Last year we successfully got the Utah State Board of Education to get us out of the Smarter Balanced Assessment Consortium (a hollow victory). The SBAC is one of 2 federally funded assessment consortia meant to test Common Core students, and through its grant application push states onto Common Core. Utah signed onto SBAC in our Race to the Top application and became one of 17 governing member states. When the state board voted to exit SBAC last year, the state office of education was quite upset. From inside the USOE, we received a tip that they were writing a new Request for Proposal (RFP) for an assessment partner in such a way that only an SBAC partner entity could be chosen for our new assessment partner. We published this on this website and were told that was ridiculous by a couple state board members. In January of 2013, the USOE announced they had selected AIR (American Institutes of Research) as our new assessment partner. AIR is the official partner of SBAC. AIR has a subversive agenda and fits well with the SBAC who is led by Bill Ayers’ friend Linda-Darling Hammond, an advocate for teaching social justice in the classroom, and one who has a very poor track record for success in actual education outcomes. The State Superintendent said of the 13 or so applicants for our assessment program, AIR was the “only organization” that met all our requirements (in spite of the fact that at the legislative hearing in January where this was announced, there was already another computer adaptive test organization being piloted in Utah that was doing the job). The SBAC just released sample Common Core tests online. Here is what you are greeted with when you begin the test. AIR is indistinguishable from SBAC. Utah never left the SBAC except to exit a direct relationship status as a governing consortia member. We encourage you to contact your legislators and tell them to get us out of the SBAC and all its affiliates. Defund the $39 million contract the state office signed us onto.
The reader of this site will recall earlier this year when we brought as much pressure as possible on legislators and state school board members to exit from the Smarter Balanced Assessment Consortium (SBAC). Utah had signed on as a governing member of this consortium which obligated us to use their tests and that was destructive of our state control of education. The State Board of Education had voted 4-10 against leaving the SBAC early in the year or late last year, but by summer we had got a commitment that the board would vote to leave the SBAC. In their August 2012 board meeting, the State Board voted 12-3 to exit. This article documented the vote and it made an important prediction which has come true.
The article said that someone within the USOE had passed information on to us that the Request for Proposal for state assessments was being specifically written by the USOE in such a way that they would have to choose a vendor that would use the SBAC’s assessments. When I published this charge, at least one state board member told me that was ridiculous.
This week the State Board appointed committee chose the “American Institutes for Research” as the assessment writer.
The USOE prepared a Powerpoint presentation (Link) on this selection and on slide 2 we see that AIR is the “Only organization currently delivering statewide, online adaptive tests approved for ESEA accountability.” The ESEA was our waiver application for No Child Left Behind. Really? AIR is the ONLY organization we can use? We’re already testing an adaptive assessment system. Why can’t we continue with that? Perhaps it’s because it’s not AIR.
Who is AIR you ask?
“AIR is partnering with the Smarter Balanced Assessment Consortium, a state-led consortium committed to developing tests that use technology to better measure student knowledge and to make tests accessible to all. The Smarter Balanced tests will be delivered online and include innovative items and performance tasks that take advantage of the potential of technology.”
Ahhh, so AIR is partnered with the SBAC and they are the ONLY organization to meet the RFP requirements. What a shocker.
Their mission statement says, “AIR’s mission is to conduct and apply the best behavioral and social science research and evaluation towards improving peoples’ lives, with a special emphasis on the disadvantaged.” Who are these disadvantaged they refer to and why would they focus on behavioral improvements in people’s lives?
One of the worries we had in working with the SBAC was that the lead researcher was Linda Darling-Hammond who co-wrote the book “Learning to Teach for Social Justice.” The concern was that test questions themselves could contain indoctrinating questions. Since we’ve already seen the USOE creating group-think indoctrinating questions for use in textbooks in Utah, it’s clearly a valid concern that Linda Darling-Hammond’s goals of social justice in the classroom will be realized through test questions. If you’re not sure what these other questions could look like that would be indoctrinating, check out these examples.
A quick browse of AIR’s website shows they have sections on “LGBT Youth,” “Inclusive Development,” “Commitments to the Clinton Global Initiative,” “Child Labor,” “Workforce Development,” “Health Care Delivery,” and “Behavior Change.” Several sections deal with mental health issues in youth and one includes the “Good Behavior Game.”
Why it is that Utah can’t find partners that match our values is beyond me. This left-wing, multiculturalism nonsense is why Utah can’t rise above the rest of the nation in academics. If we focused on educating our children in factual knowledge, we would soar above other Common Core states. It’s painfully obvious that the people in charge of education in this state are as extreme as they come in left-wing agendas and it’s time some of them were fired. Please contact your state legislators and send them this article and ask them strip the USOE of their funding and give it to local districts to control their own standards, assessments, and curriculum. It’s clear the fox is guarding the hen house in Utah education.
Early on in this fight we pointed out that the federal government was funding $350 million to 2 assessment/testing consortia, the SBAC, and PARCC. We said that since they are receiving federal funds, it would allow the feds to possibly receive information that they shouldn’t have access to. In Utah we fought to get us out of the SBAC for several reasons such as it being led by social justice advocate Linda-Darling Hammond. We didn’t want propagandizing math problems on tests, but we were ridiculed for suggesting such a silly thing because Utahns would never have that appear on materials our children receive.
<cough>Granite & Jordan school districts</cough>
Today we learn from the Missouri Education Watchdog website that this week the SBAC met with State Chiefs to discuss some financial issues. Odd that an entity that received so much money from the feds is having financial issues… ;)
Having identified financial problems at the SBAC, they have now determined to “identify areas of commonality with the other assessment consortia, PARCC, and see if the two groups can share a consultant on those common points. It is not a stretch to see that these two groups are probably going to have to combine in the future in order to remain sustainable. Then we will truly have national standards.” (link)
Missouri Education Watchdog is exactly right. Combining the 2 mega assessment consortia will result in a singular national exam that will be what nearly every teacher in the country teaches to. Consolidation will lead to a single curriculum and the rush to grade teachers based on their classroom performance will kill innovation as they all standardize to cover the same material on the same day for the same test.
When States do their RFP’s for assessments they should not accept any bid from SBAC or PARCC related entities and affiliates.
Many of you have probably seen the news that yesterday the state board voted to exit their affiliation with the SBAC (Smarter Balanced Assessment Consortium). This action by the state board vote of 12-3 is wonderful news and a victory for our cause when just a few months ago the board voted 4-10 to NOT leave the SBAC. Thank you Utah State School Board.
Now we just have to follow several steps including getting permission from the federal government to leave this consortium and it’s a done deal. Glad the feds aren’t trying to control the states or anything…
After the board vote, mathematician Ze’ev Wurman wrote:
“Congratulations to Utah!!! The first domino to fall from the Common Core bandwagon! Not only will Utah be able to offer extra 15%, but it can shift content across grades. It can even — perish the thought — offer authentic algebra in eighth grade!”
I believe Ze’ev is correct and we could reform and raise the standards to our own desire if there was the desire within the state to actually adopt the very best in standards. This has always been our goal.
However, not all is well with this decision. It turns out that the Utah State Office of Education signaled board members that it was OK for them to leave SBAC because their work with SBAC is essentially done. They are now writing a very narrow RFP (request for proposal to get bids) that only an SBAC affiliated vendor would be able to fully satisfy. This information comes from within the USOE where someone has informed us that the move to drop SBAC was just a ruse to settle things down. USOE has no desire to work with other vendors since they had a hand in the SBAC work. There is no purpose in other vendors submitting a proposal under these circumstances because USOE will award it to the SBAC vendor. If you know of other assessment vendors, please let them know they should protest to the USOE that it is patently unfair to stack the deck in favor of the SBAC. This is not the first time USOE has played favorites with vendors or grants.
On July 10th, 2012, a public forum was held where 4 visiting experts shared concerns with Common Core. A press release was sent out earlier in the day causing Brenda Hales, a USOE administrator, to post a statement on the Utah Public Education website trying to offer the official line on Common Core. Christel Swasey, a Utah public education teacher, challenged her statement with this fact filled rebuttal. I encourage you to read Brenda’s post as well so you can see what’s being said by the USOE.
To Whom It May Concern:
The following information directly conflicts with this week’s statement about Common Core and national educational reforms as published by the USOE at http://utahpubliceducation.org/2012/07/10/utahs-core-standards-assessments-and-privacy-regulations/.
The following information has links to references so that you can verify what is claimed, unlike the unreferenced information given by the USOE.
1. Personally identifiable student data will be shared with governmental and non-governmental entities, both in-state and out of state, as never before.
The Federal Register outlines, on page 51, that it is not a necessity for a school to get student or parental consent any longer before sharing personally identifiable information; that has been reduced to the level of optional.
“It is a best practice to keep the public informed when you disclose personally identifiable information from education records.” http://www.gpo.gov/fdsys/pkg/FR-2011-12-02/pdf/2011-30683.pdf
Dec. 2011 regulations, which the Dept. of Education made without Congressional approval and for which they are now being sued by EPIC, literally loosen, rather than strengthen, parental consent rules and other rules. http://www.jdsupra.com/post/documentViewer.aspx?fid=5aa4af34-8e67-4f42-8e6b-fe801c512c7a
A lawyer at EPIC disclosed that these privacy intrusions affect not only children, but anyone who ever attended any college or university (that archives records, unless it is a privately funded university).
Because the 2011 changes stretch and redefine terms like “authorized representative” and “educational program” to include non-governmental agencies and many additional governmental agencies, effectively, there is no privacy regulation governing schools anymore, on the federal level. (Thanks to Utah legislators who are on the case, we might soon have stronger privacy laws to protect Utahns from the new federal intrusion).
The types of information that the Department will collect includes so much more than academic information: it includes biometric information (DNA, fingerprints, iris patterns) and parental income, nicknames, medical information, extracurricular information, and much more. See page 4 at http://www2.ed.gov/policy/gen/guid/fpco/pdf/ferparegs.pdf and see http://nces.sifinfo.org/datamodel/eiebrowser/techview.aspx?instance=studentPostsecondary
Utah’s federally-funded State Longitudinal Database System (SLDS) exists for the purpose of sharing data not only among state agencies but from the state to the US Dept. of Ed. The SLDS also exists to “manage” and “disaggregate” educational information within the state. –A briefing was given in Utah, August 2010 by John Brandt, who is the USOE Technology Director and a member of the federal Dept. of Education, a member of the federal NCES, and a chair member of CCSSO (an organization that helped develop and promote the Common Core national standards.) On page 5 of Brandt’s online powerpoint, he explains that student records and transcripts can be used from school districts to the USOE or USHE “and beyond,” and can also be shared between the USOE and the US Department of Education.
Utah’s P-20 workforce council exists to track citizens starting in preschool, and to “forge organizational and technical bonds and to build the data system needed to make informed decisions” for stakeholders both in and outside Utah. — http://www.prweb.com/releases/2012/2/prweb9201404.htm
The linking of data from preschool to post-secondary and on to workforce, both locally and to D.C., allows agencies easy access, technologically and in terms of legal policy.
The SLDS and P-20 systems were paid for by the federal government and they transform the way data is shared– and the federally stated purpose for all the data gathering is educational research– yet this also allows the state and federal governments to track, steer and even punish teachers, students and citizens more easily. http://cte.ed.gov/docs/NSWG/Workforce_Data_Brief.pdf
Data linking changes are not just technological in nature; there are also changes being made in regulations and policies that make former privacy protection policies all but meaningless. The changes are so outrageous, harming parental consent law and privacy concerns so much that the Department of Education has been sued over it. The Electronic Privacy Information Center (EPIC) sued the Dept. of Education, under the Administrative Procedure Act, arguing that the Dept. of Ed’s regulations that changed the Family Educational Rights and Privacy Act in Dec. 2011 exceeded the Department of Education’s authority and are contrary to law. http://epic.org/apa/ferpa/default.html
The Federal Register of December 2011 outlines the Dept. of Education’s new, Congressionally un-approved regulations, that decrease parental involvement and increase the number of agencies that have access to private student data: http://www.gpo.gov/fdsys/pkg/FR-2011-12-02/pdf/2011-30683.pdf (See page 52-57)
Although the Federal Register describes countless agencies, programs and “authorities” that may access personally identifiable student information, it uses permissive rather than mandatory language. The obligatory language comes up in the case of the Cooperative Agreement between the Department of Education and the states’ testing consortium –of which Utah is still a member: http://www2.ed.gov/programs/racetothetop-assessment/sbac-cooperative-agreement.pdf
In that document, states are obligated to share data with the federal government “on an ongoing basis,” to give status reports, phone conferences and other information, and must synchronize tests “across consortia”. This triangulation nationalizes the testing system and puts the federal government in the middle of the data collecting program.
For more information about the history of similar actions taken by the federal Dept. of Education that infringe upon state law and freedom, see the white paper by ROPE (Restore Oklahoma Public Education) entitled “Analysis of Recent Education Reforms and the Resulting Impact on Student Privacy” — http://www.scribd.com/doc/94149078/An-Analysis-of-Recent-Education-Reforms-and-the-Resulting-Impact-on-Student-Privacy
For understanding of the motivation of the federal government, read some of the US Dept. of Education Arne Duncan’s or Obama’s speeches that show the passion with which the federal agency seeks access to data to control teachers and educational decisions. http://www2.ed.gov/news/speeches/2009/06/06082009.pdf
2. The State Board of Education has virtually no control over the national standards it has adopted for Utah.
Governing documents of Common Core state that the Utah School Board may not delete anything from the national standards and can only add 15% to them. If Utah needs to add about a whole year’s worth of improvement to a given standard, as is the case with the 6th and 9th grade Common Core “math bubble” of repetition experienced this year in districts that implemented Common Core math, we can’t add more –and remain the same as Common Core nationally. Our 6th and 9th graders learn no math for an entire year because of the lack of local control. (Prior to Common Core, 8th graders learned Algebra I. Under Common Core, 9th graders learn Algebra I.) Because the NGA placed the standards under copyright, Utah can not amend them in any way. http://www.corestandards.org/terms-of-use To illustrate, even a member of the state school board couldn’t do anything more than pull her grandkids out of public school to deal with the situation. The school board member home schooled her 8th grade grandson and 9th grade granddaughter this year, “since our school district had decided to adopt the Common Core for every grade rather than what was proposed by the state. It was proposed that we only adopt for the 6th and 9th grade and provide alternative programs for those students who already had the skills being taught to all through the Common Core.” http://whatiscommoncore.wordpress.com/2012/07/07/state-and-local-school-board-perceptions-of-common-core-differ-13-2/
Additionally, any changes (up to 15%) that Utah makes to the national standards will never be taken into account on the common standardized tests. The test developer, WestEd, affirmed that “in order for this system to have a real impact within a state, the state will need to adopt the CCSS, i.e., not have two sets of standards.”
Anecdotally: those Utah teachers who love Common Core confuse the academic standards themselves with the methodologies being used to implement them. New methodologies in many cases are excellent, but have nothing to do with national standards. They are used in non-Common Core states. Innovative methodologies that work well are not tied to the common national standards, which are only academic levels that could just as easily be higher or lower, and can still be taught free of Common Core’s rules, using the good methodologies.
Utah has lost its autonomy over standards and assessments. The next time Utah reviews standards and wishes to raise the bar, what will happen? There is no CCSS amendment process. Also, since most states joined Common Core, and we’re virtually all the same; where is the collaboration, competition or better example to aspire to?
The common national standards were adopted due to federal recommendations during the initial Race to the Top application for funding for federal money. Fortunately, since Utah didn’t receive the money, we can escape Common Core without serious financial problems. And we should. Despite the letter of March 7, 2012 from Arne Duncan, stating “states have the sole right to set learning standards,” legally binding documents conflict with that Constitutional right, as well as with Duncan’s promises and with the Cooperative Agreement Duncan made with the SBAC.
When the Dept. of Education forced states to choose between No Child Left Behind and Common Core, they proved that Common Core is just the next federal program.
The ESEA Flexibility releases “waiver winning” states from No Child Left Behind law, only on conditions of implementing Common Core. On page 8 of the ESEA Flexibility document (updated June 7, 2012) found at http://www.ed.gov/esea/flexibility, please read: “A State’s college- and career-ready standards must be either (1) standards that are common to a significant number of States; or (2) standards that are approved by a State network of institutions of higher education”.
Thus, since Utah chose option one, we are stuck in Common Core by choosing to accept the NCLB waiver. On page 9 of the same document, we read:
“ ‘Standards that are common to a significant number of States’ means standards that are substantially identical across all States in a consortium that includes a significant number of States. A State may supplement such standards with additional standards, provided that the additional standards do not exceed 15 percent of the State’s total standards for a content area. ”
Utah not only has to stick with the Common Core State Standards by having accepted NCLB; we also are restricted from adding to “our” standards.
3. Utah applied for, but fortunately did not receive a Race to the Top (RTTT) grant. This means Utah can leave Common Core without having to pay back a grant, something that some other states wishing to flee Common Core’s entanglements cannot do.
But, because the SBAC did receive a large RTTT grant for assessment development and because Utah is a member of SBAC, we are bound to the federal government’s data collection rules and the national standards/assessments, with Washington State our fiscal agent as long as we remain an SBAC member.
The Department of Education first incentivized the adoption of the Common Core, and then incentivized adoption of national testing. Utah is under obligations associated with the SBAC grant as long as we remain a member of that consortium.
Exiting the Smarter Balanced Assessment Consortium system requires getting federal approval. But if Utah withdraws from the consortium via the formal exit process, we will then no longer be obligated to share data with the federal government and share nationally synchronized tests, but we will still be allowed to share data with the federal government under the new FERPA regulatory changes, unless EPIC wins their lawsuit against the Dept. of Education this year.
To sum up: Common Core is very similar to Obamacare. Governor Herbert said very eloquently that Obama’s “Affordable Care Act imposes a one-size-fits-all plan on all states, effectively driving us to the lowest common denominator. It results in burdensome regulation, higher costs, and a massive, budget-busting… expansion.” If you substitute the word “Common Core” for “Affordable Care Act,” you’ll understand what the federal education push is all about. The Federal Government did not initiate both the educational and the medical programs, but does control both.
fact vs. myth
We recently received an email asking about the governing documents for Common Core and a couple of individuals sent me this list of links below. It is not intended to be a comprehensive list as that would be difficult to amass. Many of you have seen the illustration at the bottom of the previous article, The Common Core Lie, which shows the number of organizations established to fill in the network of entities and programs seeking to nationalize education. It’s a complex beast with tentacles into every aspect of education. It is apparent that this has been in the works for many years and many documents reference the common core documents or are referenced by them. A few of those are:
- America Creating Opportunities to Meaningfully Promote Excellence in Technology, Education and Science Act (COMPETES Act)
- American Recovery and Reinvestment Act of 2009 (ARRA)
- Individuals with Disabilities Education Act (IDEA)
Cooperative Agreement between Dept of Ed and SBAC: http://www2.ed.gov/programs/racetothetop-assessment/sbac-cooperative-agreement.pdf
The copyrighted standards: http://www.corestandards.org/terms-of-use
The Smarter Balanced Governance structure: http://www.smarterbalanced.org/wordpress/wp-content/uploads/2012/02/Smarter-Balanced-Governance.pdf
The RTTT application for Utah: http://www.schools.utah.gov/arra/Uses/Utah-Race-to-the-Top-Application.aspx
Challenging and in opposition to a federal takeover of education (which Common Core certainly is):
On FERPA regulations: Here’s the federal regulatory changes that were made without Congressional knowledge/approval: http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=11975031b82001bed902b3e73f33e604&rgn=div5&view=text&node=34:18.104.22.168.33&idno=34
The executive branch is being sued by EPIC for adding those illegal regulations that hurt privacy but advance the cause of Common Core testing’s national data collection agenda: http://epic.org/apa/ferpa/default.html
A link to the Federal law’s which explicitly prohibit the Feds from being involved (GEPA law): http://www.law.cornell.edu/uscode/text/20/1232a
No provision of any applicable program shall be construed to authorize any department, agency, officer, or employee of the United States to exercise any direction, supervision, or control over the curriculum, program of instruction, administration, or personnel of any educational institution, school, or school system, or over the selection of library resources, textbooks, or other printed or published instructional materials by any educational institution or school system…
9th and 10th Amendments to the U.S. Constitution:
9: The enumeration in the Constitution, of certain rights, shall not be construed to deny or disparage others retained by the people.
10: The powers not delegated to the United States by the Constitution, nor prohibited by it to the States, are reserved to the States respectively, or to the people.
Dear Utah State School Board,
First, thank you for putting on last Thursday’s statewide forum. It was an admirable display of freedom of speech and thought in America. Both sides were treated with fairness and respect.
Second, I’m asking you to review some additional research as you weigh educational data-collection methods and as you advise school boards statewide on whether to submit to federal requests for local FERPA revisions.
We realize that oppressive federal controls are in place over the SBAC via our Cooperative Agreement http://www2.ed.gov/programs/racetothetop-assessment/sbac-cooperative-agreement.pdf and for that reason, I believe some state school board members may be wisely leaning toward getting Utah out of the SBAC testing consortium.
There are also unpleasant federal control attempts coming to Utah related to the longitudinal database Utah has built with a $9.6 million dollar federal stimulus grant. Utah parents deserve to know that the aggregated, purely academic, standardized testing and data comparison of the past is very different from standardized testing set up now. Testing scores will not be limited to academic data. All data collected by schools will be up for perusal by virtually anyone, including the federal government.
According to the American Recovery and Reinvestment act, states had to agree to build database systems according to federally dictated standards to qualify for stimulus money. All 50 states are capable of maintaining extensive databases on public-school students. Utah’s database meets all essential components outlined by the federal government.
The database includes non-academic information. (According to the National Data Collection Model) it will include health-care history, nicknames, family income, family voting status, gestational age of students at birth, student ID number, bus stop times, and so much more –and not just information about kids, but families.
You can view the National Data Collection Model database attributes (data categories) at http://nces.sifinfo.org/datamodel/eiebrowser/techview.aspx?instance=studentPostsecondary
As of January 3, 2012 the Department of Education implemented changes to the Family Educational Rights and Privacy Act (FERPA) and overrode the privacy protections Congress included in FERPA, the Competes Act, and the American Recovery and Reinvestment Act where privacy protection of student information was secure.
The changes allow access to any of the information in the databases by anyone! (They say “authorized representative” but later re-define it so loosely as to lose all power.)
The Data Quality Campaign (DQC, Creating a Longitudinal Data System, 2006) recommended that states include 10 essential elements when building a highly effective longitudinal data system, and Utah has all ten. These include:
1. A unique statewide student identifier
2. Student-level enrollment, demographic and program participation information
3. The ability to match individual students’ test records from year to year to measure academic progress
4. Information on untested students
5. A teacher identifier system with the ability to match teachers to students
6. Student-level transcript information, including information on courses completed and grades earned
7. Student-level college readiness test scores
8. Student-level graduation and dropout data
9. The ability to match student records between the Pre–K–12 and postsecondary systems
10. A state data audit system that assesses data quality, validity, and reliability
Please ask our state contact, John Brandt, to explain and validate what I am saying.
Information Technology Director
Utah Office of Education
To reference the above, here’s Utah’s report to the national data collectors: http://www.dataqualitycampaign.org/stateanalysis/states/UT/
Here’s Utah being praised by the national data collectors: http://secc.sedl.org/orc/rr/secc_rr_00088.pdf (And lastly, when you have 45 minutes to watch this video, here’s a well researched and evidence-based presentation by an Oklahoma think tank that clearly explains how the data collection councils (P-20 council) literally conflict with parent-empowering FERPA laws. http://youtu.be/z1pwUSlqerg.)
If you think that none of the data collection technologies are federally relevant, think again. We are told that we must allow all “stakeholders” access to this database. The specific stakeholders are listed; included in the very lengthy list of who can or should read all this data are: “Other public agencies serving children — to understand the relationship between their services and educational outcomes.”
Yes, that would absolutely include the federal government.
Thank you again for all your time, research, and the care you put in to our educational system. I feel that we are all in this together and if we pool our research efforts we can come up with solutions that are free of federal intrusions and yet uphold educational excellence in this state.
Here’s one comment that has been submitted to the USOE during this week’s comment period.
Click to open: SBAC Cooperative Agreement PDF
I was looking at the cooperative agreement of the SBAC which Washington is the “recipient” and Utah is considered a “sub-recipient” dated January 7th, 2011. In this contract, ED represents the US Office of Education. This contract from what I understand, is the agreement we have as a sub recipient with the federal government as we develop the assessments with the SBAC.
Is Common Core truly state led and do we have full control? The federal government states clearly in this contract what we are required to do. With this criteria, why did we sign such a contract and say we will have control?
On page 2 it states our responsibilities including we will have to give status updates, report our effort, deliver written reports and student data to the U.S. Dept of Education.
On page 3 it clearly states the “federal responsibilities”.
On page 9 it states: “the Grantee is responsible for managing the day-to-day operations of grant and sub-recipient-supported tasks and activities. This includes: 1) The Grantee and its sub-recipients actively participating in all relevant convenings, communities of practice, trainings, or other activities that are organized or sponsored by the State or by ED. ”
On page 10 it states clearly our cooperation with the federal government: “This supplement is awarded to support the consortium and its participating States efforts successfully transition to common standards and assessments. ” It also states, “The Grantee must provide timely and complete access to any and all data collected at the State level to ED.”
On page 7 it states the failure to comply clause, “Failure to comply with the content of this agreement may result in the Secretary imposing special conditions on the award pursuant to EDGAR §80.12 or taking other enforcement actions, including partly suspending or terminating the award, pursuant to EDGAR §80.43
Question: What are “the other enforcement actions” should we not be able to fulfill our part of the bargain? Will we have to pay back the amount utilized on our behalf to create CC if our efforts are not “good” enough?
Thank you for addressing my concerns.