COMMON CORE CONCERNS

Just a letter found in a group I belong to (cause they don't know who I am)

Open Letter to Secretary Duncan, the Council of Chief State School Officers and the National Assessment Governing Board Concerning Non-Cognitive Testing in Common Core/College Career Citizenship Readiness Standards and the Reauthorization of ESEA.

July 3, 2015

Dear Secretary Duncan,

I have grave concerns about the direction that the Common Core Standards movement has taken.  I am just as concerned with the ethics of testing in the affective domain. Recently, there have been several documents that reveal that the Chief State School Officers, CCSSO, the National Assessment of Educational Progress, NAEP, and the ESEA Flexibility Waivers you continue to grant to states are integrating affective domain/non-cognitive areas into the Common Core Standards.

February 20, 2014, it was announced that James Comer had been tapped by the Obama administration to present this agenda.  The Comer "Pathway Method" implies that “magic circle” and other psychological techniques will begin once again, just like in the 70's and 80's.  President Obama and James Comer know that parents do not want the school to delve into the social, emotional, moral, and the ethical development of their children.

Comer states that  “executive function," the part of the brain that gives us self-control and helps us stick with a task to its completion, doesn’t fully develop until we reach our !20s. Does this mean that P-20 schools will focus on "continual development from before birth to maturity?"  Are we to believe that the school will model and mold the perfect personality starting with universal day care from birth as designed in President Obama's Playbook??

Parents have no say in this systemic government portrayal of fake college and career readiness that will change personalities? Has government decided that this is the "missing link" for people control? Will "Promoting Grit, Tenacity, and Perseverance: Critical Factors for Success in the 21st Century" be the design for a diabolical scheme for people control through interpersonal skills and intrapersonal skills? Parents reject this idea and reject this trajectory.

My experience in dealing with these deceptive types of programs and testing that were done in the affective domain in the Pennsylvania state assessment, EQA, Educational Quality Assessment,  and NAEP, National Assessment of Educational Progress, appears to be resurfacing with a great amount of marketing and hoopla. ACT is testing the "whole child" calling testing in the affective domain "academic behaviors" in their Aspire test. They were the contractors for employability soft skills contracted by the Department of Labor aligned to the Secretary’s Commission for Achieving Necessary Skills, the SCANS reports.

Ms. Angela Duckworth, University of Pennsylvania, is researching and campaigning for a "grittier" type of character and personality.  Andrew Ho, contributor to the Gordon Commission on Assessment, is eyeing "trait identification."  The CCSSO added dispositions to their list of readiness skills. Last August, ETS and NAEP Saturday Policy Board Discussion raised the issue of developing an assessment that measures Affective Skills (AKA Work Readiness Skills, 21st Century Skills and Soft Skills) and to make NAEP as relevant as the census.  In David Conley's report published in Ed Week, January 22, 2013, "Rethinking the Notion of Non-cognitive," he states that we should be "... elevating so-called non-cognitive information to an equal position relative to content knowledge....."  Really, Mr. Conley?

There was also a “Deeper Thinking" Conference at the White House, February, 2014. These components of “deeper learning have been found vital to student development of higher-order knowledge, skills and dispositions and to college and career readiness — and the meeting aims to figure out how to test them. The William and Flora Hewlett Foundation is the White House partner on the gathering — and one of the Foundation’s big initiatives is all about "deeper learning." [Source: http://bit.ly/1nGn7LH ].

The Lumina Foundation created a new college diploma incorporating affective domain skills as a requirement for graduation called the Degree Qualification Profile calling for Civic Engagement. They are deeply involved with the Innovation Lab Network in the Next Generation Schools in various states, a model for the 21st Century competencies, better known as including the affective domain.

So let's set the background record straight.  I can document that it is true that behaviorists Ralph Tyler and David Krathwohl, with the help of Educational Testing Service, ETS, and others, designed the Educational Quality Assessment, EQA/NAEP using Pennsylvania students as their Petri dish. I can document that NAEP is the EQA. Many years lapsed before questions were asked as to the exact premise of why the government would be testing and scoring the attitudes, values, opinions, and beliefs of Pennsylvania children. My son took the EQA. I questioned and acted upon the dubious legality and validity of this agenda.  Therefore, I have legal standing.

I filed a federal complaint under the Protection of Pupils Rights Amendment against the McGuffey School District, my local school district, and the Pennsylvania Department of Education for testing non-cognitive objectives in the Educational Quality Assessment, EQA. "The definition for ‘Psychiatric or Psychological examination or test’ means a method of obtaining information, including a group activity, that is not DIRECTLY related to academic instruction and is designed to illicit (sic) information about attitudes, habits, traits, opinions, or beliefs." (Taken from correspondence regarding the Anita Hoge complaint from Leroy Rooker, Director Family Policy and Regulation Office, May 13, 1988 to Mary Rogers, Esq., Chief Counsel, Pennsylvania Department of Education.) 

Mr. Rooker states, "...based on the information we have received, there remains a legitimate concern that the EQA may fall within the above definition of ‘psychological test'...At no time have we received information from the McGuffey School District or the Commonwealth which would indicate that the EQA is NOT a psychological test as defined by PPRA. There is also concern that the primary purpose of the EQA is to reveal private information from one or more of the seven protected areas." (See below.)

April, 1990,  my federal complaint was resolved. The EQA had had to be withdrawn.  A new policy was issued on April 2, 1990.  I received a letter from Ernest Helling, Assistant Chief Counsel from the Commonwealth of Pennsylvania carbon copied to Joseph Bard and Donald Clark both of the Pennsylvania Department of Education citing that a negotiated agreement had been decided.

On May 29, 1990, I received a letter from the late Senator Arlen Specter, as well as, Thomas E. Anfinson, the Deputy Under Secretary, Office of Management, the United States Department of Education. The letter stated:

The Office of Inspector General and the Department's Office of General Counsel conducted extensive negotiations with the Department of Education. The agreement resulted in Pennsylvania Department of Education adopting a policy statement implementing PPRA that will be distributed to all 501 school districts and administrators in the state of Pennsylvania and should assure compliance with the PPRA. The agreement was called Basic Education Circular 8-90 that created a prior consent requirement for psychological and psychiatric examination, testing, or treatment conducted as a part of any covered program and where the purpose of the examination or treatment is to reveal information explaining the following:

The Protection of Pupil Rights Amendment (PPRA) (20 U.S.C. § 1232h; 34 CFR Part 98) applies to programs that receive funding from the U.S. Department of Education (ED). PPRA is intended to protect the rights of parents and students in two ways:

It seeks to ensure that schools and contractors make instructional materials available for inspection by parents if those materials will be used in connection with an ED-funded survey, analysis, or evaluation in which their children participate; and

It seeks to ensure that schools and contractors obtain written parental consent before minor students are required to participate in any ED-funded survey, analysis, or evaluation that reveals information concerning:

1. Political affiliations;

2. Mental and psychological problems potentially embarrassing to the      

    student and his/her family;

3. Sex behavior and attitudes;

4. Illegal, anti-social, self-incriminating and demeaning behavior;

5. Critical appraisals of other individuals with whom respondents have

    close family relationships;

6. Legally recognized privileged or analogous relationships, such as those

    of lawyers, physicians, and ministers; or                   

7. Income (other than that required by law to determine eligibility for

    participation in a program or for receiving financial assistance under

    such programs).

This policy still stands in the state of Pennsylvania.

In 1991, one year later, the Pennsylvania State Board of Education began the process of revising education toward "learning outcomes" called outcome based education, OBE, with similar themes as in the present College and Career Readiness Standards of  Common Core.  (The Pennsylvania 53 learning outcomes included standards in the affective domain similar to the soft skills in workforce readiness standards today.)                   There were many public meetings on the controversial outcomes. The IRRC, the Independent Regulatory Review Board, had ultimate responsibility for reviewing, agreeing and changing the regulations.

On January 17, 1992, Frank Ertz, Executive Director of the IRRC, after reviewing the regulations and submitted objections that related to several significant areas, including the fiscal impact on school districts, the clarity, feasibility, and ambiguity and the reasonableness of the implementation procedures and timetables, put the Board’s conclusions in writing.

This historical document explodes the current debate about testing in the affective domain in the Common Core Standards once again:

"The most troublesome area of the proposal is the student learning outcomes. It appears that the majority of the commentators do not support the direction in which the board is going and are gravely concerned with the student learning outcomes as they are currently proposed. Many of the outcomes proposed are non-academic and some could be interpreted to relate to moral or religious principles. Many are not based on cognitive learning which can be easily and objectively measured; instead they are based on affective learning which deals with attitudes, habits, traits, feelings, values, beliefs, and opinions which are difficult and subjective to measure. We believe these outcomes are too vague; there are too many outcomes; and in some instances, outcomes contradict one another. We recommend all outcomes be removed which could be subject to religious or moral interpretation be removed (sic). In addition, we believe that the remaining outcomes should be further defined and more closely coordinated with academic requirements that can be measured."  

On April 16, 1992, the IRRC stated appropriately, "...in response to public concern and comment, those outcomes (ie. non-cognitive and attitudinal 53 outcomes) were removed from this rulemaking package."  

I now want to highlight a historic meeting that I had with Emerson Elliott, Commissioner from the National Center of Education Statistics, and several Education Consultants from around the country that led to Mr. Elliott’s addressing my questions in writing about non-cognitive testing, NAEP, and data collection on July 11, 1994. Following up on our meeting, Mr. Elliott answered my questions in writing.

Similarly, I am requesting that the following questions be answered in writing about current practices:

Question 1.  Does the NCES/IES receive personally identifiable information being collected at the local level that align assessment measures of identified workforce readiness “soft skills” with the SCANS, Secretary’s Commission on Achieving Necessary Skills, competencies?  

Question 2.   Who currently holds the subcontract for workforce “soft skills” frameworks and benchmarks?

Question 3.   Why are student attitudes, values, opinions, beliefs, and dispositions being queried  again? (ie. by NAEP, the CCSSO, ACT, and the recommended future trend by the Gordon Commission)

Question 4.   What are the legal parameters and protections that would prevent NAEP from testing attitudinal areas that assure parents that measurement would be confined to strictly limited academic content?  What legal authority does the CCSSO or ACT have to include

non-cognitive test items or standards in Common Core benchmarks?

Question 5.   Will any behavioral data be collected from TITLE I including: Response to Intervention (RTI), Multi-Tiered System of Support (MTSS), or Positive Behavior Intervention and Supports (PBIS), or data collected and used for workforce readiness “soft skills” aligned to the SCANS competencies from the states’ longitudinal data systems?  

Question 6.   Please indicate how ACT and ETS will validate proficiency levels in the affective domain for the “interpersonal and intrapersonal” skills, the exact stated objectives and subgoals of what will be measured when assessing behavioral domains?  (For example: efficacy, sociability, ethical judgment, honesty, responsibility, adapting to change)  PLEASE INCLUDE THESE RELATED CONTRACTS WITH YOUR ANSWERS TO THESE QUESTIONS.  

The above questions are extremely relevant in that each child now possesses a unique national ID that is warehoused in the NCES/IES data base that will monitor individual progress on Common Core/College Career Citizenship workforce readiness skills that incorporate the SCANS competencies. The most important question, of course, has there been any change in the 1988 law that would allow NAEP to begin to test attitudes and behaviors again?  If the law has changed, could you please cite the legislation for verification?  Would you also submit the policy or position paper that would endorse any activity that NAEP would proceed to test attitudes, values, opinions, beliefs or dispositions?

I would also like to draw your attention to the fact that former Governor Corbett had withdrawn the controversial non-cognitive standards called the "interpersonal skill standards" from the Pennsylvania portal, standards aligned system in Pennsylvania, on October 22, 2014 after I had emphasized that the use of these standards were in violation of the Protection of Pupil Rights Amendment and the policy negotiated from my federal complaint, BEC 8-90. A PennLink was sent to all 500 school districts in the state addressing the issue of noncompliance of the Pennsylvania State Board, never having gone through required channels of oversight. Similarly, the interpersonal skills standards were not vetted and public hearings had never been held.

However, it must be noted that the aligned curriculum addressing the remediation of these non-academic standards in Pennsylvania is still intact which also violates federal law and state policy.

Mr. Holliday, as Commissioner of Kentucky Education and former Board member of NAGB, was involved with the Innovation Lab Network.  I believe he heartily endorsed Kentucky students’ being used as a guinea pig model state for college and career readiness experimentation in the affective domain. I believe he referred to this model as "the people development business." It is interesting that poor states, like Kentucky and West Virginia, have always been the states that the progressives gravitate to do their experiments on unsuspecting parents and students.

Would you please supply any marketing materials and permission slips that were used to implement the Innovation Lab Network in each of the other states? These would have been used to explain to parents and communities about the Innovation Lab Network affective domain or non-cognitive areas that were going to be assessed and treated with interventions.  Also, please investigate if Dr. Duckworth has also followed protocol in establishing the legal guidelines of using human subjects in her “grit” research at the University of Pennsylvania.

With this historical perspective in mind, concurrent with the movement to include the affective domain in testing and curriculum, I will have to ask, why the Secretary, CCSSO, NAEP, and the Gordon Commission proposals would be entertaining the non-cognitive-affective domain again with law and community against them?  Testing across domains, to my knowledge, would conflict with the Protection of Pupil Rights Amendment if informed written permission is NOT obtained. My question is, will permission be required as NAEP moves forward with the plans to test non-cognitive areas?

I have attached this illustration of an EdWeek Webinar that was recently presented September 27, 2013, by Angela Duckworth and others, sponsored by the Bill and  Melinda Gates Foundation.  I will have to ask this very precise question, "Do you really think parents will agree to have their children's brains “rewired?"  

I also have attached a Common Core framework entitled Personal and Workplace Skills from West Virginia that was fashioned by P21 Partnership, led by former State Superintendent of Schools, Stephen Paine. This proves that the Innovation Lab Network pilot states’ grants for 'Race to the Top' Next Generation Schools, indeed, use non-cognitive standards.(Funded by the International Organization for Economic Cooperation and Development, OECD, CCSSO, and Stupski Foundation). The frame of reference of the intense "behavior change" that is prescribed is definitely group goals and group efforts. Willingly or unwillingly, the student must change. I quote from the document that stresses "authentic affective engagement".....

"The Standard: Personal and Workplace Skills: The student will exhibit leadership, ethical behavior, respect for others, accept responsibility for personal actions considering the impact on others, take the initiative to plan and execute tasks, and interact productively as a member of the group.

Learning Skills Objectives: Student remains composed and focused, even under stress, willingly aligns his/her personal goals to the goals of others when appropriate, approaches conflict from a win-win perspective, and derives personal satisfaction from achieving group goals.

Are these the standards for the 21st Century global worker driven by a fanatical, psychological theory of changing independent American children to embrace global cooperation? Is this forcing our children to change by creating conflicts in the student’s belief system, and to change their values without protest, or willingly going along with group goals? Is this the collectivist goal Secretary Duncan, the CCSSO and the National Assessment Governing Board have agreed that students should attain?

Do you really think American families will agree to this sinister molding of personalities, values, attitudes, and beliefs to government approved attitudes values, and beliefs to some standard determined by whom?....tested and scored by whom? However a child "measures up" to these standards, a score or proficiency will be given for meeting the affective domain standards. Response to Interventions and positive behavior interventions and supports are well underway and being proposed through legislation in the Reauthorization of ESEA. We must discuss these next steps, changing the behavior, thoughts, actions, feelings, and opinions of young pliable minds without the prior knowledge or consent of parents. And to what ends? Who decides what that standard will be?

I have also evaluated the current proposed legislation for the Reauthorization of ESEA both in the House, HR 5, and Senate, S. 1177. Each of these proposed pieces of legislation expands education attainment to the affective domain referred to as non-academic standards. ESEA appears to be the vehicle that will try to make legal that which is currently illegal, the testing and intervention supports to change dispositions of students.

I am requesting that the United States Department of Education General Counsel review the legislation and demand an immediate investigation into the the direction that these legislative proposals are taking our country.  All action on the Reauthorization of ESEA MUST BE HALTED. The removal of true academic attainment  in Title I bastardized the historical concept of educating our children.  Using IDEA and Sec. 504 of the ADA further complicates the issues of direct student services that will be performed on normal children being identified for psychological re-education in violation of Civil Rights and Privacy which are protected in the United States.

Assessing personal information by asking personality trait items and questions in assessments and activities is an invasion of privacy. Collecting psychometric dossiers to be digitized and transported to the NCES/IES IS A COMPLETE INVASION OF PRIVACY.  Delving into personalities to score, and, then, to change behavior to the minimum positive attitude or proficiency according to government goals with interventions to change how a student thinks, feels, or acts is the destruction of freedom, and will not be tolerated. No matter what name you may use to market this agenda, parents will not accept their children being made into government drones under any accountability system. As Boris Yeltsin said, “Freedom will not be fooled.”

I will be looking forward to your immediate reply.  My questions are timely and of the utmost importance.

Sincerely,

Anita B Hoge

CC. Senator Alexander
Congressman Kline
Council of Chief State School Officers
National Assessment Governing Board
Kathleen Styles, Family Policy Compliance Office, PPRA
Angela Arrington, Dale King, Family Policy Compliance Office

Senator Toomey
Senator Casey
Governor Wolf
Pennsylvania House Education Committee Members
Pennsylvania's IRRC
Pennsylvania Department of Education
U.S. Department of Education General Counsel

Endnotes:

BILL: HR-5 DENIES PARENTS THEIR RIGHT OVER THEIR OWN CHILDREN
http://www.newswithviews.com/Hoge/anita113.htm 

Alexander S.1177-RESHUFFLES his Deck of Cards MEDICAID
http://www.newswithviews.com/Hoge/anita120.htm

The Medicalization of Schools
http://www.newswithviews.com/Hoge/anita117.htm

Obama taps Yale professor Comer to help promote grit
http://ctmirror.org/comer-to-obama-look-beyond-test-scores/

OECD CCSSO Stupski workshop
Stupski workshop presentation:  http://www.oecd.org/edu/ceri/46399963.ppt

Grit Report
http://pgbovine.net/OET-Draft-Grit-Report-2-17-13.pdf

Gordon Commission, Andrew Ho
http://www.gordoncommission.org/rsc/pdfs/20958_gordon_c_msn_assmt.pdf
And
http://varenne.tc.columbia.edu/cee/doc/Gordon-commission_on_assement.pdf

NAEP soft skills board meeting
http://www.nagb.org/content/nagb/assets/documents/what-we-do/quarterly-board-meeting-materials/2013-08/tab11-saturday-board-policy-discussion.pdf

CCSSO Dispositions/ Knowledge Skills & Dispositions, CCSSO, Innovation Lab Network
http://www.ccsso.org/Documents/ILN%20Knowledge%20Skills%20and%20Dispositions%20CCR%20Framework%20February%202013.pdf

The Duckworth Lab, University of Pennsylvania/Testing Grit
https://sites.sas.upenn.edu/duckworth/pages/research

David Conley-Re-thinking Testing the Non-Cognitive
http://www.edweek.org/ew/articles/2013/01/23/18conley.h32.html?tkn=UYQFW2AbCPTeVLcwPR4HfIKhPmstRkbShARv&cmp=ENL-EU-VIEWS1

Getting Inside the EQA Inventory
http://files.eric.ed.gov/fulltext/ED103468.pdf

Common Core Global Communion
http://www.newswithviews.com/Hoge/anita102.htm

West Virginia Molds Cookie Cutter Kids in Obama's Race to the Top Schools
http://freedomoutpost.com/2013/06/common-core-molds-cookie-cutter-kids-in-obamas-race-to-the-top-schools/