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On January 3, �鶹������ý Early Education Initiative Director Sara Mead testified before the D.C. Council on the need to improve proposed . The prepared text of her remarks is posted below:

My name is Sara Mead and I am Director of the Early Education Initiative at the �鶹������ý Foundation, a non-profit, non-partisan public policy institute in the District of Columbia that conducts research, develops policy, and provides resources and technical assistance to federal, state, and local policymakers.

Universal pre-k, if done well, has real potential to complement the education reforms currently underway in the District and lead to improved student achievement and life outcomes. But, as you have heard many times today, pre-k programs will produce these results only if they are of truly high quality. As the Council considers this legislation, you must be aware that you are not simply funding a program, but working to build a new system of early education for young children in the District of Columbia. How that system is designed—not simply funding or specific classroom quality requirements, but how pre-k providers are recruited, selected, and held accountable—is critical to its long-term ability to deliver high-quality programs and results for children. Unfortunately, the system and quality requirements this legislation proposes are not sufficiently developed to produce high-quality results. This legislation goes too far in mandating one-size-fits all requirements that would burden providers while making minimal, if any, additions to quality, while also being insufficiently stringent on some of the issues that really matter. Let me give you some examples:

• Teachers. This bill admirably requires all lead pre-k teachers in public (including charter public) schools and new community-based programs to employ teachers with bachelor’s degrees. This requirement reflects research showing that teacher quality is critical to student learning and greater education is associated with higher quality. However, the legislation goes too far in requiring pre-k teachers to have one of only 3 college majors—an arbitrary requirement that has little research behind it and would exclude many potentially qualified individuals (such as certified kindergarten teachers). Research and common sense show that pre-k teachers who have specialized training, knowledge or experience in educating young children are more effective—but this requirement should be much more broadly defined.
• Teacher Pay and Class Sizes. This bill would require all teachers to be paid on a single salary schedule set by ECEA, and mandate a maximum class-size of 16 and adult:child ratio of 1:8. I don’t need to tell you these provisions are expensive, and you have heard from providers today about their concerns with them. These provisions are unnecessarily one-size-fits-all and could ultimately undermine quality by preventing programs from innovating in teacher pay, different staffing structures (such as team teaching), or strategies to “grow their own” supply of high-quality teachers.
• Licensure. The bill would require public and public charter schools to be licensed as daycare centers. This requirement is burdensome and duplicates existing oversight by DCPS and the Public Charter School Board.
• Accreditation. This bill would require all programs to obtain national certification, most likely from the National Association for the Education of Young Children, by 2014. This is an extremely demanding standard that would also limit parent choice by imposing a particular pedagogical vision—not the only one consistent with quality—on all pre-k programs. It would also dramatically increase the program’s costs.
• Professional Development. This bill would specify a single entity as the provider and coordinator of all technical assistance and professional development for pre-k teacher quality in the District. This provision would limit providers’ and teachers’ flexibility to obtain professional development that meets their needs. Building a supply of high-quality pre-k teachers for the District is a tremendous challenge—why hobble ourselves by placing all the responsibility on a single entity when there are many qualified organizations in the District?
• The 50% set-aside for community-based programs is arbitrary and problematic.
  

While this bill is too “one-size-fits-all” on some “quality” indicators, it demands too little on others. Most obviously, lead teachers in existing community-based settings would need to have only a Child Development Associate credential—less than an associate’s degree—and there is no quality requirement for assistant teachers. These requirements are too low for quality. Many community-based providers will need additional time and support to meet high quality requirements—this bill helps provide that. But we should not create a two-tiered system of separate standards for school- and community-based programs, nor should tell parents programs high-quality “Pre-K for All” before they meet standards. I am also concerned that the language currently in Sec. 301 of the bill does not clearly require lead teachers in community-based settings to hold a bachelor’s degree even after 2014.

Even more fundamentally, this bill includes insufficient provisions for ongoing oversight and evaluation of program quality, for assessing child outcomes, or for holding programs accountable for their impacts on children’s learning and lives. This is critical. It is not enough simply to fund pre-k programs for all District 3- and 4-year-olds. We need to know whether they are working. That does not mean NCLB-style accountability, but there are a variety of appropriate ways for assessing program quality and children’s learning on an ongoing basis. This legislation seeks to ensure the quality of pre-k programs it funds. Lgislation can set a floor beyond which programs cannot fall. But there are real limitations on policymakers’ ability to legislate true quality, and efforts to do so often lead to harmful micromanagement. Instead, legislation must create systems and structures that support quality:

• A qualified and effective entity charged with recruiting, evaluating, approving, and carrying out ongoing oversight of high-quality pre-k providers;
• Systems of accountability and oversight;
• Structures and ongoing relationships that link pre-k programs to the K-12 education system.

These elements are largely lacking in the current bill. I, and am sure many of other experts who spoke this morning, would be happy to work with you further to develop outlines for such systems.