As part of the "American Reinvestment and Recovery Act of 2009," the U.S. Department of Education sponsored the "Race to the Top" competition to encourage education reforms anchored in improving teacher effectiveness as a driver for improving student-achievement outcomes and closing achievement gaps. The New York State legislature revised regulations related to the Annual Professional Performance Review for teachers and subsequently was awarded almost $700 million in the second round of the competition. Using data obtained from document analysis and semi-structured interviews of elite policy makers and key implementers, this qualitative policy analysis explored the operational, fiscal, and political challenges and facilitators to implementation of the new teacher-evaluation system. This study used institutional theory to identify the intent and theory of action of the policy agenda, and explore the impact that the culture of the educational institutional had on implementation of the policy in local school districts.