Comment on FR Doc # 2012-14954

These comments are submitted jointly on behalf of the Illinois State Board of Education (ISBE), the Illinois Department of Human Services (IDHS), and the Office of the Governor. 1. The proposed requirements are not clear as to whether applicants can make adjustments in the scope, budget, timeline, and performance targets for required areas given the more limited budget. We request that the final requirements clearly permit reductions and adjustments in the scope, budget, timeline, and performance targets for the activities in Criteria A(3)(a)(1), Core Area B, and Competitive Preference Priority 2. 2. The proposed application assurances require a State to "maintain its commitment to and investment in high-quality, accessible early learning and development programs and services for children with high needs, as described in Section A(1) of its FY 2011 RTT-ELC application." As proposed, this assurance does not clearly indicate the budgetary expectations imposed on RTT-ELC2 finalists. We ask that you clarify this assurance requirement for Phase 2 applicants. 3. The proposed requirements require a state to “use funding to support only those activities included in an eligible applicant’s FY2011 RTT-ELC application.” Since the initial application process and submission of the application, we have engaged in information gathering, planning, and implementation of some activities related to the RTT-ELC even though funding was not received in the first round. Based on new information learned following the submission of the first application, Illinois proposes that the RTT-ELC Phase 2 grant application allow for reasonable modifications to proposed activities to be included in the grant response. 4. We recommend flexibility for States with respect to the term of the grant period, not to exceed four years. 5. We request clarification on the contracting and sub-grant requirements that will apply to RTT-ELC2. In particular, can funds be sub-granted under this program?