June 20, 2025
Submitted via Regulations.gov
Linda McMahon
Secretary of Education
U.S Department of Education
400 Maryland Ave SW
Washington, DC 20202
RE: ED–2025–OS–0020; Proposed Priorities and Definitions-Secretary's Supplemental Priorities and Definitions on Evidence-Based Literacy, Education Choice, and Returning Education to the States
Dear Secretary McMahon:
On behalf of the more than 3 million members of the National Education Association (NEA), we submit the following response to the U.S Department of Education’s Secretary’s supplemental priorities and definitions, published in the Federal Register on May 21, 2025. We have reviewed the Secretary’s priorities and have provided feedback for each of the three priorities, with special attention to the second and third priorities, which have no evidentiary basis and serve only to undermine public schools.
Proposed Priority 1: Promoting Evidence-Based Literacy
We believe that literacy, including the skills and knowledge to read and communicate through written language, is critical for students to succeed in school and in life. Research-based literacy instruction and interventions, especially in the early years, are essential for learning in all content areas and achieving high standards. As part of literacy instruction, independent reading with the guidance of certified library personnel and teachers is fundamental to reading skills development.
The creation of standards, design of curricular support materials, and development of assessments to support and understand students’ strengths and opportunities for growth should all be developed through meaningful and authentic partnership with educators. While educational agencies may lead the identification of standards and critical competencies, educators must lead the design and implementation of instructional strategies to support student success. This proposed priority cannot entail the imposition of standardized curricula, assessment, and/or pedagogical methods by the Secretary and/or agency staff as a condition of receiving discretionary grant funding or acceptance into programs overseen by the U.S. Department of Education.
In keeping with NEA’s Principles for the Future of Assessment, we maintain that standardized tests must not be the sole indicator determining whether students have met learning targets in literacy. Students’ grades and school quality measures reflecting student achievement in literacy should be based on a combination of evidence from a variety of sources. Examples of such sources include, but are not limited to, educator recommendations, a representative sample of student work, and performance-based assessments with full and appropriate flexibilities, accommodations, modification, and adaptations.
Educators must have the professional autonomy to develop, implement, and evaluate an array of content-relevant, high-quality classroom assessments (including formative, interim, and summative assessments, as appropriate) to enhance and improve literacy instruction for students. To accomplish this, we call upon the Secretary to direct funding under this priority for ongoing professional learning, supporting communities of practice, developing resources, and identifying high-quality exemplars of classroom and local assessment—including and especially performance-based assessment—to understand and propel student literacy.
Federal funding and literacy initiatives must focus intensely on birth to age eight, a critical developmental window where literacy interventions have a high return on investment. To make Priority 1 more impactful, we encourage the Department to collaborate with the U.S. Department of Health and Human Services and States to increase access to high-quality early childhood education programs led by highly competent early childhood educators for children and families.
Support should go beyond classroom instruction to include early identification and support systems—such as tutoring, family literacy outreach, wraparound services, community schools, and programs that reduce chronic absence —and should be eligible for literacy funding and technical assistance.
The Department should ensure that evidence-based literacy efforts are equitably resourced, particularly in communities disproportionately impacted by poverty, housing instability, and underfunded schools. Literacy priorities should promote racial equity and explicitly include strategies that close gaps for students of color and emergent multilingual learners.
By anchoring the proposed priority in the science of early literacy development, the Department has an opportunity to lead a transformative shift in literacy outcomes for all students.
Proposed Priority 2: Expanding Education Choice
The NEA rejects Secretary McMahon’s Proposed Priority 2–Expanding Education Choice because we have failed to adequately fund our nation’s public schools for far too long. We believe that every student deserves fully funded neighborhood public schools that give them a sense of belonging and prepare them with the lessons and life skills they need to reach their full potential. Studies over the last decade have demonstrated that money matters, especially when it comes to public education, where 90 percent of America’s students attend public schools. These studies show conclusive evidence that spending more money on public schools improves academic outcomes for all students. Spending on public schools also improves graduation rates, adult wages, and even reduces local crime rates. Funding public education has generational payoffs for children and increases local economic development.
Privatization efforts disguised as “school choice” yield devastating effects on our nation’s students and their communities. Voucher-accepting schools are regularly investigated for discrimination against vulnerable students, including students with disabilities or those from LGBTQ+ families as seen in states like Florida, Indiana, and Wisconsin. Rural communities, where schools often serve as hubs of community life and economic stability, are especially vulnerable when vouchers siphon away funding from public schools. Vouchers continue to create revolving doors for school failure, with 40 percent of voucher-receiving schools in states that have long-standing programs opened and subsequently closed over time. Voucher proponents argue that voucher programs improve student achievement; however, this has been debunked by countless independent studies. In fact, studies in Indiana, Louisiana, Ohio, and the District of Columbia have shown impacts on test scores on par with the COVID-19 pandemic or Hurricane Katrina’s effects on student achievements. Studies also revealed about 15–30 percent of voucher participants forfeit their vouchers to return to their local public school, where their academics improve immediately. Voucher programs fail students. We must fully fund public education.
We believe that there are better alternatives to the expansion of charter schools, particularly those privately governed. For public charter schools, like all public schools, we maintain that they must continue to provide students with a free, accessible, non-sectarian, quality education that is delivered subject to the same basic safeguards and standards as every other public school, namely: i) in compliance with open meetings and public records laws; ii) prohibitions against for-profit operation or profiteering as enforced by conflict of interest, financial disclosure, and auditing requirements; and iii) the same civil rights, including federal and state laws and protections for students with disabilities; and iv) the same employment, health, labor, safety, staff qualification, and certification requirements as other public schools. Furthermore, we believe that charter schools must be classroom-based entities. Remote and virtual charter schools demonstrate little financial accountability to the public and show no improvement in student achievement. We remind you of a rigorous study of charter school performance commissioned by ED, which found no positive effect for charter schools, debunking the myth that students in charter schools do better than their traditional public school counterparts.
Instead, we recommend that the Department prioritize the expansion and replication of Full-Service Community Schools, where countless success stories have taken place across the country. Districts and schools that adopt the community schools model—including hiring a community schools coordinator, a crucial piece of this strategy—have proven it was a wise investment: Coordinating resources at the school and system levels translated to a return on investment of more than $7 for every $1 invested in a coordinator's salary. Moreover, the model coordinates and aligns school and community resources, which, in turn, engages families and community in support of student success. The community schools model is a century-old strategy used by schools to help overcome challenges—like the mental health crisis, gun violence, or teacher shortages—and has yielded striking results. We hereby request that ED support and sustain federal funding for the Full-Service Community Schools (FSCS) program at the highest level possible.
We call upon the Secretary to model that congressionally mandated assessment programs, including the National Assessment of Educational Progress and statewide assessments required under the Every Student Succeeds Act (2015), are not to be used to shame and denigrate our nation’s public schools. The information gathered from these assessments should be evaluated with the purpose of identifying exemplars and driving meaningful, positive innovations and reforms in education policy and practice; they should not serve as evidence for case-making to defund our nation’s public schools and promote private school vouchers.
To expand access to competency-based education, work-based learning, and serving students with disabilities, the Secretary should grant flexibility for state educational agencies through the Innovative Assessment Demonstration Authority and consider broadening the program to the extent allowable under law to include innovative accountability approaches. The Secretary should also consider targeted waivers to reduce testing redundancies and create space for states to deploy performance-based assessment strategies as part of expanding access to high school and postsecondary learning opportunities outlined in Priority 2, Sections (g) and (j)(i)-(v), prior to high school graduation.
We must reiterate that public schools are for every one of us, no matter our skin color, family background and beliefs, or neighborhood. Across the country—in urban, suburban, and rural communities— educators, parents, and leaders are coming together so that every public school student has the resources they deserve, qualified educators they need, and opportunities that help them succeed and pursue their dreams. All of America’s children deserve to attend welcoming and safe neighborhood public schools in every zip code, fully staffed with dedicated educators, and able to provide students with the resources they need to thrive and reach their full potential, but this can only be achieved by fully funding public education.
Proposed Priority 3: Returning Education to the States
The core mission of the U.S. Department of Education includes “assuring access to equal educational opportunities” in contrast to the Secretary’s priorities—specifically, as it relates to this third proposed priority of returning education to the states. We are concerned that this priority will exacerbate the current inequities within state education finance systems that disadvantage under resourced communities currently.
This third priority seeks to completely remove districts from being prioritized for grants. School districts turn to federal grant programs for additional funding as a means to support critical programming that states have struggled to prioritize. Without the ability to directly apply for these federal competitive grants, districts will have to rely on states to direct resources to their neediest students. We cannot assume states are best equipped to target resources. Therefore, it should be the role of the federal government, through the federal competitive grants process, to target its limited resources to the communities who are seeking support and have been historically underserved in their allocation of federal funding.
Additionally, this priority conflicts with the underlying statute that governs many federal competitive grant programs. For example, the School-Based Mental Health Grant Program is awarded to both districts and states. If this priority goes into effect, districts would be locked out of the competition, which goes against the nature of the program as written by Congress. We urge you to reconsider this priority with the knowledge that local education agencies must be able to directly apply for federal grant programs to secure funds for their communities.
The NEA respectfully submits these comments for consideration and we would welcome a deeper dialogue to discuss the Department’s priorities. We urge the Department to reconsider and reevaluate the impact of these priorities and develop new priorities that seek to fulfill the Department’s mission.
Sincerely, Rebecca S. Pringle
President
National Education Association
