**Collaborative for Building After -**  **School Systems Comments**

Thank y ou 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 Expand ed Learning Time.” The Collaborative for Building After - School Sy stems (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 pro grams, and to leverage the combined power of community organizations and schools. We strongl y 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 clarit y 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 CCL C competitions and whether the state prioritized any

model

– EL T, 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 ye ars;  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 spe cific activities funded by 21st CCL C (i.e., the percentage of total funding for the EL T program that is used specificall y to increase teacher salaries; how much funding is used to provide direct services to students; how much funding is used for profession al 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 ye ars; 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 EL T enter all students into the state data collection s ys tem; who “counts” as participating in the Annual Performance Report).

__________________________________________________ ____________________________ ED RESPONSE:ED thanks the Collaborative for Building After - School Sy stems for the comments on the

Evaluation of State Expanded Learning Time data colle ction package. This study will provide information on states’ plans for the use of 21 st CCLC funds to support ELT, how states have adjusted the structure of their 21 st CCL C competitions to allow for ELT, and any elements or components of ELT that states r equire sub - grantees to implement . As outlined in the 21 st Century Community

L earning 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 spe cific changes that states have made to 21 st CCL C 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 21 st CCL C competitions. Some of the other data you requested (e.g., information on before - school, after school, and summer programs; number of participants; speci fic activities; and metrics used for student outcomes) are outside the scope of this study because this data collection will focus on EL T (and not before - school, after - school, or summer programs) and will occur before implementation information is availabl e .