Recurring Nightmare – Action Needed- Sign Federal Public Comment Form by Sept 9

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Like a recurring nightmare, Race to the Top 2.0 is here.

Race to the Top #1 is an ugly story from 2009 that some Americans might not know.  Picture the Federal Department of Money riding in a buggy, driven by the Secretary of Education.  There are 50 horses (taxpaying states) pulling his load, and 5o sticks (RTTT grants and data systems) with 5o carrots (RTTT monies) dangling in front of each horse.  Carved into each carrot is the word “Race to the Top” to make the horses feel noble, and not embarrassed about so lustily chasing the cashcarrots, because the horses can then say that they only chased the cashcarrots to improve education.

But it was never, ever about improving education.  It was about implementing a labeling system for individuals, lifelong (with State-federal-corporate data tags) and it was about  controlling education from the top.   Regardless of what we are now calling Common Core (“Challenging State Academic Standards” is ESSA’s latest name) –it was the common data tags and systems that  married corporate greed to the federal power agenda by labeling individuals, tests and digital curricula uniformly, and nationwide (CEDS).

Race to the Top 1.0 dangled huge money lures in front of state education departments.  If the state boards of education took the bait, they might or might not ever see the cash, but the buggy drivers (feds) had successfully lured all the states into driving in the direction they wanted them to drive– and they only had to give out the money to a few “winners”.  (Utah was not a RTTT grant winner).

Where did they drive the states? In the direction of big “Fed Ed” –by signing on to Common Core standards, Common Educational Data Standards, State Longitudinal Database Systems, aligned tests and more.)

Now, United States Parents Involved in Education (USPIE) reports, we have to stop Race to the Top 2.0.

It isn’t called 2.0 by the feds, but instead is called the ridiculous title of:  The Elementary and Secondary Education Act as Amended by the Every Student Succeeds Act Innovative Assessment Demonstration Authority.  

What a name.  The anachronym would be TEASEAAABTESSAIADA.

Just call it  2.0.

It’s like the first Race to the Top  in its federal bribery, coercion, and control grabbing from states.

• Like Race to the Top 1.0, it increases data mining of children without parental consent. 2.0 requires federal study of children’s data by peer reviewers including psychometricians and requires states to “collaborate” with federal data mining agents at the Institute of Educational Sciences.
•  Like 1.0, it pushes federally aligned tests, but this time, states are encouraged to get away from parent-opt-out-able standardized tests by using other systems:  “an array of innovative assessments” which will likely mean stealth/gaming assessment.
• Like 1.0, cements Common Core Standards but under the new name of “challenging State academic standards,” which are, of course, still aligned to the federal-corporate common data tags.
• Like 1.0, it cements the use of student tracking and labeling via common data tags (CEDS).
• And, as if federally aligned education was not “Big Brother” enough, it also promotes globally aligned education and data standards  and asks states to continue to use the  “Universal Design for Learning.“

#ReinInTheKing

In USPIE’s recent blog post, we read more about these federally proposed regulations which must be commented upon LOUDLY AND FIRMLY by citizens, teachers, and legislators.   The deadline is September 9th for comment and that commenting link is here:

https://www.regulations.gov/comment?D=ED-2016-OESE-0047-0001:

Before you comment, you could read this summary –provided by USPIE parents:  (footnotes documentation also below.)

“The following are specific areas in which the proposed regulations are egregious in their attempts to impose a common, Federal education system, stripping parents and SEAs of what little local control of education remains, and in many ways contradicts and undermines the law in which they are intended to provide guidance.

PROPOSED 200.76:

• Clarifies that any innovative assessment design can be used as long as it meets the Department’s requirements and is aligned to the State’s “challenging academic standards.”

NOTE: In other words, only assessment designs aligned to Common Core and approved by the Department can be used. This is contrary to the meaning of “innovation,” and flies in the face of ESSA prohibitions.

• Gives States “flexibility” by allowing them to choose computer-adaptive statewide tests, so long as they align to “challenging State academic standards,” and are approved by the Department.

NOTE: This gives the illusion of flexibility while still ensuring States’ assessment systems align to the Common Core State Standards. Furthermore, since 2013 countless computerized testing malfunctions have been recorded leaving invalid results and wasted classroom time.¹

• Requires applications to be peer reviewed to help the Secretary of Education determine whether an applicant will be able to successfully meet the requirements. The peer review panels will include “psychometricians” (psychometrics is the modeling of test taker responses (behavior) in response to items (situations),²“measurement experts,” and “researchers.”

NOTE: These peer review panel members will collect data on children’s behaviors while testing, which is well beyond the scope of assessing a child’s knowledge…

• Requires applications to include a description of how a State’s innovative assessment demonstration will align to” challenging State academic standards.” NOTE: The Department is requiring States to align to the subpar Common Core State Standards in order to receive funding. Parents are not fooled by the rebranding.

 

PROPOSED 200.77:

• Requires a State Educational Agency to prove it has collaborated with “experts” including the Institute of Education Sciences (IES), the lead Federal agency in charge of data collection, and in the planning, development, implementation, and evaluation of innovative assessments.

NOTE: The entire mission of IES is to collect data on America’s school children and share it.³

• Requires State Educational Agencies (SEAs) or consortia to ensure assessments are “accessible for all students including children with disabilities and English learners. An SEA may also incorporate the principles of Universal Design for Learning in developing its innovative assessments.”⁴

NOTE: Universal Design for Learning uses computerized assessment programs to track a child’s brain function.⁵

 

PROPOSED 200.78:

• Is aligned with the principles of President Obama’s Testing Action Plan, as is much of the proposed regulations. The criterion of the President’s plan will help SEAs or consortiums to develop “an array of innovative assessments so that we may learn from a variety of models rather than establish a preference for one particular approach.”⁶

NOTE: Obama’s Testing Action Plan states that there are “other means” of measuring a student’s performance alongside assessments such as school assignments, portfolios, student surveys, school climate, etc. This will certainly encourage more surveys given in schools and lead to more data mining.⁷

• Clarifies the selection criteria the Secretary will use to evaluate an application and permit the Secretary to provide Innovative Assessment Demonstration Authority to an SEA or consortia of SEAs.

NOTE: Under ESSA, the federal government is prohibited from funding the development of assessments. ⁸

• Requires SEAs to ensure that each Local Education Agency (LEA) has the technological infrastructure to implement the [aligned] testing system.

NOTE: This requirement will incentivize increased State spending in order to compete to receive Federal funds.  Very few states have the necessary technology⁹ to support the federally designed testing system, and ESSA prohibits the Federal Government from mandating “… a State or any subdivision thereof to spend any funds or incur any costs not paid for under this Act.”¹⁰

• Requires an SEA or each SEA in the consortium to annually report to the Secretary updates on the implementation of the innovative assessments. Definitions of innovative assessments may include: “cumulative year-end assessments, competency-based assessments, instructionally embedded assessments, interim assessments, or performance and technology-based assessments.”

NOTE: These types of assessments are based on the mastery/competency/performance based education model or blended learning where children will be assessed and data mined all day long electronically and through projects.¹¹  The federal government is incentivizing states to implement computer adaptive, nationally-aligned assessments and education models through a pilot grant. This is all prohibited in ESSA.¹²

• Requires States, for selection purposes, to include continuous improvement process assurances for “developing or improving balanced assessment systems that include summative, interim, and formative assessments, including supporting local educational agencies in developing or improving such assessments.”¹³

NOTE: Testing consortia providers such as the Smarter Balanced Assessment Consortium offer a complete assessment kit including formative (daily classroom testing tools through their digital library of computerized learning video games, etc.), interim, and summative assessments. As these new pervasive testing systems are incentivized by Federal funding, the potential of data mining will be expanded to all day long, every school day. As testing evolves into a daily activity embedded in the curriculum, the opt-out movement will die, and parents will lose more authority over their children’s education.

 

PROPOSED 200.79:

• Requires States and consortia to annually measure the progress on the Academic Achievement indicator of at least 95% of all students.

NOTE: Under ESSA, States are still obligated to the 95% participation rate of the burdensome NCLB, but with even more restrictions as opt-outs are added into the rate and with punitive actions taken against schools with low participation rates.¹⁴

• States an SEA may use their innovative assessment system for purposes of academic assessments and statewide accountability only after the Secretary determines whether an SEA’s innovative assessment system is of high quality.

NOTE: “No State shall be required to have academic standards approved or certified by the Federal Government in order to receive assistance under this Act” (ESSA).¹⁵

 

Works Cited

¹   Computerized Testing Problems- Chronology:

http://fairtest.org/computerized-testing-problems-chronology

² Improving Assessment: The Intersection of Psychology and Psychometrics:

(P. 4) http://www.ets.org/Media/Research/pdf/RM-08-15.pdf

³ Institute of Education Sciences, Connecting Research, Policy and Practice:

https://ies.ed.gov/aboutus/

⁴ Innovative Assessment Demonstration Authority; Proposed Rule: P. 44962

⁵ National Center on Universal Design for Learning, The Three Principles of UDL:

http://www.udlcenter.org/aboutudl/whatisudl/3principles

⁶ Innovative Assessment Demonstration Authority; Proposed Rule: P. 44967

⁷ U.S. Department of Education- October 24, 2015, Fact Sheet: Testing Action Plan:  http://www.ed.gov/news/press-releases/fact-sheet-testing-action-plan

⁸ ESSA SEC. 8549A (a)(1); p. 865

⁹ “Are schools “tech-ready” for the Common Core Standards?”http://www.greatschools.org/gk/articles/technology-ready-for-the-common-core-tests/

¹⁰ ESSA SEC. 8549A (a)(1); p. 865

¹¹ ESSA SEC. 1201 (2)(L); p. 209   

¹² ESSA SEC. 8549A (a) and (b); pp. 865-866

¹³ ESSA SEC. 1201 (2)(F); p. 207

¹⁴ ESSA SEC. 1111 (4)(E); pp.87-88

¹⁵ ESSA SEC. 8527 (d)(1); p. 845-846

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Thanks to USPIE parents !