The Department of Education earlier this month issued a document that sows more confusion about the use of 21st CCLC funds and will result in afterschool programs closing doors or reducing services. The document contains a series of questions and answers, known as FAQs, regarding implementation of the Department’s No Child Left Behind waiver, a process that permits approved states to redirect scarce and badly needed 21st CCLC afterschool funds to pay for a longer school day. The FAQs have the effect of rewriting law and bypassing the will of Congress. Yet they were written without any guidance or input from Congress, the public, or those served by 21st CCLC grants. By law, 21st CCLC funds are to be granted to local communities to provide safe, supportive, and engaging activities for kids during the sometimes perilous afternoon hours. While the FAQ restates the 21st CCLC program’s original (and still badly needed) goals, it then invites states to use 21st CCLC funds in ways that are inconsistent with those goals. By the Department’s new interpretation in the FAQ, afterschool money could be diverted to pay for ‘additional time for teacher collaboration and common planning,’ or ‘redesigning the whole school day to use time more strategically.’ While the document does say extended learning time must add ?significantly: more time to the school day, and that state educational agencies have a responsibility to ensure that local grantees use 21st CCLC funds properly, examples included expanding the school day by as little as 50 minutes. That would not satisfy the daily needs of working families, who would still need an afterschool program in addition to this longer day to keep their children safe and learning till 5 or 6 pm. If this all sounds very technical, it is – but what is at stake is straightforward and tangible: whether more than a million children and working families will have the afterschool, before school and summer learning programs they need. Moreover, the department has yet to come to grips with the economics of its own proposal. The 21st CCLC funding stream is much too small to support the Administration’s extended learning time ambitions. Dollar for dollar, afterschool programs provide significantly more hours of quality programming to students and families than extending the school day in the manner the Administration envisions. Based on the Massachusetts model of extended learning time, the cost of extending the school day by 90 minutes in one school is the same cost as running seven comprehensive afterschool programs for a full year. In the end, the administration’s approach would serve fewer communities, and the program would have considerably less impact. The Afterschool Alliance is urging Congress to take a close look at this document and at the Administration’s plans for 21st CCLC, and to act to protect the afterschool programs America’s kids and families need and deserve. Investments in expanded learning time pilots should come from funding streams that are better aligned with school redesign such as School Improvement Grants, Race to the Top funds, Title I and Innovation Grants—not by quietly diverting 21st CCLC funding. A huge body of research shows that 21st CCLC-funded afterschool, before-school and summer learning programs improve students’ social, behavioral and academic performance. Shoehorning the 21st CCLC program into the regular school day would be a terrible mistake. Readers who agree should let their representatives in Congress know that they oppose efforts to divert afterschool funding. Unless we speak out, afterschool programs could be the first of many programs severely damaged by an overzealous Department of Education which is overriding laws through a process that requires no input, no oversight and no opportunities for review.

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