies). We would like to see the SFEC program also be informed by a new Federal Parent and Family Advisory Council to advise the Department on the best strategies for ensuring impact and sustainability of the program. Parents are the experts on the systemic change and program innovation required for effective family engagement. Connecting parents to all levels of leadership in relation to SFECs – local, state, and federal – is the best way to ensure the program’s success.

    Again, thank you for the opportunity to comment and we look forward to the next steps in this process.

  12. National Parent Leadership Institute
    COMMENTS ON STATEWIDE FAMILY ENGAGEMENT CENTERS (SFECs)

    National Parent Leadership Institute(NPLI) believes that the SFECs proposed by the US Department of Education should not be created and implemented without the input and consideration of family leaders as decision makers. For too many children and youth, outcomes for learning are too low and are almost always inequitable along race and class lines. When state policy makers search for solutions, parent voices are often missing from the conversations on how to improve outcomes for children. NPLI contends the creation of SFECs should model the importance of parent leaders by engaging them as thought and action leaders in the development process and beyond.

    The Every Student Succeeds Act (ESSA) highlights the need for stakeholder engagement in decisions that affect the education of children. NPLI believes that the Department of Education’s (US ED’s) implementation of the Statewide Family Engagement Center (SFEC) program must reflect a commitment to bringing the voices of parents to the design, roll-out, and evaluation of any family engagement effort. We point to Section 4504, part a1C, a1D, and a1E of Title IV of ESSA. This part of the statute requires SFECs to promote families’ roles in systems leadership, program design, and decision-making. These roles should not be token, but rather as partners in the process.

    NPLI brings parent voices to the table. NPLI knows firsthand that when parents bring their real-world perspectives to the policy-making table, outcomes for children improve. We are a national non-partisan entity that partners with local communities across the Country to engage parents as civic leaders. We ask US ED to apply ESSA’s demands for community and family leadership to the SFEC program. For example, applicants should be required to show how they will bring parents’ voices and expertise to all aspects of their work. Grantees should also be required to demonstrate authentic family leadership of their program as part of their evaluation and commitment to equity.

    As another pathway of promotion of families’ roles, NPLI believes that US ED would greatly benefit from a Parent and Family Advisory Council (Council). We believe the Council can advise US ED on the best strategies for ensuring impact and sustainability of the SFEC program. Parents are the experts on the systemic change and program innovation required for effective family engagement. This can also demonstrate another strategy of US ED’s commitment to connecting parents to all levels of leadership in relation to SFEC – local, state and federal – as this is the best way to ensure the program’s success.
    Lastly, NPLI is concerned about the impact of the FY 2018 appropriations amount on the SFECs’ abilities to live up to their potential. With a minimum grant amount of $500,000 and only $10 million to spend, each SFEC could potentially lack the resources needed to meet its goals. Furthermore, we anticipate that many students live in states that won’t have access to any of the supports that SFECs bring. As a national organization with over 25 years of experience and data that demonstrates positive outcomes for children and families when parents are authentically engaged as leaders and partners, NPLI calls on US ED to design the SFEC program for FY 2018 to strategically position it for greater funding in FY 2019 and beyond. The immediate plans for SFECs must have sustainability and growth of the program in mind for all children to have what they need to succeed.

  13. Matching Funds. Additional information is requested on how matching funds (funds v. in-kind) will be calculated and applied to potential grantees.

    Linguistic and Cultural Accessibility. Please ensure that all components of this grant, from the application, award, administration and activities are linguistically and culturally accessible to all parents and families.

    GPRA Measures. What are the assigned GPRA measures and what are the assurances to ensuring the measures do not change or, if they do, it is being done in consultation with grantees and stakeholders?

    Professional Learning for Parents/Families. Can funds be used for direct professional learning opportunities for parents and families?

    Capacity Building. Please recognize that that capacity building includes systematic integration of efforts between families, LEAs and SEAs.

    Location/Structure of Centers. The location of the centers can impact the scope and scale of which areas receive state supports for this work. This has been the case formerly with Parent Information Resource Centers (PIRCs). Locations of PIRCs often times where the sole recipients of the work. We would recommend including opportunities that encouraged the development of regional, LEA-level or building –level family engagement centers. This would allow for greater opportunities to leverage dollars to ensure the work is sustainable and is occurring statewide. This would also allow for more effective manner of evaluating effectiveness and provide models for other LEAs.

    Parent Outreach. We recommend that outreach be tied to parent and families being able to support learning and healthy development outcomes as well as strengthening school improvement efforts.

    Parent Participation. Instead of reinforcing simply “parent participation”, it is important to include language that provides for deep and meaningful ways that SEAS, LEAs and educators can support parents in helping students meet identified outcomes. Further, can there be a goal for parent leadership development as opposed to mere participation?

    Strengths-Based Language. Wherever possible, please ensure that language is crafted that seeks to capitalize on the strengths of parents, families and communities rather than focusing on efforts to improve conditions.

    Training Learning Opporuni v. PLO. Wherever possible, language indicating that parents will be “trained” should be replaced with parents being provide learning opportunities for student growth and healthy development.

    Alignment with USEF FE Dual Capacity Framework. Would encourage the purposes to be aligned to the USDE FE Dual Capacity Framework’s Opportunity conditions. Activities should be aligned with process and organizational conditions.

    Process conditions include the following:
    • Linked to learning
    • Relational
    • Development vs. service orientation
    • Collaborative
    • Interactive

    Organizational Conditions include the following:
    • Systemic: across the organization
    • Integrated: embedded in all programs
    • Sustained: with resources and infrastructure

  14. On behalf of the Governor’s Prevention Partnership, we recommend that Family Engagement Centers focus on chronic absence for students with disabilities whose absenteeism rates (in Connecticut) are 10.7% higher than that of their regular needs counterparts, and students of color whose absence rates are 8.4% higher than that of their white counterparts.
    We recommend using trained mentors who can build relationships with families and use strengths-based, affirming approaches that are inclusive of parents and families. As these relationships develop, mentors can identify barriers to attendance and student success, partner with families to address these barriers and help connect families to needed resources. Working with, families, school administrators and mentor’s frequent communication can create success and plans that are customized to a student and family’s unique needs.
    As a Program manager that runs a school-based mentoring program I see first hand the value that this can bring to schools, students and families.

  15. Advocates for Children of New York (AFC) appreciates the opportunity to provide feedback on the implementation of the Statewide Family Engagement Center (SFEC) Program. Since 1971, AFC has been working in partnership with New York’s low-income families to ensure access to quality education for all children. As a U.S. Department of Education-funded Parent Training and Information Center, we support thousands of families of students with disabilities each year by providing training, individualized guidance, and informational materials in multiple languages. We also house the New York State Technical and Education Assistance Center for Homeless Students (NYS-TEACHS), which works with school districts across New York State to assist them in serving the growing number of students in temporary housing. We offer the following comments based on our extensive experience working with families that face myriad obstacles to engaging effectively with their children’s schools:

    1. We agree with other comments that ask the Department to provide applicants with greater clarity as to what constitutes high-impact family engagement. We support reference to NAFSCE’s definition of high-impact family engagement as well as the Department’s evidence-based Dual Capacity Framework for Family-School Partnerships.

    2. We strongly recommend that in addition to building capacity for schools and government agencies, applicants should be required to work directly with families. It is important that SFECs building the capacity of state and local education agencies remain sensitive and responsive to the diverse range of experiences that families encounter on the ground. Including parents in an advisory committee can help keep the SFEC connected to the needs of the families in their communities, but it is no substitute for continued work with those families through the challenges they see every day.

    3. We strongly recommend that selection favor applicants that are physically located in the state they intend to serve. There are so many variations among the states in terms of cultures, school governance and structure, and stakeholder involvement that grantees without a strong presence in the state will have a harder time promoting family engagement effectively.

    4. To ensure that the program will include a focus on advancing equity, applicants should demonstrate their experience working in urban and rural Title I communities with culturally, racially, and linguistically diverse students and families as well as families of students with disabilities. Applicants also should demonstrate experience in implementing culturally responsive family engagement strategies.

    5. We oppose requiring applicants to obtain a sign-off from the chief of the State Education Agency, which could, in effect, result in delegating to that individual the selection between competing proposals from a state.

    6. With respect to the requirement that SFECs work with Parent Training and Information Centers (PTICs) and Community Parent Resource Centers (CPRCs), we recommend that applicants be asked to provide evidence that they have worked effectively with these entities in the past. In addition, applicants should be encouraged to include in their proposals memoranda of agreement (MOAs) and/or subcontracts with PTICs and/or CPRCs from the state to be served. SFEC applicants should be encouraged also to budget for PTICs and/or CPRCs for that state to be funded partners in the SFEC, as well as being represented on the Special Advisory Committee.

    Thank you for the opportunity to provide input on this important program. We look forward to working with the SFECs once they are up and running.

  16. On behalf of the National Center for Learning Disabilities (NCLD), I write to share our comments on Statewide Family Engagement Centers (SFEC) program and competition design as authorized by the Every Student Succeeds Act (ESSA).

    NCLD represents and works to improve the lives of the 1 in 5 children with learning and attention issues in the United States. Children with learning and attention issues are in every public school classroom in the country, and come from every racial, ethnic, and socioeconomic background. Parents are a critical part of the school community and are the best advocates for their children. For parents of children with disabilities, family engagement is especially important to securing services and supporting their child’s education. The U.S. Department of Education (ED) and the programs it funds have an important obligation to meaningfully engage with parents and support schools and districts in doing the same. High quality family engagement practices ensure that all students are equipped for success in college and life after high school. NCLD asks that ED prioritize programs that are collaborative and inclusive of the disability community and that focus on engaging families early on their child’s education.

    Inclusion
    When designing the competitive grant process, ED should consider awarding grants to programs that have a plan to engage and align with the Parent Training and Information (PTI) Centers in the state, which are funded through IDEA to serve parents of children with disabilities, and have relationships and a demonstrated record of engaging with the disability community. SFECs should conduct activities with all students in mind, including students with disabilities and ensure inclusive practices for students with disabilities and their families. SFEC programs should also provide resources that are inclusive and accessible to people with disabilities. Collaboration and inclusion of the disability community will ensure the success of these programs and benefit all students.

    Early Identification
    In addition, ED should consider selecting programs that are equipped and plan to engage families early on in their child’s educational journey. SFECs can play an important role in ensuring that parents are informed and equipped from the beginning to spot the early signs of learning challenges and partner with the school community to address problems before they become roadblocks to student success. Early and accurate identification of learning disabilities and ADHD in schools is possible, and addressing the issues early can set struggling students on a path for success. But, too often, identification is happening late or not at all. Grants should be provided to programs that provide resources and training for both educators and families to better work together especially as it relates to the disability identification process.

    NCLD is grateful to ED for the opportunity to provide input on the design of this important program. We urge the Department to support programs that prioritize engagement of the disability community and have strategies to support families of students with diverse needs and varied disabilities.

  17. The training and technical assistance provided by the Statewide Family Engagement Centers program needs to go beyond compliance with existing local, state and federal regulations regarding family engagement.

    This new and exciting program should assist state and local education agencies develop standards and measures for family engagement that address the areas of most concern to families in low preforming schools, promote partnerships between families and schools, have the strongest influence on meeting the educational needs of children and fostering parent engagement. Those areas include district and school site decision-making, discipline, human resources, instructional quality, language access, leadership and services for children—particularly the most vulnerable children.

  18. Heather B. Weiss, M. Elena Lopez and Margaret Caspe say:

    Global Family Research Project (GFRP) is a leader in the field of family, school, and community engagement. We bring over thirty years of experience in identifying high-leverage opportunities to spread, scale, and sustain family and community engagement practices and policies so that all children have rich learning opportunities in and out of school.

    ESSA provides states with a significant opportunity to consider how they might use federal funds to strengthen family and community engagement and build schools’ relationships with families as major ways to insure children’s learning and school success. In this process, it is critically important to think and act on key areas that research and related, evolving practice tell us are high-leverage practices that families and communities do to keep children on a learning pathway from birth through high school. Ongoing efforts to engage parent voices in planning and implementing new family and community engagement practices will no doubt suggest additional areas for states to consider.

    Research now shows that when family engagement in children’s learning is a shared responsibility of families, schools, and community organizations, and it is supported in and out of school, it strongly contributes to children’s development and school success. In fostering children’s learning and development, families play multiple roles, including those of teacher, data analyst, co-learner, and advocate for their child and for high-quality schools for all. These roles are strengthened when schools and community organizations reach out to families and develop empowering partnerships based on respect for families’ expert knowledge, values, culture, and diversity.

    GFRP’s review of research and practice shows there are several interwoven and high-leverage areas for family engagement: attendance; the content areas of literacy, science and math; out-of-school-time learning; digital media for learning; transitions for students; focusing on data; and professional learning for educators on working in partnership with families. When braided together, these areas help to form strong, individualized pathways that powerfully contribute to children’s ongoing and cumulative success, from birth until they move into college or a career. Engaging parents as partners around these synergistic areas not only improves that particular aspect of a child’s learning, but can also lead to broader, positive rippling effects greater than the sum of the parts.

    For example, home-visiting programs in the early years can ensure that families know how to support children’s early development and learning and have been shown to reduce achievement gaps due to poverty when children enter kindergarten. Teachers and other family engagement professionals can also learn how to better support families through transition points-such as entering kindergarten or changing schools-that create stress for children and parents. Schools, libraries, and non-profit organizations can work together to develop strategies for supporting families during these transition times. During the school years sharing data with families about their children’s school attendance can lead to fewer absences. School performance data can also open up parent-teacher conversations about enriching students’ academic and social skills through support in the home, classroom, and community. Guiding families on how to access high-quality after-school and community-based summer learning programs can enhance their children’s literacy, science and math skills as well as their social and emotional development.

    Those are just a few examples of how states can work with families and communities to co-construct children’s learning pathways, promote equity, and create opportunities for local agencies to partner in support of effective family engagement that is continuous from birth on, crosses the multiple settings in which students learn, and powerfully contributes to children’s learning and school success.

    Thank you for the opportunity to comment.

  19. As a parent, I urge you to strongly consider funding state organizations that already have a family peer workforce and if possible, already working to elevate family voice and engagement so that we are not having to reinvent the wheel. There are strong family run organizations that work across systems to do this type of work with exemplary outcomes.

    Engaging families and understanding the barriers is most effective when other families who have navigated the system can walk along side them. I urge you to look for these already existing organizations when funding states.

    Also, please consider calling out highly marginalized families (ie., rural, frontier, LGBTQ, multilingual, etc) in the project deliverables so that we don’t unintentionally create increased inequities for these families.

    Finally, while this should be a collaborative with education, please consider funding organizations that can authentically represent the family voice in increasing engagement without being compromised by system ‘think’ or politics. Thank you.

  20. MENTOR Independence Region recommends that Centers emphasize the importance of successful community partnerships and should engage community-based organizations proactively as training providers/subject matter experts in areas of expertise. The statewide leadership for the Family Engagement Centers should include a representative from an organization that works on school-based mentoring aimed at reducing chronic absenteeism to provide a critical voice on supporting students and families. On Sec. 4504 (A) (1) school-based mentoring programs can support increased communication and empower family engagement. Parents are integrated into school-based mentoring models through engaging with the school-based mentor that discusses resources, programming and events for the family that could support student attendance. An emphasis on culturally relevant services for families is critical, including providing resources and materials for families who are ELL like those created by Attendance Works,

  21. (Please see that these comments on other priorities and evaluation are in addition to our other comments submitted.)

    PACER Center is a National Parent Center and also serves as the Parent Training and Information Center (PTI) for Minnesota. At PACER, we have successfully strengthened and systemically improved parental engagement in Minnesota and around the country. Our work to improve parent engagement through the parent center approach has produced positive and long-lasting results and is the cornerstone of improved student achievement and family outcomes in our schools and communities. Given our 16 years of experience being a federally-funded national technical assistance provider, we are happy to provide comments on the Statewide Family Engagement Centers (SFECs) program and competition per the U.S. Department of Education (ED)’s request and where relevant we cite the specific language in the statute to reinforce our points.

    Other Priorities
    While ED has the ability to apply priorities to discretionary grant competitions, we urge caution in expanding the already significant work that an SFEC must undertake to be a successful grantee under this program. Given that SFECs inherently have multiple critical focuses demanding their attention, including statutory requirements to engage with and coordinate between parents, schools and State or Local Educational Agencies; using not less than 65 percent of grant funds to serve high concentrations of disadvantaged students and 30 percent of grant funds to establish or expand evidence-based parental education programs; and a required focus on improving adult and financial literacy, PACER would recommend that ED carefully consider whether to apply additional priorities, and therefore duties, for fear of harming the ability of an SFEC to operate effectively.

    Evaluation
    PACER would recommend incorporating a strong evaluation component into the program requirements. Such requirements should address the dual focuses of SFECs to provide services to both families and state and local education agencies. As such, we would recommend requirements include the development of data that captures the output of SFEC centers’ work as well as the impact of services for families and others. Specifically, we recommend a unified evaluation that all centers have to conduct to demonstrate how program funds are being used and the effectiveness of services provided. The TA provider should be responsible for developing the data collection system and collecting and compiling the data. As part of this unified approach,:

    1) The evaluation should be unified so that all SFECs are collecting consistent data that can be aggregated across projects.
    2) The data should be collected and compiled annually.
    3) The evaluation data should demonstrate the total number of parents and total number of professionals and others served by the program.
    4) The evaluation should measure outcomes and impact of the services provided.
    5) The unified evaluation data requirements should reflect the variety of SFEC services that different programs may provide but not be so specific that they become overly cumbersome.

    Demographic Data
    In collecting demographic data under such an evaluation, any such data should reflect the numbers of parents and professionals served, including data such as numbers of culturally and linguistically diverse families. This quantitative data should also be broken down by numbers served through (1) individual assistance, (2) training, and (3) information dissemination (such as websites, newsletters, resource booths, etc.).

    Outcome Data
    For the outcome data, having the SFECs do a short follow-up survey (4-5 questions) with a sample of families who participate in services would work well. The survey can be completed 4-6 months after the services have been provided, so parents and others have time to use the information they have learned.

  22. PACER Center is a National Parent Center and also serves as the Parent Training and Information Center (PTI) for Minnesota. At PACER, we have successfully strengthened and systemically improved parental engagement in Minnesota and around the country. Our work to improve parent engagement through the parent center approach has produced positive and long-lasting results and is the cornerstone of improved student achievement and family outcomes in our schools and communities. Given our 16 years of experience being a federally-funded national technical assistance provider, we are happy to provide comments on the Statewide Family Engagement Centers (SFECs) program and competition per the U.S. Department of Education (ED)’s request. Our comments are grouped by topic and where relevant we cite the specific language in the statute to reinforce our points.

    Definition of a Statewide organization and Demonstrated Effectiveness
    The statute (in section 4502(a)) establishes eligibility for “statewide organizations or consortia of such organizations” for grants under this program. The intent of Congress here seems clear – that organizations which propose to serve a single state be eligible. Such an approach would forgo a regional or multi-state model under this grant program. While we understand that would mean that not every State would benefit from an SFEC given the total appropriation of $10 million, this statewide approach would ensure that centers are not overextended and would also bolster their ability to effectively serve children, families, states, school districts and schools.

    In addition, we would recommend that ED seek to vigorously review each applicant’s “demonstrated experience” as required to be documented in their application pursuant to section 4503(b)(4). This statutory provision requires a prospective grantee to describe their demonstrated experience, including “evaluation results, reporting and other data exhibiting such demonstrated experience.” Grants should not be awarded to organizations which do not have documentable experience in high quality and effective family engagement. Documentable experience would be a history of working directly and effectively with and being actively engaged with parents, in particular, low-income and underserved parents. For example, ensuring that applicants demonstrate their specific and direct background in family engagement in education rather than indicating experience in other related strands of work such as representing parents or others in the system is critical to grantees being in a position to maximize the resources provided under this program.

    Scope of Services Provided by SFECs
    The SFEC program has a dual focus for centers to both (1) provide direct services to parents and their children and (2) improve the ability of states, school districts and schools to engage with families. We view this dual focus, with the requirement that each grantee determine parental needs and the best means of delivering services under section 4503(6)(I), as essential to effective SFECs. We would urge ED to ensure that all grantees are operating under this dual focus approach.

    Minimum Grant Award (Section 4502(b))
    PACER recommends that ED take several factors into account when establishing a minimum grant level for awards. While Congress provided some direction to ED through the $500,000 amount in section 4502(b), the statute also provides discretion through the modifier “to the extent practicable.” Through our experience as a PTI and a grantee under the prior Parental Information and Resource Center program, we would recommend that the Secretary establish a minimum grant, but at the $350,000 level rather than the $500,000 level mentioned in the statute. \ A $350,000 minimum would provide ED with the flexibility to provide additional resources when and where an application and the service needs of a potential state warrant, while still being able to fund a sufficient total number of centers.

    Matching funds for grant renewal (Section 4502(c))
    The statute (in section 4502(c)) requires that a portion of services provided by grantees be provided through matching resources, in cash or in-kind. We believe this requirement adds value to the statute as it requires grantees to ensure they have non-Federal resources to expend on the provision of services. However, we would not want a matching requirement to serve as a barrier to an otherwise qualified and high-quality organization receiving a grant under this part. For these reasons, we would recommend that the obligation to demonstrate in-kind or matching resources not be overly burdensome for organizations and consortiums receiving assistance under this program. Should these requirements have a very high dollar or in-kind time amount threshold, it may prevent high-quality parent centers from participating.

    Technical Assistance
    The technical assistance provision in section 4503(d) provides that the Secretary reserve not more than 2 percent of appropriated funds to carry out this function through a grant or contract. First, we recommend that any contract or grant provided under this authority be provided on a competitive basis, so SFECs and ED get the most qualified entity as a technical assistance provider. Second, we would urge ED to ensure sufficient funding is provided to a technical assistance contractor or grantee to ensure the services provided are effective and of the scope needed to benefit SFECs. As with our recommendations on demonstrated effectiveness above, only organizations with many years of hands-on experience working with multiple nonprofits, schools and parents which can document their ability to provide high-quality, effective family engagement should be able to compete for a technical assistance grant or contract. Additionally, the technical assistance provider should be responsible for annually developing, collecting, and compiling unified evaluation data from the SFECs.

  23. Thank you for the opportunity to weigh in on effective ways to involve parents and families in DOE’s Family Engagement Center Program. I have been involved in school issues for many years first as a parent and then as staff and a volunteer with various national, regional, and local groups. Engaging busy families is, as you know, no easy task, but I believe communicating that they have real power and that their recommendations will be heard and acted on is critical. The following steps will help:

    1. Inform parents of their rights and address communities’ specific needs (no cookie cutter approaches, please) providing relevant information, skill-building, and leadership development.

    2. Allocate funding and support so centers can use best practices in reaching out to and engaging parents.

    3. Monitor the centers and set high expectations for outreach programming; involve families in developing evaluation systems; and create a transparent, accountable complaint process for cases where the program fails to function appropriately.

    4. Fund an ombudsman-type position to review and assist families with complaints or concerns.

    5. Give parent/family committees real authority to oversee and influence center operations.

  24. Mass Mentoring Partnership strongly recommends including quality school-based and school-integrated mentoring programs because they are an evidence-based strategy that can promote successful family engagement
    and offer a low-cost, sustainable, and systemic family engagement solution that places mentors in the lives of students who are at risk for chronic absence. Chronic absenteeism affects students at every grade level, is the strongest indicator that a student will drop out, and presents barriers for academic success and keeping students on a path to graduation.

    In the U.S. only 56 percent of students who have dropped out report that there was a school staff person they could go to about school problems . Studies have consistently shown that youth in developmental relationships are less likely to skip school, present better attitudes and behaviors at school and at home, and are more likely to attend college than their peers. Reasons for dropping out vary depending on a number of social and economic challenges, but data shows that inequitable access to appropriate academic and social-emotional supports, and poor school climate for youth and their families, often result in poor educational attainment and barriers to successful life outcomes.

    Currently, Mass Mentoring Partnership is advocating for graduation coaches- wraparound, social-emotional support in schools, as a systemic solution to high dropout rates and chronic absenteeism. These graduation coaches connect schools to the student’s families, social services, community-based resources, and provides structured programming that serves as both a wraparound support and a safety net.

    In providing our students with the tools they need to graduate, or work towards an alternative plan for graduation, we position them to earn more money, decrease their likelihood of being dependent on public assistance, and lower their risk of incarceration, breaking the school-to-prison pipeline. A high-school diploma has a transcendent effect on young people, and an impact on their families as well.

  25. The National Center for Families Learning (NCFL) appreciates the opportunity to comment on the U.S. Department of Education (ED) Statewide Family Engagement Centers’ (SFECs) notice of competition. NCFL is a non-profit organization dedicated to inspiring and engaging families in multi-generational learning. We have helped families make educational and economic progress since 1989 by utilizing evidence-based, innovative programming that focuses on empowering families, including those with small children.

    ED must ensure the definitions and specific requirements used to develop funding priorities and grantee selection criteria are finely tuned to meet both the requirements of the statute as well as the needs of families and schools in diverse communities. Therefore, we offer the following:

    Definitions
    The Every Student Succeeds Act (ESSA) Sec. 4503(b)(7) requires that [SFEC] grantees ‘assure training programs…will improve adult literacy.’ NCFL urges ED to include the four-part federal definition of ‘family literacy services’ as defined by ESSA: Sec. 8101.

    The term ‘family literacy services’ means services that are of sufficient intensity in terms of hours, and of sufficient duration, to make sustainable changes in a family and that integrate all of the following activities: 1). Interactive literacy activities between parents and children 2). Training for parents regarding how to be the primary teacher for their children and full partners in the education of their children 3). Parent literacy training that leads to economic self-sufficiency 4). An age-appropriate education to prepare children for success in school and life experiences.”

    The definition portrays how intensive intervention elevates entire families. When low literacy-skilled parents utilize the family literacy approach, they, along with their child, experience significant literacy acquisition gains.

    Priorities
    To effectively award SFEC grants, we encourage ED to prioritize awards that include the four-component evidence-based model comprised in the delivery of evidence-based family literacy services. NCFL’s evidence-based model, referenced throughout ESSA and used in more than 330 sites and by over 15,000 educators in 39 states, has helped over one million vulnerable families learn—and thrive—together. Evidence-based family literacy strategies have a proven track record of disrupting the cycle of poverty and elevating entire families.

    NFCL also requests that multi-generational learning be included as a priority for SFECs. The family approach to learning harnesses the power of parent-child bonds to help those who are most at risk of failing economically, emotionally, and socially to reach their full potential. A multi-generational model works effectively to break the achievement gap cycle and leads to a meaningful outcome for all involved. When family engagement is authentic and built on a two-way exchange of information, mutual trust and respect between families and school is greatly enhanced.

    The demographics of the nation’s students imply that most, if not all, teachers can expect to have English Learner (EL) students in their classrooms (U.S. Ed. NCELA, 2015). Therefore, ED must prioritize the needs of ELs, including low-to-moderate English speakers to ensure students and their families form strong connections to family literacy/learning and family engagement programming. Examples of those programs are those that: reinforce partnerships to support students; create two-generation successes with immigrant families; overcome barriers for school/program participation; work with dual-language families; generate communication strategies to reach families; promote understanding of American school systems; assure outcomes of children, parents, and families in immigrant programs and more.

    ED must also prioritize the children and families served by the Bureau of Indian Education including those participating in the Family and Child Education (FACE) program. FACE provides comprehensive center-based educational services to families. The FACE family literacy and family engagement model focuses on high-quality instruction for children and adults, professional development and evaluation. This dual-generation approach to education implements a culturally relevant early childhood education approach while concurrently meeting the unmet academic and parenting skills needs of parents, which has lasting effects. The SFEC would be strengthened with a focus on FACE.

    Requirements
    NFCL recommends that applicants are required to ensure they will use evidence-based approaches to utilize a multi-generational approach to learning. Two-generational learning is an evidence-based practice that has lasting positive effects on entire families. Engaging more than one generation in learning positively impacts the entire family, and in turn, the larger community. Research indicates that the inclusion of more than one generation in education increases the likelihood that economic success will be passed on as a shared value.

    Grantees must demonstrate capacity to build parent and families’ capabilities and connections at home, school and within the broader community. NCFL encourages that the SFEC clarify this and ensure that grantees can implement a program of sufficient intensity and duration to successfully build adult literacy and education alongside child and school capacity.

    Selection Criteria
    NCFL is pleased the Secretary is giving priority to statewide family engagement centers that will use funds under Section 4504 for evidence-based practices; we urge ED to maintain this priority. Programs which are evidence-based have been shown to improve student attendance, achievement and behavior, including decreased absenteeism, while simultaneously building adult capacity for college and career readiness.

    Funding Amount: Rather than a cap of $500,000, NCFL recommends a cap at $750,000 to ensure grantees have sufficient funds to create meaningful family engagement programming across states and regions.

  26. The Afterschool Alliance is grateful for the opportunity to offer feedback on the important Statewide Family Engagement Centers (SFEC) authorized under the Every Student Succeeds Act. The Afterschool Alliance is a non-profit organization, with over 26,000 afterschool partners, that works to ensure that all families have access to quality afterschool and summer learning opportunities for their developing children and youth.

    Afterschool programs expand learning opportunities for students nationwide by tapping community partners to keep children safe and well-nourished, and providing engaging, hands-on activities that raise school attendance, academic achievement and graduation rates. Moreover, they can often form an essential bridge between students, schools, families, and communities. By being offered in various and flexible combinations of schedules and locations, and focusing on relationships with trusted staff, afterschool programs can be important partners in expanding the availability, accessibility and impact of meaningful communication between educators and parents.

    SEC. 4503 (2): Partner Commitments

    We suggest the Department create priority for applicants that have collaborative agreements with statewide, regional, and local partners such as Statewide Afterschool Networks in order leverage partners in the field currently working with families in connection to student education and youth development. This will also help ensure that the center is able to spread the impact of technical assistance and support broadly across sectors to where parents and students engage throughout the day.

    We believe that committed and demonstrated support from State Education Agency (SEA) leadership will be crucial to the success of the SFECs. Therefore, we suggest that this language be strengthened to require evidence of that SEA commitment, including past progress made in advancing family engagement policy and practice, demonstrated SEA involvement in program planning, and a sign-off requirement of the SEA Chief directly to the US Department of Education as evidence of SEA commitment to advance this grant initiative.

    SEC. 4503 (B) (4): Applicant Experience

    Being more deliberate in defining what “effective” experience includes could strengthen this language. We suggest requiring applicants to demonstrate their experience in providing training, support and implementation expertise addressing high-impact family engagement. This specificity is more likely to ensure family engagement programs and services are linked to learning, measured by child development milestones, student achievement and/or school improvement and foster equitable educational outcomes. To ensure that programs will include a focus on advancing equity, applicants should demonstrate their experience working in urban and rural Title I communities with culturally, racially and linguistically diverse students and families. We also suggest that priority is given to not-for-profit family engagement organizations that already have a demonstrated statewide or multi-state presence

    Evaluation:

    Best practice recognizes the need for continuous improvement in any initiative based in working with stakeholders and external parties in identifying, measuring, evaluating and considering progress towards particular, and defined goals. To that end, we suggest that a minimum of 5% of funds granted to each center should be dedicated to evaluation. Additionally, we suggest that grant applicants submit a theory of change and logic model to show the ultimate impact of this work in advancing statewide family engagement policy and practice.

    Thank you again for your consideration of these comments. We look forward to strong, effective opportunities for family engagement through these centers in collaboration with education and community partners.

  27. On behalf of the Governor’s Prevention Partnership, I would like to thank USDE and ESSA for the opportunity to give our input on the Statewide Family Engagement Centers Program. As the Connecticut affiliate of MENTOR The National Mentoring Partnership, our agency is invested in providing meaningful and effective mentoring strategies to all students.

    We recommend that Family Engagement Centers put a laser focus on chronic absence for students with disabilities whose absenteeism rates (in Connecticut) are 10.7% higher than that of their regular needs counterparts, and students of color whose absence rates are 8.4% higher than that of their white counterparts.

    As a state with several Success Mentors site schools, we recognize that implementing mentoring models that incorporate family engagement as a tier 1/whole school strategy is imperative to a student’s success, especially a student that is struggling with school connectedness.

    Therefore, we also recommend that these centers operate in conjunction with other tier 1 strategies, namely: early warning system weekly data meetings, and school-based and school-integrated mentoring programs which are an evidence-based strategy that can promote successful family engagement and offer a low-cost, sustainable, and systemic family engagement solution that places mentors in the lives of students who are at risk for chronic absence.

  28. • Chronic absenteeism affects students at every grade level and presents barriers for academic success to keep students on a path to graduation. Because of our six years of experience working with the Success Mentors for the NYC DOE, we recommend including quality school-based and school-integrated mentoring programs because they are an evidence-based strategy that can promote successful family engagement and offer a low-cost, sustainable, and systemic family engagement solution that place mentors in the lives of students who are at risk for chronic absence.

    • Experience informs us that families are more engaged when trained mentors who proactively build relationships with both students and families use strengths-based, affirming approaches that consider parents and guardians. As these relationships develop, mentors can begin to partner with families, addressing educational challenges and helping to connect them with needed resources. Through frequent communication, families, school administrators and mentors partner to create success plans that are customized to a student and family’s unique needs.

    • We have witnessed firsthand the positive results that come from well-prepared school administrators who understand how to effectively recruit and train mentors to meet the needs of a diverse student body who often struggle with attendance. We see how programs leading school-integrated mentoring, that focuses on reducing chronic absence, can play an integral role in Statewide Family Engagement Centers. Change is possible with strategic activities that include best practices trainings, technical assistance, orientations, recruitment and resource development for SEA’s, LEA’s, schools and other organizations.

    • Partnerships with community-based organizations, including health and mental health agencies, youth development programs and social service providers, as well as individual school parent coordinators, are an essential component of successful family engagement strategies. We recommend that Centers emphasize the importance of successful community partnerships and should engage community-based organizations proactively as training providers and subject matter experts.

    • Mentoring can be seen as a Tier 2 strategy, or a strategy that is effective for students who have been identified as “at risk” for an issue such as chronic absence (Early Warning Systems Implementation Guide, National High School Center, 2010). It builds off of and informs a school’s Tier 1 strategies – those offered to all students and families. A critical feedback loop occurs during weekly data meetings, a core component of school-integrated mentoring programs. During these meetings, mentors receive real-time data about students’ attendance which enables them to respond quickly enough to help the student and family get back on track, while administrators receive information about the collective needs of students and families that can help them assess and improve the effectiveness of Tier 1 strategies. These Tier 1 approaches help to ensure that schools and districts build a family-centered environment, or a responsive environment where families feel welcome and engaged (Strengthening your EWS Strategy through Relationships, NSAESC, 2017)

  29. Family engagement in education is critical to maximize the success of all students. The establishment of Statewide Family Education Centers (FECs) would help facilitate meaningful family engagement, quality professional development, and improved outcomes for students. These centers should have the expertise necessary to facilitate authentic engagement and technical assistance to professionals, SEAs, LEAs, and families.
    Family-run and family-led organizations, such as Parent Training and Information Centers (PTICs) and Community Parent Resource Centers (CPRCs), are funded through IDEA Part D and exist in every state. These non-profit organizations have proven track records for improving outcomes for families, youth, and communities through comprehensive training, information, technical assistance, and mentoring services.
    Successful FEC candidates should be required to collaborate with existing resources within the state they serve and build capacity in conjunction with local groups and individuals for sustainability.
    Preference should be given to applicants that have demonstrated established networks of support for delivering statewide supports and the ability to leverage local and state resources.
    FECs should be required to have a board of directors that reflect the communities they serve and FECs should have a physical presence in the state that they serve.

  30. The Michigan Department of Education appreciates the ability to provide comment regarding the opportunity for the new Statewide Family Engagement Centers authorized under the Consolidated Appropriations Act of 2018.

    The goal of this opportunity is to carry out parent education and family engagement in education; or to provide comprehensive training and technical assistance to State educational agencies and local educational agencies, schools, organizations that support family-school partnerships, and other organizations that carry out such programs. Under Section 4504, however, supporting parents, and the development of policies and initiatives are allowable activities. It may be beneficial when considering outcomes for students and families to foster the development and support of both families and school administrators, teachers, and/or community providers. Evidence-based practice implemented at all systemic levels will yield the best outcomes in family engagement.

    While applicants may be a state educational agency or consortia, might coordinated applications receive priority funding, whether through a consortia of states or through public/private statewide partnerships? Such applications may have the potential to offer the greatest match, capitalize on resources, and support sustainability. We suggest priority competition points being allocated for those states or consortia applications identifying strategic collaborative applications. Further, under Section 4503, a description of applicant approval is provided. It may yield greater outcomes if states/consortia are prioritized that have already initiated the coordination of efforts across agencies and districts, such as through an advisory team, family engagement framework, or family engagement guide.

    Section 4503 includes requirements for advisory committees representing elementary and secondary education. In order to support best outcomes for family engagement, it is suggested that early childhood programs and services be explicitly included in the development and implementation of services, with collaborative partners, and within the advisory committee. Early childhood programs and services are not explicitly identified in statute and are essential in addressing the continuum of engaging families.

    In establishing a statewide family engagement center, does the center need to be a brick-and-mortar center or can the center be an online entity? While this is not spelled out in statute, there are many potential benefits to contributing resources to a virtual center, especially when targeting a large geographic region. Participants can receive evidence-based online training, resources, and support from the development of an accessible online center.

    There should be an expectation that applicants for the statewide center are aware that coordination and collaboration with any tribal program awarded funding via Section 4505 is expected.

    The statute does not explicitly require performance metrics, evaluation, and reporting. Grant reporting to the Secretary, as well as expectations that the awardee for technical assistance funded in 4502 (2)(d), should attend to the contributions that these grants can make to further the evidence of the importance of consistent and coherent policy and practice in family engagement.

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