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The Common Core Memorandum of Understanding: What a Story

October 14, 2013

The question of who, exactly, is truly responsible for writing the Common Core State Standards (CCSS) has been a matter for debate. Here is how the CCSS website (update 03-23-14: link altered on the CCSS website but preserved here) describes CCSS development:

Building on the excellent foundation of standards states have laid, the Common Core State Standards are the first step in providing our young people with a high-quality education. It should be clear to every student, parent, and teacher what the standards of success are in every school.

Teachers, parents and community leaders have all weighed in to help create the Common Core State Standards. [Emphasis added.]

First of all, if the “states” have “laid an excellent foundation of standards,” why does America need CCSS?

Let us relegate the first statement above to flattery meant to disguise the lack of details of CCSS origin on the CCSS website.

Then there is the second statement, “Teachers, parents, and community leaders… weighed in….”

Another dodge.


A more promising document for discerning the truth behind CCSS creation is the memorandum of understanding (MOU) that states entered into with the US Department of Education in applying for Race to the Top (RTTT) funding.

Let is closely examine a CCSS MOU, shall we?

According to Investopedia, a MOU is “A legal document outlining the terms and details of an agreement between parties, including each parties requirements and responsibilities. ”

This link leads to the State of Delaware’s RTTT Application for Initial Funding. The CCSS MOU is located on pages 128-130.

The copyrighted “owners” of CCSS are named in the title of the MOU:

The Council of Chief State School Officers and the national Governors Association Center for Best Practices Common Core Standards Memorandum of Agreement

CCSS MOU: Purpose

The very first statement of the CCSS MOU is problematic:

Purpose: This document commits states to a state-led process…that will lead to the development and adoption of a common core of state standards.

If the process is “state-led,” why is the state entering into a legal arrangement with the federal government to “ensure” that the state “leads” itself? If the state is “leading itself,” how is it that the “standards” will be “common” to other states?

Simple: This MOU tells the states how they are to “lead themselves” in matters of CCSS.

Here is the entire “purpose” paragraph:

Purpose: This document commits states to a state-led process that will draw on evidence and lead to development and adoption of a common core of state standards (common core) in English language arts and mathematics for grades K-12. These standards will be aligned with college and work expectations, include rigorous content and skills, and be internationally benchmarked. The intent is that these standards will be aligned to state assessment and classroom practice. The second phase of this initiative will be the development of common assessments aligned to the core standards developed through this process.

Got that?

Not only was the product, CCSS, never tested; in signing this MOU, states agreed to an as-of-yet undeveloped “second phase” of “common assessments.”

It sure sounds like the state signing these MOUs are “following,” not “leading.”

CCSS MOU: Background

The next section is entitled, “Background.” it includes information on previous efforts to develop some set of “common” standards and assessments, including the American Diploma Project (ADP) and the New England Common Assessment Program (NECAP).

ADP is the product of “bipartisan nonprofit” Achieve, Inc.— a key voice in CCSS. Achieve’s funders include the Gates and Joyce Foundations (Obama was once on the Joyce board of directors) as well as a number of American Legislative Exchange Council (ALEC) corporations (e.g., Boeing, Chevron, IBM, Intel, Microsoft, Nationwide, State Farm).

Achieve, Inc.: Business muscle masquerading as “nonprofit.” Then again, so is ALEC.

Interesting how ALEC is sits on the board of a major contributor to CCSS, yet ALEC initially drafted and passed a detailed resolution against CCSS. in the end, Jeb Bush “talked ALEC into CCSS.”

There is money to be made in working for a nonprofit. Based upon Achieve’s 2010 IRS Form 990, ten individuals employed for 40 hours a week drew annual salaries and “other compensation” ranging from $154,000 to $311,000.

According to the same 990, the primary mission of Achieve is to “support standards-based education reform efforts across the states.”

There is money to be made in academic standards.

As for NECAP, this is the program that has been misused as a graduation requirement in Rhode Island. Even the corporation that designed NECAP agrees. (More on NECAP here.)

The Gates Foundation paid Measured Progress (developer of NECAP) over $4 million to contribute to teacher evaluation and teacher-moderated scoring systems.

So. The “background” of CCSS is rooted in both Achieve, Inc., and NECAP, and the background of Achieve is rooted in ALEC, and the background of both is rooted in Gates.

But never forget that it is the “states” that are “leading” this CCSS effort.

CCSS MOU: Benefits to the States

In the next section, “Benefits to the States,” NGA and CCSSO are making promises. But keep in mind that the states signing the MOU are committing to a process that they agree to implement (in the future), not one that they themselves have already written. So to make promises of what CCSS is supposed to do in the future while calling it “state led” for states just signing on is a contradiction.

Technically, if a single governor generated the idea for CCSS and all other governors followed, the “initiative” could still be called “state led.”

Reminds me of how “pork and beans” is technically correct even when a company includes only a single one-inch square of pork in a 12-ounce can.

Forget the token pork. Why not just call it what it is: In signing the MOU, states are agreeing to implement a set of standards and assessments that obviously originated outside of the time of the signed agreement, and with others, who are not state officials, in key leadership roles.

From the “Benefits to the States,” it is clear that CCSS is “one size fits all”:

Benefits to the States: The time is right for a state-led, nation-wide effort to establish a common core of standards that raises the bar for all students. This initiative presents a significant opportunity to accelerate and drive education reform toward the goal of ensuring that all children graduate from high school ready for college, work, and competing in the global economy and society.

The One Size Fits All Promise.

The “benefits” section also includes a list of what participating states will be able to do, including “articulating… general public expectations for students,” “aligning textbooks… to the standards,” “ensuring professional development… based on identified need and best practices,” “develop[ing] and implement[ing] an assessment system to measure student performance against the common core,” and “evaluat[ing] policy changes needed to help students and educators meet the common core standards….”

It is not clear how this list connects to the promise that CCSS “ensures all children will graduate… ready for college….”

And yet another promise: According to the CCSS MOU, CCSS is guaranteed to match or outdo current state standards:

…No state will see a decrease in the level of student expectations that exist in their current state standards.

Yet according to CCSS advocate Chester Finn of the Fordham Institute, Texas’ ELA standards rated higher than did CCSS.

Uh oh.  Promise broken.

CCSS MOU: Process and Structure

And now, the CCSS MOU section, “Process and Structure.” it opens with a statement akin to CCSS being “state led” since NGA and CCSSO are “in charge.”

CCSS MOU: National Validation Committee

The next subsections are curious for their ordering. First comes the National Validation Committee, a group of “national and international experts on standards.” However, their role was not to develop CCSS– it was to review:

The national validation committee shall provide an independent review of the common core. The national validation committee will review the common core as it is developed and offer comments…. This group will use evidence as the driving factor in validating the common core. [Emphasis added.]

The validation committee did not develop CCSS. They “reviewed” and “offered comments.”

According to testimony of Sandra Stotsky, CCSS validation committee member, the validation committee was little more than a “rubber stamp” whose “requests were ignored” for the “supposed body of research evidence” on which CCSS was based.

The validation committee is listed first on the CCSS MOU, yet the validation committee did not write the standards.

Why list them first?

Because it looks good to list the expected education standards experts first even if their role is superficial.

CCSS MOU: Develop End-of-High-School Expectations and K-12 Standards

The second group was the one with the power. They are identified in the next two subsections, “Develop End-of-High-School Expectations” and “Develop K-12 Standards in English Language Arts and Math”:

Achieve, ACT, and College Board.

NGA and CCSSO wanted to keep the membership of this group a secret.  Stotsky testifies as much:

After the Common Core Initiative was launched in early 2009, the National Governors Association and the Council of Chief State School Officers never explained to the public what the qualifications were for membership on the standards-writing committees or how it would justify the specific standards they created. Most important, it never explained why Common Core’s high school exit standards were equal to college admission requirements without qualification, even though this country’s wide ranging post-secondary institutions use a variety of criteria for admission.

Eventually responding to the many charges of a lack of transparency, the names of the 24 members of the “Standards Development Work Group” were revealed in a July 1, 2009 news release. The vast majority, it appeared, work for testing companies. Not only did CCSSI give no rationale for the composition of this Work Group, it gave no rationale for the people it put on the two three-member teams in charge of writing the grade-level standards. [Emphasis added.]

As the CCSS MOU notes, this “Standards Development Work Group” is overwhelmingly comprised of Achieve, ACT and College Board members.

But there are others whose affiliations remain unacknowledged in the CCSS MOU– including David Coleman and his national standards writing company, Student Achievement Partners.

David Coleman, “a lead architect” of CCSS. David Coleman, “the architect of the Common Core State Standards Initiative.”

The very public CCSS “ghost writer.”

Mr. State Led

Student Achievement Partners co-founders Jason Zimba and Susan Pimentel were also a CCSS-MOU-unmentioned part of that Standards Development Work Group.

Zimba was “the lead writer of the [CCSS] math standards.” He teaches at Bennington College, where his mother, Elizabeth Coleman was president.

The Student Achievement Partners website glowingly refers to a Boston Globe article that names Pimentel and Zimba as “lead writers” of CCSS.

Moving on.

CCSS MOU: Adoption

The CCSS MOU repeatedly states that CCSS is “internationally benchmarked.” (In short, this means researching high-performing education systems in other nations in order to use the results to improve US education.)

Stosky maintains that CCSS is not internationally benchmarked.

Under “Adoption,” states are given three years to fully institute CCSS. That brings us to the 2014-15 CCSS implementation deadline shared by most CCSS states (and DC).

This section also includes the statement, “This effort is voluntary for states…,” a convoluted statement given the requirement of states to commit to CCSS in order to be eligible for RTTT funding. (Keep in mind that this MOU is part of a RTTT application.)

States also agree to use the complete CCSS, though NGA and CCSSO “fully intend that states… choose to include additional state standards beyond the common core” such that 85% of a state’s total standards are comprised of the CCSS package.

The RTTT prisoners get to personalize their cells. How nice.

NGA and CCSSO want to foster a process of continued improvement to “this first version of the common core….”

Don’t even think about being “state led” and modifying CCSS on an individual state basis. This is Lord of the Flies. We’re in it together.

CCSS MOU: National Policy Forum

We’re traveling farther down the ladder of CCSS influence. Time for that token teacher input. This is where organizations like the National School Boards Association, National Education Association, and American Federation of Teachers are allowed into the CCSS clubhouse. It is a token role to “inform the common core initiative,” a “place for refining our shared understanding of the scope and elements of a common core.”

Teachers and other traditional educators (i.e., the ones not affiliated with education companies or standards-writing nonprofits) are invited late to the CCSS party.

To those teachers who say, “I know that CCSS was developed by teachers. I was there,” I say,

You have been used as window dressing.

CCSS MOU: Federal Role

I just have to present this section in full. Notice the emphasis now on common core state standards:

Federal Role. The parties support a state-led effort and not a federal effort to develop a common core of state standards; there is, however, an appropriate federal role in supporting this state-led effort. In particular, the federal government can provide key financial support for this effort in developing a common core of state standards and in moving toward common assessments, such as through the Race to the Top Fund authorized in the American Recovery and Reinvestment Act of 2009. Further, the federal government can incentivize this effort through a range of tiered incentives, such as providing states with greater flexibility in the use of existing federal funds, supporting a revised state accountability structure, and offering financial support for states to effectively implement the standards. Additionally, the federal government can provide additional financial support for the development of common assessments, teacher and principal professional development, and other related common core standards supports, and a research agenda that can help continually improve the common core over time. Finally, the federal government can revise and align existing federal education laws with the lessons learned from states’ international benchmarking efforts and from federal research.

So, you see, the federal government has not written CCSS.

(Neither have NGA and CCSSO, but I digress.)

However, the federal government has helped pay for CCSS; it has required CCSS as a component for eligibility for RTTT funding; and NGA and CCSSO (themselves, ironically, national-level organizations pushing for “state led” involvement) has generously invited the federal government to pay for as much that is connected to CCSS as is possible to pay for and to funnel federal money earmarked for states to use for other purposes into CCSS.

Certainly the federal government would not use federal funding to hold a CCSS state hostage to CCSS.

Federal-level Arne Duncan surely does take CCSS well-being to heart.

CCSS MOU: Agreement

Time to sign on the dotted line. Just two signatures: A state’s governor and education superintendent.

Two officials making a decision with profound consequences for thousands of people.

State led.

Contrast this to the irony of this propaganda originally from the CCSS website (update 03-23-14: but now preserved via the Hunt Institute):

With students, parents and teachers all on the same page and working together for shared goals, we can ensure that students make progress each year and graduate from school prepared to succeed in college and in a modern workforce. [Emphasis added.]

The “same page,” for sure.  It just happens to be the last page.

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