UNITED STATES DEPARTMENT OF EDUCATION

OFFICE OF ELEMENTARY AND SECONDARY EDUCATION

January 13, 2017

Lisa Wiltshire

Deputy Assistant Commissioner

Tennessee Department of Education

710 James Robertson Parkway

Nashville, TN 37243-1219

Dear Lisa Wiltshire: 

On July 21, 2016, a team from the U.S. Department of Education (ED) (the Department), conducted a 

desk monitoring of the Tennessee Department of Education’s (TDE) implementation of its approved 

Preschool Development Grant (PDG)-Development. This monitoring aims to continue the collaborative 

relationship that began at the grant award and development of the scope of work. It provides the 

Department with a deeper understanding of each State’s overall performance; the successes, challenges, 

and strategies for the implementation of its Preschool State Plan, and the fiscal management of the grant 

funds. It also helps us tailor technical assistance to each State’s specific needs.

The desk monitoring included discussions related to all projects in the approved scope of work, including 

grants management, high quality new and improvement program, early learning standards, integration of 

various state preschool programs including PDG, and sustainability. During the desk monitoring, ED 

project officers talked with staff from the Office of Early Learning and fiscal staff at the TDE. 

Enclosed is a summary report based upon this review. The report includes highlights of Tennessee’s

implementation of PDG and a snapshot of Tennessee’s progress under each PDG key area. This report 

will be posted on the PDG website. The report includes “next steps” to ensure that Tennessee implements 

PDG consistent with its approved application, scope of work, and timelines identified in its project plans.

We want to thank you and your staff for your cooperation during the desk review, and for your 

tremendous efforts in providing high quality preschool opportunities through the Preschool Development 

Grant. It is not necessary to provide a written response to this report, however, if Tennessee receives a 

corrective action requirement as a result of the desk monitoring, a written response is expected. We hope 

you will continue to communicate any needs or concerns to your ED project officer(s). 

We look forward to continuing our work with you and supporting Tennessee’s technical assistance needs 

to ensure successful implementation of PDG. Thank you for your commitment to Tennessee’s youngest 

children.
Sincerely,

 /s/

Libby Doggett, Ph.D.

Deputy Assistant Secretary for Early Learning

Office of Elementary and Secondary Education

U.S. Department of Education

Enclosure
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PDG Desk Monitoring Report

Monitoring Information

State Lead Agency Tennessee Department of Education

State Participating Agency(s) Tennessee Department of Education

Grant Period January 1, 2015-December 31, 2019

Current Year of Grant January 1, 2016-December 31, 2016

PDG Monitoring Period May 2016 – September 30, 2016

PDG Monitoring Activity (Desk or 

Onsite)

Desk

Monitoring Review Date(s) July 21, 2016

State Participants/Project Leads Connie Casha, Beth Vorhaus, Ginny Ventro, Liz

Newsome

U.S. Department of Education 

Project Officer(s)

Shevine G. Holeman and Kimberly Mitchell

Overview of PDG Monitoring

The Department of Education is committed to supporting States as they implement the expansion of new 

and improved high quality preschool for eligible children through their PDG grant. Consistent with this 

commitment, the Department has designed a monitoring process to assess a State’s implementation of 

the program requirements and its approved Scope of Work for PDG and the State-level systems and 

processes needed to support implementation.

During the recent desk monitoring, Tennessee’s implementation of PDG was reviewed across several 

key areas: Capacity Building and Increasing Slots, Subrecipient Monitoring, Birth to Third Grade 

Continuum, Budget and Sustainability, and Fiscal Accountability which represent the core priorities for 

implementation as outlined in the PDG Monitoring Tool. In each area, the Department identified key 

elements that are required under PDG and are likely to increase the access to and quality of State 

Preschool programs and lead to increased high quality opportunities for young children and their 

families.

Tennessee was identified for a site visit based on the following factors: 

• Tennessee is a PDG Expansion State and the Department is conducting desk monitoring or onsite 

monitoring visits of all PDG grantees; and

• Tennessee had not been monitored previously during the grant period.
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The report contains the following sections:

• Summary of Visit. This section describes, in brief, the topics covered, the lead agency and 

subrecipients visited, as well as personnel participation in any meetings or activities.

• Highlights of the State’s Implementation. This section identifies key accomplishments in the 

State’s implementation of PDG as identified during the site visit.

• Status of Implementation of PDG. This section indicates the State’s implementation progress 

based on the monitoring and information collected.

• Elements Requiring Next Steps. This section identifies any elements for which the State is not 

on target for meeting its timelines outlined in the approved scope of work and includes next steps 

that the State must take to meet the grant outcomes, as identified during the monitoring. 

• Recommendations to Strengthen Implementation. This section provides recommendations to 

support the State in continuing to meet the goals and timelines of its PDG grant, as identified 

during the monitoring.

• Additional Comment. As appropriate, this section includes any additional information related to 

the State’s implementation of PDG not included elsewhere.

Summary of Visit

The PDG desk monitoring for Tennessee was conducted on July 21, 2016. During the desk monitoring 

ED and TDE officials discussed various aspects including building capacity and increasing slots; 

subrecipient monitoring; fiscal and budget implementation; and birth to third grade continuum. TDE

provided documentation to ED officials before the scheduled monitoring call. ED officials reviewed the 

documents, used annual performance report (APR) information, and information obtained from various 

monitoring activities during the time of the grant. 

Highlights of the State’s PDG Implementation

• TDE has worked hard to provide high quality preschool with this program in spite of negative 

press and negative feelings regarding preschool in Tennessee. The Brookings report, provided by 

the Brookings Institution, provided negative information regarding PDG implementation. 

• TDE has worked hard to maintain continuity in PDG implementation regardless of critical staff 

changes at the state and subgrantee level. The project director left TDE and TDE staff worked 

hard to implement the PDG program during the critical time of the transition. 

Status of Implementation of PDG

In the desk monitoring, the Department used a monitoring and accountability rubric to help determine 

progress of the State’s implementation. The rubric includes three implementation status levels: 

• Level 1 – Developing: the State is in the process of developing this activity, or the activity is 

very new. The State may be facing challenges in implementation, roll-out, or communications 

with subrecipients and other stakeholders. 

• Level 2 – Implementing: the State has developed and implemented the activity, although the 

activity might still benefit from adjustments, training, or communications with subrecipients and 

other stakeholders. 
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• Level 3 – Sustaining & Continuing Improvement: the activity is well-established in the State, and 

may be undergoing a process of evaluation or program improvement. Subrecipients, stakeholders 

and users have been trained and/or communications strategies have been established.

Element Status

Capacity Building and Increasing Slots

The State public awareness and recruitment 

activities are targeted towards eligible 4 years old 

children in high need communities and families 200 

percent below poverty. 

Level 2-Implementing

The State’s expansion efforts are targeted towards 

increasing the access to high quality preschool 

programs for 4 year olds.

Level 2-Implementing

The State has a plan to ensure that existing State 

Preschool slots met the twelve standards of a High 

Quality Preschool Program under the PDG funding. 

Level 2-Implementing

Subrecipient Monitoring

The State Lead Agency has a process to monitor 

grant and sub-recipients activities to ensure 

implementation of the goals and performance 

measures outlined in the approved PDG State Plan. 

Level 2-Implementing

The State is on schedule with its monitoring of 

subrecipients to ensure that all of the high quality 

standards for Preschool are met within PDG funded 

preschool classrooms.

Level 1-Developing

 

The State is providing access to comprehensive 

services to all children enrolled in the PDG funded 

preschool classrooms.

Level 2-Implementing

Birth to Third Grade Continuum

The State has aligned the PDG funded program 

within the Birth to Third Grade Continuum of early 

learning standards and activities that help prepare 

children for kindergarten thru third grade. 

Level 1-Developing

The State is implementing a data collection system 

for tracking student outcomes from prekindergarten

to kindergarten entry through third grade.

Level 1-Developing

The State is implementing a transition protocol to 

ensure that children transitioning from early care 

and education environments to kindergarten to third 

grade settings receive the supports necessary for a 

smooth transition.

Level 1-Developing

Budget and Sustainability

The State has policies and procedures to track the 

State and Subrecipient budget activities to ensure 

that funds are expanded according to State, Local 

and Federal procurement laws.

Level 2-Implementing

The State has in place a system to track the “use of 

funds” under the PDG grant. 

Level 2-Implementing

 
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The State has a plan to ensure that High Quality 

State Preschool Programs will remain of high 

quality after federal funds are no longer available. 

Level 2-Implementing

Fiscal Accountability

The State has policies and procedures in place to 

ensure the grant funds are expended according to the 

federal laws outlined in the federal Super Circular 

and EDGAR.

Level 2-Implementing

 

The State has a system in place to ensure that its 

Subrecipients are meeting the federal laws of the 

Super Circular and comply with the “supplement not 

supplant” requirements. 

Level 2-Implementing

Elements Requiring Next Steps: 

1. TDE’s current MOUs with subgrantees must be revised to include critical contractual terms of 

agreement for PDG implementation. Without this language, expectations between TDE and its 

subrecipients are not clear. At this time, MOUs include “boilerplate” language without 

specifying how high-quality preschool programs will be delivered to eligible children (e.g. 

students served, funding per students, etc.). 

2. TDE must immediately and effectively implement a sub-recipient monitoring plan to ensure 

program compliance. Although TDE has submitted documentation showing evidence of some 

monitoring, TDE needs to strengthen its monitoring and develop a monitoring protocol that 

addresses all twelve indicators of quality for the PDG program. The report, “Obama Pre-K 

Program Not evaluated and Unlikely to be Effective” discussed some of the quality indicators of 

the PDG program. For example, this report discussed excessive transition time. 

Recommendations to Strengthen Implementation:

• The Department recommends that TDE ensures that contractors involved in the 

evaluation of the program are forthcoming with how data obtained through the evaluation 

process will be used. The report, mentioned above, was written by a contractor employed 

by the TN PDG team. Some of the findings mentioned in the report (e.g. excessive 

transition time) should have been identified, followed up, and corrected by the TDE and 

its subgrantees. Additionally, the TDE was unaware of how the data from these 

contractors would be used; therefore, TDE should strengthen its monitoring protocols and 

the sharing of data from its contractors. 

• The Department recommends that TDE align all required elements of PDG and the state 

funded preschool in Tennessee for subgrantees and monitoring purposes in order to 

reduce the burden among subgrantees and the TDE. 

• The Department recommends that TDE strengthen its implementation of the PDG in the 

area of the Birth to third continuum.