Accountability Common Core Education Industry Testing

Vermont: The Heavy Fist of the Federal Government Demands Testing!

Interesting essay samples and examples on:

Vermont is not only a beautiful state, but it is a wonderful state when it comes to education. Early on, Vermont policymakers made clear that its educators would do what was right for children and would not be bullied by federal bureaucrats in Washington, D.C.


But something strange is happening. Keri Gelenian, the principal of Rivendell Academy, sent out a letter to 196 other principals and SBAC testing coordinators the Common Core test to inform them that the school would not administer the test. The response was silence. Then State Commissioner Rebecca Holcombe, who was earlier named a hero of American education by this blog for her steadfast values, wrote a letter to all schools warning that they would lose all federal aid–Title I, special education, and everything else– unless they gave the Common Core test. I assume she believes this to be true or she would not have sent out this warning.


But we learn something important from Holcombe’s letter: the federal government is using its power to force states to give the Common Core tests. This is grounds for a lawsuit challenging the U.S. Department of Education’s for interfering with the curriculum or instruction at any public school, a prohibition written into law. Everyone knows that tests drive curriculum and instruction. The media endlessly repeats the lie that Common Core and Common Core testing are in no way tied to the federal government. The lying must stop. Common Core and Common Core testing are driven by federal might, not by the voluntary endorsement of the states.


Please read the following correspondence, written by Michael Galli, dean of students at Rivendell Academy in Vermont:



Those of us who administer the SBAC test in silence will not be condemning our students to wear “a scarlet letter,” rather we will be stitching that ruddy sign to the lapels of our breast.

A Response to Secretary Holcombe’s February 17th SBAC Memo

On December 11, 2014 a principal from Vermont penned an anonymous letter to Governor Peter Shumlin and Secretary of Education Rebecca Holcombe.1 It was in response to the Governor’s statements that school budgets are too high. The principal declared, “I am not arguing against the need to examine how we fund our schools … [but] neither one of you truly understands the crisis facing our school children.” He/she then presented three detailed case studies of individual students in his/her district that struggle with abuse, poverty, drugs, and mental illness; four very real problems that virtually all public educators in this nation encounter. What I found odd about the letter is that this “30 year” education veteran felt the need to write in secret for fear that his/her district would “come under political fire.” I thought that I had left that climate far behind when I moved out of California. After all, last year colleagues and I drove to Montpelier to speak with Secretary Holcombe regarding our concerns about education in Vermont. I found her to be open, reflective, and transparent, the very opposite of fear-inducing. After my visit I sent her a research article I wrote critizing the corporate path to the Common Core.2 It never occurred to me not to sign it. If, however, such a practice is an aberration in this state, then, for the first time in my five years here, I am fearful. Any time those of us who toil in the academic arena, the education ground of democracy, withhold our voice out of fear, our republic suffers.


On February 10, 2015 Rivendell Academy Head of Schools Keri Gelenian penned a 338 word open letter to 196 of his fellow Vermont administrators and SBAC test coordinates in which he declared:


The amount of instructional time and administrative time that has been devoted to preparing for the testing is completely disproportionate to any conceivable benefit that I can see coming from our results… We have been lulled into accepting testing as a useful practice without questioning the impact, if any, on learning or meaningful change in school structures… From my vantage point, this more mechanistic testing structure is pulling me, teachers, and students away from important instructional time… I am beyond the point of questioning the educational relevance of SBAC testing. I am at the point of questioning the moral implications of the testing, especially for our most vulnerable learners. I have been vocal about my concerns with this latest round of testing but I am kicking myself for not being vocal enough. My next board report will include a request that Rivendell not administer the test.3


On February 11, Dr. Gelenian received only one response from the one hundred and ninety-six. It read, “Thanks for your thoughts.” How can such silence be accounted for if fear is removed from the equation?


Six days later Secretary Holcombe published a memo to all Vermont Superintendents and Principals. It begins:


It has been brought to my attention that some school leaders in Vermont are contemplating an “opt out” of the Smarter Balanced Assessment Consortium (“SBAC”) test at the local level. I know that for some of you, there is frustration around the timeline and the work involved with the initial administration of the SBAC. While this frustration is understandable, I want to be very clear that if we (AOE, school administrators and school board members) in Vermont do not maintain fidelity to federal requirements, we/you will forfeit federal funds. As federal fund recipients, at both the state and local level, we must be clear that schools, districts or systems that do not administer the test will not be eligible for any federal funding, without exception. This includes federal programs such as IDEA, Title I, Title II, and federal support for Child Nutrition.4

From memos like this, one begins to understand the origin of the fear factor. I hypothesize that the Secretary’s choice of the phrase “some school leaders” is just a polite way of not singling Dr. Gelenian out. I suspect this because if others were publically contemplating an opt-out, why wouldn’t they have shared their views with Rivendell’s Head of Schools? If, indeed, there are others, in the spirit of transparency I would ask the Secretary to share their reasons. What is not made clear in Secretary Holcombe’s memo is whether or not she endorses the threat to pull federal funds (not to be confused with being in a position where she may be forced to carry it out), although the fact that “without exception” is underlined does not bode well. That being said, I would be interested in hearing her view on the matter.


What such a threat means for Rivendell is the loss of more than half a million dollars. Because such funding is intertwined with state and local dollars, a complicated matrix to be sure, the negative impact on the percentage of the 520 students in our district who receive special education and reading support is difficult to calculate. One fixed metric that can be calculated is the number of children (the anonymous principal’s case study souls) that the government will no longer feed breakfast and lunch.


Secretary Holcombe makes clear that she “objects” to the “punitive use” of the SBAC test “under NCLB,” aptly criticizing the SBAC’s “proficiency threshold” that is likely to condemn “two thirds of our high school students” as “not proficient” despite the fact that Vermont ranks “seventh in the world in math and science.” She writes, “It is a virtual certainty that once again, all our public schools will be labeled [by the federal government] ‘low performing.’” And despite the “anonymous” principal’s claim at the top of this letter that the Secretary does not understand the crisis facing our school children,” she clearly does, as evidenced by her attached citation of Gary Orfield:


“Setting absurd standards and then announcing massive failures has undermined public support for public schools . . . We are dismantling public school systems whose problems are basically the problems of racial and economic polarization, segregation and economic disinvestment.” (Educational Researcher, August/September 2014, p.286)5


This is why I find her underlined plea to “not let the inappropriate uses to which tests are put under NCLB undermine what value there is in tests, when used appropriately” difficult to accept, especially after equating the government’s use of the tests as akin to forcing students “to wear [a] ‘scarlet letter’ of shame,” hence Dr. Gelenian’s “questioning the moral implications of the [SBAC] testing.” Equally confusing is that on September 18, 2014 the Vermont Agency of Education sent out a memo inviting “K-12 educators, higher education faculty, parents, and community members from Vermont to participate in the Online Panel for Achievement Level Setting for the new Smarter Balanced Assessments in English language arts/literacy and mathematics… to help ensure these new state assessments are accurate and fair measurements of college and career readiness for all students,” yet in a statement to the SBAC governing states six weeks later Secretary Holcombe declared that “as of yet we have little empirical evidence related to the validity of the proposed cut [SBAC test] scores for actually discriminating between those who are ‘college and career ready’ and those who are not.” 6, 7 As she writes in her February 17 memo, Secretary Holcombe has good reason to “worry that too much emphasis on test-based accountability creates a new kind of equity gap, as schools — and particularly high poverty schools– feel compelled to narrow curriculum to what is tested, and away from other critical learning children need to thrive as adults in civic and economic life.” The Smarter Balanced Assessment Consortium website celebrates its “level setting” success with an eight minute video that shares comments like this from Larry, a social science curriculum coordinator:


We’re going to have an instrument that will truly gauge what our student’s know and are able to do, and we can make more informed decisions regarding enhancing their education moving forward.


Or Susan, a 7th grade math teacher:


These recommendations are crucial to align exactly what we are supposed to be teaching with what they are actually testing to get really good quality information on the achievement of our students.8


Yet this is not the only “inappropriate use” that has astute educators concerned. In January 2011 the U.S. Department of Education and the Smarter Balanced Assessment Consortium’s “Cooperative Agreement” was released stipulating that the SBAC consortium “must provide timely and complete access to any and all data collected at the State level to ED or its designated program monitors, technical assistance providers, or researcher partners.” 9 In a troubling turn of events, in December of that same year, without any congressional oversight, the U.S. Department of Education made significant changes to the Family and Educational Rights and Privacy Act (FERPA) allowing non-governmental agencies access to student information without obtaining parental consent.10 One month later the U.S. Department of Ed released an updated version of its National Education Data Model, a database of 240 individual student descriptors including discipline, disability, pregnancy status if unmarried, class rank, and co-curricular activity “for states to collect the data they need to fully understand their progress on successfully adopting the Common Core State Standards or any other standards.”11,12 In response to concern over the federal government’s data mining of students, Secretary Holcombe signed a letter addressed to Arne Duncan in January 2014 pledging “not [to] share any personal identifiable information about K-12 students with the USED or any federal agency” with the understanding that such a stance “is consistent with…the cooperative agreement between the consortia and the USED,” which, as cited above, appears not to be the case, and there is no indication that such a pledge carries the weight of law. 13


The goal of the legislation that led to SBCA testing has always been to link teachers to students for “the development of performance-based teacher evaluation systems.” 14 According to a 2013 report published by The National Council on Teacher Quality, thirty-five states “require student achievement” to be “a significant or the most significant factor in teacher evaluations.” 15 An interesting case to watch will be that of fourth grade teacher Sheri Lederman from Great Neck New York. She is suing the New York State Education Department for tying “20 percent of her evaluation score … to local tests and 20 percent … [to] state tests.” 16 To her credit, Secretary Holcombe has resisted this trend, even going as far as questioning Arne Duncan directly in March 2014 about the appropriateness of using “high stakes” test to evaluate teachers.17 Duncan told her that Smarter Balanced should answer such a question. She then informed him that she did put the question to Smarter Balanced and was told to ask Duncan. Appearing to dodge the question, Duncan finally admitted in the exchange with Holcombe that test score data should be used to “identify top-performing teachers and not punish low performing ones,” even though he is on record of supporting “50 percent of a teacher’s evaluation [be] based on student achievement data.” 18 Even though Secretary Holcombe questions the validity of using student scores in teacher evaluations, Vermont schools have been forced to submit data to the AOE for the past two years linking individual students to individual teachers. As to the use of this data, the Agency’s response is less than reassuring as evidenced by a statement published by the Secretary’s predecessor on March 13, 2012 supporting the teacher/student link for “an analysis of teacher effectiveness.” 19 And then there is the following statement published on the Agency’s SECT FAQ page:


The VT DOE is required to collect these data. However, the types of analyses and reports created from these data have yet to be determined but we have identified many benefits of having access to the information linking teachers and students. 20

In December of 2013 Vermont principals “were surveyed regarding their districts’ teacher evaluation practices.” 21 Of particular interest was question # 3:


Does your evaluation process include student assessment results, including student growth measures, as a criterion in determining teacher performance?


I eagerly await the SBAC’s white paper on the “appropriate and inappropriate use of test scores.” It is important to understand, however, that even though under the Shumlin administration our current Secretary of Education is able to resist using SBAC results to punish teachers, the punitive machine, embraced by the federal government and, so it would seem, the majority of states, has been built, and has our number; something that will be passed on to the next administration.


And then there is the largest “inappropriate use” of all, administering the SBAC test as part of U.S. national security policy. No, this isn’t a statement of hyperbolic fancy. The long road to the Common Core began with the 1983 report A Nation at Risk and culminated in its 2005 ideological successor, Rising Before The Gathering Storm, a title poached from Winston Churchill’s 1948 work chronicling the rise of the Nazi state. 22,23 Penned by a committee that included Norman R. Augustine, retired chairman CEO of Lockheed Martin Corporation, the world’s largest weapons manufacturer, Lee Raymond, chairman and CEO of Exxon Mobil Corporation, the world’s largest oil company, and Robert Gates, former director of the CIA and future Defense Secretary of the world’s largest military, “ Rising Storm” repackaged A Nation at Risk’s claim that public education in America is a failure and poses an imminent national security threat. This, despite the fact that between 1983 and 2005 both the economy and weapon’s spending, development, and deployment reached an all-time high.


Ironically, or logically, depending how you look at it, the Common Core SBAC test that we are about to deliver to our students will use software developed by Amplify – a subsidiary of Rupert Murdoch’s News Corp – to report and analyze test results.24 The CEO of Amplify is former New York City school chancellor Joel Klein who, in 2010, published a “Manifesto” along with Michelle Rhee in the Washington Post declaring “everything we use in assessing teachers must be linked to their effectiveness in the classroom and focused on increasing student achievement” so that we can “establish a performance driven culture in every school.”25 In 2012 Klein, along with Condoleeza Rice, published a report for the Council on Foreign Relations titled U.S. Education Reform and National Security, as well as an article for CNN titled Education Keeps America Safe.26 Klein and Rice argue that education in America is “on a trajectory toward massive failure” which poses a “direct threat” to our “national security.”27 Their proposed solution? “States should expand the Common Core State Standards and implement assessments that more meaningfully measure student achievement” as well as “launce a ‘national security readiness audit’ to hold schools and policy makers accountable for results and to raise public awareness.” Until policy makers divorce themselves from the use of fear mongering war rhetoric when discussing public education, absurd militant mandates and threats like “100% proficient” and “do as we command or you will be defunded,” will continue to be issued.


There is no evidence that SBAC data will improve education in Vermont. And, in fact, if you believe as I do, that what is needed to properly equip more students to prosper in the 21st century is more instructional time, coupled with better mental health services, then SBAC testing actually retards such work. The idea that SBAC data will inform teachers which students are “career and college ready” and which need better support is laughable. Though “career and college ready” is more a political than academic descriptor, if schools in Vermont do not already know, from a very early age, which of their students are on track to succeed after graduation and which are likely to struggle, then I think one could agree with Klein and Rice that our education system is on a “trajectory toward massive failure.” This, of course, is not the case because schools in Vermont do know this information and can list the strategies that they have in place to support their students at risk. I put this question to Secretary Holcombe. Why not ask each school for the following information to be provided to the Vermont AOE in a confidential manner:


  1. Define your criteria for “career and college ready.”
  2. Provide of list of students in each grade that are at risk for not meeting this criteria.
  3. Provide list of reasons why each of these students are at risk.
  4. Provide a list of supports and interventions you have in place for these students.
  5. Provide a list of supports that you believe these students need but are not getting.


With this information, the Secretary could convene a more meaningful, relevant, and problem solving dialog among Vermont educators than SBAC data could ever hope to provide. And, of course, one of the reasons why Vermont ranks “7th in the world” is because we already have strategies in place that work. We can, of course, do better.


Maybe Dr. Gelenian’s memo was not ignored by his peers out of fear, but resignation, though I can hardly judge which is worse. Just because so many of us who fill the ranks of public education come from roots embedded deep within the working class, does not mean we need to plod along in silence like Orwell’s old plow horse Boxer. The Vermont AOE is not a knackery. Secretary Holcombe, who renowned education scholar Diane Ravitch has labeled “a hero of American education” needs to hear our voice.28 I believe she wants to hear our voice. Remember, we work within the academic arena. We get paid to think. What a privilege!


Respectfully to all,


Michael Galli

Dean of Students

Rivendell Academy

[email protected]



  1. Letter from Anonymous Principal:’%20Association/W~Anonymous%20Vermont%20School%20Principal~Testimony~1-29-2015.pdf


  1. The Corporate Father of the Common Core:


  1. Email to SBAC Coordinators:


  1. AOE SBAC Memo:


  1. AOE MEMO to SBAC Governing States:


  1. Vermont Agency of Education Invites Educators and Others to Online Panel to Recommend Achievement Level Scores for Proficiency on Smarter Balanced Assessments:


  1. AOE MEMO to SBAC Governing States:


  1. Video on Achievement Level Setting:




  1. EPIC v. The U.S. Department of Education:


  1. Common Education Data Standards (CEDS) Version 2 Data Model Guide:


  1. Common Education Data Standards:


  1. CSSO Letter to Duncan:


  1. State Implementation of Reforms Promoted Under the Recovery Act:


  1. National Council on Teacher Quality:


  1. Will test-based teacher evaluations derail the Common Core?:


  1. Duncan Addresses Council of Chief State School Officers:


18. The Tennessee Way: Lessons for the Nation:




  1. SECT FAQ:


  1. Teacher & Principal Evaluation Survey Results:


  1. A Nation at Risk:


  1. Rising Above the Gathering Storm:


24. Amplify Insight Wins Contract from Common-Core Testing Consortium:


  1. How to fix our schools: A manifesto by Joel Klein, Michelle Rhee and other education leaders:


  1. S. Education Reform and National Security:


27. Rice, Klein: Education keeps America safe:


  1. Rebecca Holcombe, a Hero of American Education:








Related posts

Rob Astorino, Cuomo Opponent for Governor, Will Opt His Children Out of State Testing


Psychologist: The Common Core Tests Cannot Be Independently Verified for Validity or Reliability


Florida Law Requires Multiple Tests for Kindergartners


Angela Engel: Support Your Child by Opting Out of State Tests


Leonie Haimson: What Matters Most in Really Reforming Our Schools: Must Watch!


New York City: Commissioner King Brings His Show to NYC Next Week


Hakeem Jeffries, a DFER Democrat, Joins the Party Leadership


Boston Globe: Will Common Core Mean “Joyless Kindergarten”?


New Mexico: Hundreds of Students Walk Out of Common Core Tests


Leave a Comment