As the U.S. Department of Education finalizes its rules for the Race to the Top Fund competition, NYSUT has submitted comments to Secretary Arne Duncan outlining five areas of concern.

The $4.35 billion competitive fund, part of the Obama administration's economic stimulus package approved earlier this year, is designed to encourage states to make coordinated, large-scale education improvement.

Echoing comments made by the union's national affiliates, the American Federation of Teachers and the National Education Association, NYSUT urged federal officials to be less prescriptive and give states more freedom to innovate and tailor reforms.

"Top-down, narrowly defined reform stifles creativity and will never work," said NYSUT President Dick Iannuzzi. "As I'm sure you recall from your years as a superintendent," Iannuzzi wrote to Duncan, "the experience of No Child Left Behind clearly demonstrated the federal government's limitations in managing educational reform."

NYSUT identified five areas of concern that need to be addressed before the application period begins:

• overreliance on test scores to measure teacher effectiveness;
• lack of emphasis on professional development to improve teacher effectiveness;
• narrow focus on charter schools as the pathway to reform;
• overemphasis on alternative teacher certification; and
• unrealistic timeline for adopting common standards and aligned assessments.

The letter emphasizes there is no question New York is fully eligible for the federal funding, refuting claims the state's charter school cap or tenure law could stand in the way.

NYSUT will continue to make the case that multiple measures need to be used to determine teacher effectiveness, NYSUT Vice President Maria Neira said.

NYSUT is encouraged that the proposed guidelines seek letters of support from statewide union leaders and memoranda of understanding signed by local union leaders who share the responsibility of improving student achievement.

NYSUT's full comments are posted at www.nysut.org.

Under the current schedule, guidelines for the program would be finalized in October, and state applications would be due by the end of the year.

The first round of awards would be issued in March, with a second wave of grants scheduled in September 2010.

"We look forward to working with the new commissioner, David Steiner, in providing input and guidance on the State Education Department's Race to the Top application," Neira said.