Collaborative for Building After-School Systems Comments

Thank you for the opportunity to comment on the Department’s January 28, 2013 Federal 

Register Notice regarding “Agency Information Collection Activities; Comment Request; 

Evaluation of State Expanded Learning Time.” 

The Collaborative for Building After-School Systems (CBASS) is a national coalition of 

intermediary organizations that support high quality expanded learning opportunities—including 

extended day, week, or year models and before-, after-, or summer learning programs—that help 

children gain the skills, knowledge and experiences they need to lead successful lives. We do 

this by helping cities and regions employ coordinated approaches to increase the scale, quality

and accountability of programs, and to leverage the combined power of community

organizations and schools. 

We strongly support the collection of data to determine how states are implementing the optional 

Elementary and Secondary Education Act waiver to use 21st Century Community Learning 

Center funds for expanded learning time (ELT). We feel it is extremely important to ensure that 

funds are used effectively and efficiently to benefit students. In order to ensure that outcome, and 

to enhance the quality, utility, and clarity of the information to be collected, it essential that the 

interviews address, and the final descriptive report include the following: 

 The amount of funding that is allocated in the state for before-, after-school, summer 

programs, and expanded learning time (disaggregated among these categories) and how 

that differs from past allocations; 

 The specific changes that States have made to 21st CCLC competitions and whether the 

state prioritized any model – ELT, after-school, or summer – in the competition; 

 The number of students served through before-, after-school, summer programs, and 

expanded learning time in the state and how this differs from previous years; 

 Whether or not the state requires that ELT be provided to the entire school, to certain 

grade levels, or through voluntary participation; 

 Whether the state has required or encouraged partnerships with Community Based 

Organizations for implementation of expanded learning time; 

 The data that is required to be shared among partners, as applicable; 

 The specific activities funded by 21st CCLC (i.e., the percentage of total funding for the 

ELT program that is used specifically to increase teacher salaries; how much funding is 

used to provide direct services to students; how much funding is used for professional 

development activities and whether those activities are provided to both school staff and 

partners; how much funding is used for administration and planning); 

 The amount of time increased in schools as compared to previous years; and 

 The metrics being used for student outcomes and how data will be differentiated for ELT 

as a distinct model versus after-school or summer (i.e., will sites funded for ELT enter all 

students into the state data collection system; who “counts” as participating in the Annual 

Performance Report). 

______________________________________________________________________________

ED RESPONSE:
ED thanks the Collaborative for Building After-School Systems for the comments on the 

Evaluation of State Expanded Learning Time data collection package. This study will provide 

information on states’ plans for the use of 21st CCLC funds to support ELT, how states have 

adjusted the structure of their 21st CCLC competitions to allow for ELT, and any elements or 

components of ELT that states require sub-grantees to implement. As outlined in the 21st

Century Community Learning Centers state coordinator interview protocol, we are already

planning to collect some of the data you have requested. Specifically, we will be gathering data 

on: the specific changes that states have made to 21st CCLC competitions to allow for ELT; 

whether ELT is mandatory or voluntary for the whole school or a subset of students; and any

required or allowable plans for collaborations with Community-Based Organizations. We will 

collect this data based on states’ plans for ELT and changes they have made to their 21st CCLC 

competitions. Some of the other data you requested (e.g., information on before-school, afterschool, and summer programs; number of participants; specific activities; and metrics used for 

student outcomes) are outside the scope of this study because this data collection will focus on 

ELT (and not before-school, after-school, or summer programs) and will occur before 

implementation information is available.