When I see smart guys like Dean Millot and Sherman Dorn confused about what went on in Reading First I think it is safe to assume that nearly everyone else is confused as well.
So this is my attempt at a brief and simple primer on what actually went on in Reading First. To understand what's going on you need to understand the reading wars, basic economics, and a little history. Then all you need to do is to follow the money. I'll keep this as short and sweet as is humanly possible.
The diagram below shows you the kinds of reading programs in use.
There are two kinds of reading programs on the market: whole language/balanced literacy and phonics programs.
Whole language programs and balanced literacy programs are similar. Balanced literacy programs merely add a phonics component. Both programs use predictable texts which favors the guessing of text from context clues rather than the decoding of words via phonics skills.
Phonics based programs use highly decodable texts that facilitate the decoding of text via the use of phonics skills and discourages the use of context clues during the initial stages of reading instruction.
Oddly enough, the presence of a phonics component does not distinguish between between balanced literacy programs and phonics based programs. Both programs claim to have a phonics component. In fact, both will argue that they contain the five essential elements of reading instruction (ECRI), i.e., phonemic awareness, phonics, vocabulary development, reading fluency, and reading comprehension strategies. These are the five components that the National Reading Panel's meta-analysis found were present in all highly-effective reading programs (though the presence of these components does not guarantee effectiveness).
Rather, the most easily ascertainable difference between the two is in the texts that are used in the initial stages of reading. Look at the texts and you'll easily see which pedagogical lineage the program belongs to.
Most of the reading programs in use today have not been validated by scientifically based reading research (SBRR). At the time Reading First was adopted, only three reading programs have program specific SBRR -- Success for All (SfA), Direct Instruction's Reading Mastery (DI), and a prior edition of Open Court (OC) (though not the current edition). All of these programs are phonics based programs using highly decodable texts.
The publishers of these reading programs are capitalists and will dutifully provide whatever product the market calls for. The market has been predominantly calling for balanced literacy programs. This is because balanced literacy ideologues are firmly entrenched in most school districts throughout the country and at all levels of the education hierarchy, including at schools of education and at state level departments of education.
The poor track record of balanced literacy programs with 'at-risk" students and the mounting research base of phonics based programs has not served to dislodge the entrenched balanced literacy programs which remain in widespread use.
But, phonics advocates had the Bush administration's ear starting in 2000. Apparently, someone had the idea to let the federal government do what it does best -- bribe schools with federal dollars to adopt scientifically based reading programs for their "at-risk" students. And, thus, Reading First was born as part of NCLB and the effort to force more accountability and obtain better results from the federal dollars being sent to schools to increase the achievement of "at-risk: children. NCLB was enacted with overwhelming bi-partisan support.
Reading First was designed to cause change. And change is going to cause tension between those who want change (and federal dollars) and those that want to maintain the status quo (while getting federal dollars). Given the state of the reading wars let's see how all this breaks down.
At the state level, the motivation is to continue the status quo, i.e., balanced literacy, while grabbing as much Reading First funding as possible. This is called rent seeking and it is what monopolies do. (It's also why your utility companies and the DMV treat you like crap.) As a result, these folks were going to do whatever they could to get their existing reading programs funded with little or no modification. If you read the IG's reports on Reading First, you can plainly see that this activity was going on behind the scenes and DoE was trying to prevent it.
Reading program publishers were trying to increase their market share caused by the disruption caused by the injection of Reading First funding. To accomplish this goal they published phonics-based programs that were capable of being funded under Reading First, but yet were palatable to those balanced-literacy lovin' educators who would ultimately be selecting those programs at the state level. (Publishers are, by and large, capitalists who will provide the market with whatever it is asking for.) Thus, publishers were also trying to game the system by skirting the line between phonics-based programs and balanced-literacy programs in order to grab the biggest market share they could. Similarly, publishers were simultaneously trying to re-market their existing balanced-literacy programs as complying with the Reading First statute.
The U.S. Department of Education would be charged with determining which reading programs qualified for Reading First funding and which ones didn't. The DoE would be constrained by two primary factors: the statute itself and the department's prohibition against directly mandating curricula.
The relevant section of the Reading First statute is vague, requiring only that funding go to a school that selects and implements a reading program that is "based on scientifically based reading research" and includes "the essential components of reading instruction." Both of these terms are further defined in the statute, but not in a meaningful way that would have informed DoE where to draw the funding line.
But, let's cut right to the chase. There are only three meaningful places where the funding line could be drawn based on the statute.
1. Funding limited to reading programs having program-specific reading research. Basically, this would have limited funding to Success for All, Direct instruction, and Open Court. But, the statute clearly intends broader funding than this since it reads "based on" SBRR and not something more restrictive like "having its own program-specific" [SBRR]. Now Bob Slavin thinks the line should have been drawn here, but Slavin is an interested party that would reaped a financial windfall had the line been drawn here. I've been going back and forth with Dean Millot, both in private correspondance and on his blog, about this issue. Dean thinks this is where the line should have been drawn, but has been unable to convince me that his interpretation is proper. I will go so far to say that this is where I wish the line were drawn, but the statutory language precludes such a strict interpretation. Moreover, no one involved in the drafting of the law has gone on record and said that this is the proper interpretation of the statute. If anything, those members of Congress who have made statements appear to be of the opinion that the funding should have been widely distributed.
2. Funding limited to phonics-based programs having decodable texts. In my opinion, this is the most likely place that the funding line should have been drawn based on the statutory language. In fact, this is where DoE thought the line was drawn and was the distinguishing point at which they excluded programs from funding. All the major publishers must have thought that this was where the line was drawn as well sicne they all developed new phonics-based reading programs. Publishers were also trying no make their balanced literacy programs appear to be phonics-based by including a phonics component. these programs were rightfully sent packing by DoE since the research shows that a phonics component won't do the trick; it has to be a phonics component plus complementary decodable texts. In any event, this is where the main battle line was drawn and where much of the behind-the-scenes fighting took place. A few questionable reading programs appear to have been funded, but it appears that those programs snuck by with the help of ideologues at the state level that did whatever they could to obscure the reading programs they intended to fund on their Reading First applications. It also appears that DoE was fearful about violating the prohibition against mandating curricula and capitulated to the demands of some of the more aggressive states that wanted to fund balanced literacy programs. The facts also indicate that DoE did what they could to make sure as few non-phonics-based reading programs as possible.
3. Funding not limited; all reading programs funded. This is not a reasonable reading of the statute, but some members of Congress and the Inspector General believe that some reading programs were unfairly excluded from funding. Given that DoE pretty much funded all the phonics-based reading programs, this would mean that all reading programs were fundable for some to be unfairly excluded. This is a ridiculous interpretation, by any standard, but it appears to be the standard that the IG used in finding in its reports. And, those reports were parroted by various Democratic congressmen for partisan ends -- just in case you think your congressman is more concerned with making sure "at-risk" are properly taught with federal dollars than throwing them under the bus when political gains could be made.
With this background in mind, you can read any Reading First media story, any congressional press release, or any of the IG reports and make a fair evaluation of what actually went on. Did DoE violate the law?
We don't know for sure. The IG didn't find any actual violations in which a program was improperly excluded, was improperly include, or in which anyone in a position to make a funding decision made one that benefited him or herself.
At most, DoE played fast and loose with the law and regulations in an effort to maintain as much control over the process as possible. That activity was technically improper by an reasonable standard even if DoE thought they needed the control to fend off hostile publishers and states that were trying to get funded improperly. The conditions appear to be in place for violations to have occurred, but oddly, the IG failed to find any actual violations.
But that's for you to decide. If you find an actual violation let me know.
What a great summary.
Can you give a sample of a sentence that is "easily decodable" versus the "whole language" kind?
Here are two examples from the Reading A-Z site, which offers both “leveled” books (balanced literacy approach – sight words and “predicting” from pictures and the first letter) and “decodable” stories, based on letter-sound correspondences that have been taught. In decodable stories, children should be able to work out the words even if they have not seen that exact word before, providing they have learned the letter/sound association, and learned the skill of blending sounds into words.
Both these are from the Kindergarten level, roughly partway through K:
(Fountas and Pinnell Guided Reading Level A)
Maria Counts Pumpkins
(each sentence is on a page by itself, with a detailed illustration)
Maria has one pumpkin. Maria has two pumpkins…. (etc.) up to Maria has seven pumpkins. Maria has too many pumpkins!
Note that most of these words are not “decodable” by the beginning kindergarten student, who would not have learned diphthongs (ou), or how to sound out two-syllable and three-syllable words like “Maria” and pumpkins” and “many.” The number words would have been taught as sight words, and can also be inferred from the pictures. “has” can be decoded, but might also have been taught as a sight word. Many K students learn letter names, but are not taught to decode words, left-to-right, saying the sounds. They are told to use the first letter sound as a “cue” to guess the word.
Now here’s a decodable story which would be appropriate for a child who had learned most of the single consonant sounds and the short vowel sounds (plus the long vowel digraph ay and final y and i-consonant-e as a long I sound)), and been taught to blend them together. Programs like “Jolly Phonics” teach these to four and five year olds in one school term, with a lot of practice in blending new words and spelling by sounds.
My Pug Has Fun
(format is the same, but there are several sentences on each page and a detailed drawing. The drawing would help the child confirm that he decoded correctly )
My pug Bud and I like to play. We like to tug on the rug. We like to get a bug. We like to sit on a rug in the sun. (New page, shows pug digging in a sandbox, holding a coffee mug in his jaws, while child takes a nap on a blanket or mat) My pug likes to tug my mug. He dug a pit. He put my mug in a pit.
There are a couple more pages about things the pug and boy do together. It’s not deathless literature, but it’s cute. The child can read it independently.
Many of the “leveled books” at the early stages (you can see some free samples on readinga-z.com) are quite contrived and boring. It’s hard to imagine any kid staying up with a flashlight to read these things under the covers! Although balanced literacy proponents make a big deal about exposing children to “authentic literature,” it is a sad fact that most of the “literature” the students read is contrived and far from authentic – or interesting.
Decodable stories are no prose masterpieces, either, but they do provide children with a chance to consolidate an important skill. Moreover, children who master decoding early and fluently will soon be reading that “authentic literature” that “whole language” enthusiasts love.
Wow, what a great discussion on Reading First. I have already posted my comments on edbizbuzz so I hope this is legal. As I mentioned there, this is one of the few times I have actually read a blog interchange that is factually based and addresses the issues in a serious way. Some other blogs that have done an outstanding job of discussing the details and the issues are those sponsored by Mike Petrilli (Flypaper), Jay Greene (Jay Greene), and Pat Riccards (eduflack). Likewise, the discussion on the Interim Report on the RFIS is very informative and compelling. You guys are really studying these issues. I may have a different take on some of the points raised and some of the interpretations of the law that have been made, so I will lay them out for discussion sake.
The first point I want to clarify is that Reading First was not designed to pit phonics programs against whole language programs. In fact one major intent that we had in drafting the law was to move the ball beyond that very unproductive debate.
Some history. In 1996 then Bill Goodling, Chairman of the House Education and Workforce Committee, requested that I brief him and his staff on the converging evidence relevant to reading development, reading difficulties and reading instruction. Mr. Goodling was, as he said, “tired of this reading wars nonsense” as he felt that the real issues were not being addressed – to wit, how the heck you help poor kids learn to read. The discussion during those briefing led to the conceptualization of the Reading Excellence Act (REA), the first piece of legislation that invoked the term Scientifically Based Reading Research (SBRR) and required federal funds to be spent on only those programs, materials, etc., that met the an SBRR criterion. When Bob Sweet and I worked on the development of Reading First, we were able to bring forward much of the language used in the REA.
During the period from 1996, Chairman Goodling and Chairman Jeffords of the Senate HELP Committee felt a need to apprise committee members of what constituted SBRR and requested that I provide testimony on this topic several times. Concurrently, the NRC convened a panel funded by DoED and NICHD to examine what was known about preventing reading difficulties. Given that their published findings in 1998 did not address what types of instructional programs, strategies and approaches were most beneficial for well defined kids, Senator Thad Cochran and Representative Ann Northup sponsored the National Reading Panel and assigned it to NICHD to convene the panel in partnership with DoED.
Most in the reading world are well familiar with the NRP but it appears that few understand what it actually found and reported. In a nutshell, it reported that phonics is absolutely essential but insufficient in teaching kids to read. This finding was reported probably a dozen times in the report. As much attention was given to phonemic awareness as a necessary but not sufficient component, fluency as a necessary but not sufficient component, and vocabulary and comprehension strategies as necessary but not sufficient component. The NRP was anything but a “phonics” report as has been interpreted by many. The finding that ticks a lot of folks off – particularly those who are invested in literature based approaches – is that evidence showed that explicit and systematic instruction was more effective than less intentional and systematic instructional strategies, approaches, and methods. This raised the hackles of some to such a degree, a number of replications by Camilli et al., Swanson and Hammill, and Steubing et al, have looked particularly at the finding of the need for systematic instruction in teaching phonics. Most recently, Dick Allington edited an invited series of papers in the Elementary School Journal which claimed that the NRP got it wrong – Systematic instruction in phonics was no more effective than non-systematic instruction. But a replication of those findings by the Steubing group published in a highly rigorous peer reviewed journal (Journal of Educational Psychology) supported the NRP findings. If you guys are into these kinds of details I strongly suggest you take a look at this series of studies – this is how science is supposed to work – replication rather than getting medieval on each other.
Sorry for the digression but it was important because we based Reading First on the findings of both the NRC Panel Report and the NRP findings. And in writing the legislation we DID NOT place any greater emphasis on phonics than on any other reading component. To obtain federal funding, a program had to be COMPREHENSIVE, covering all five reading components) and delivered explicitly and systematically. It is really that straightforward. We did not want there to be any misunderstanding about the absolute need for comprehensiveness and systematic and explicitly instruction – why – because that is what the converging evidence indicated were essential for improving reading capabilities in kids at risk for reading failure or kids who were already struggling.
As has been reported many times, our initial language required that federal funds could only be spent on programs with proven effectiveness. It is the case that this would have limited the number of programs eligible for funding, and the discussions within the congressional staffs revolved around the practicality of implementing such a small number of eligible products. But I am pretty sure that the decision was equally political. If one checks the lobbying schedule with the congressional policy makers working on Reading First, you will find a flood of visits from every commercial text book publisher and vendor known to man. In the research I am doing for an upcoming book I found that out something I did not know. A very large sticking point was that Congressional folks felt that the prescriptive program effectiveness criterion would exclude what they called “home grown” programs. This was a very big deal. The end result was a feeding frenzy by publishers and small program vendors all ravished and wanting a piece of the pie. It certainly was not hard for many to change marketing language to meet, at least on paper, the broader funding criteria. While some programs that were used were legitimate vis-à-vis meeting the criteria, others were not. The Oregon group provided a service to that state by designing a review protocol to evaluate programs. It was a systematic and objective protocol at least in my view, and other states picked it up. But no state ever had to use any published program (remember the “home grown” issue) or any checklist. To be sure however, given that many states and districts had no idea what constituted SBRR, they were grasping at anything that funded states used. Implementation was not well thought out at the Federal level.
The bottom line is that the softening of the language placed a significant burden on Chris Doherty and his very small team to ensure that funding was provided for only those programs that were comprehensive and delivered instruction systematically and explicitly. He never, nor was he allowed to, recommend any particular program. He was required by the law to withhold or withdraw funding if it was to be used on programs not meeting the comprehensive and instructional criteria. Thus, he did not allow funding for the Wright program or the Rigby program, both of which did not meet the dual criteria at that time. And he definitely did not dissuade any state, district, or school from adopting SFA. The OIG found no evidence that SFA was discouraged at either the federal level or the Technical Assistance Center level. The OIG has in its possession substantial emails from the Florida TAC to the SFA staff providing a great deal of assistance. The Florida TAC did balk when Slavin asked for them to write a written endorsement of the program and to send to all states. That would have given an unfair advantage to SFA as neither the TAC nor the feds could do that for anyone.
All that said, there were serious implementation and perceived conflict of interest problems, and some real goofball mistakes. A state RF person in Georgia told vendors that there was a list of approved programs. There wasn’t. Another mistake was the pushing of DIBELS by a DIBELS trainer who somehow was working on a TAC staff. Both of these problems were taken care of immediately and the OIG has that documentation. I am still working through the issues with the assessment committee work and have not figured out the perceived conflict of interest issues in that area. What Congress, and many commentators do not understand, is that Doherty was under a strict obligation to not provide funding for programs that did not meet the comprehensive and instructional criteria. If one examines the programs that were not funded, you will see immediately why those programs were not funded. I cannot find a program that was purchased through RF funds that addressed only phonics, but I certainly stand to be corrected.
There are some issues brought up in this discussion that I strongly disagree with. A point was made that I was the subject of investigation. I was not. I was asked by the OIG and the Congressional committees to provide relevant information, and if necessary to appear as an informational witness. I willingly proactively provided all information about my professional and financial interactions with everybody I knew in education. If asked any questions about any topic I accompanied my answers with objective evidence. And it is beyond me that my self-interest flowing from being a subject of investigation (which I wasn’t) would lead me or anyone to re-invent how we wrote the language
Second, that tired conclusion that I was a long time advocate of phonics only reflects a limited if not sloppy examination of the written record and probably a reliance on some media outlet that believes its readers are morons who can’t get their hands around comprehensiveness. All one has to do is examine my testimonies before congress beginning in 1997, the research criteria that we required at NIH to ensure that single approach programs were too narrow for funding (see 1992 RFA on studies to determine effectiveness of reading interventions, methods, programs, and approaches). , and at least 10 peer reviewed publications in the 1990s that reflect my concern, if not disdain, for the simple phonics-whole language dichotomy. In fact, look at my 1997 testimony where I described the serious negative consequences of trivializing reading into two dumb dichotomies.
Third, I believe that the changes in the legislative language are available in different forms. Bob Sweet, while a Republican and a supporter of “phonics” is a very honest man (for the record, I am a Democrat). His integrity has never been questioned by any congressional members or staff on both sides of the aisle. He has a tremendous amount of experience negotiating language in conference and with committee staffs. A simple phone call to Bob would provide you with a detailed analysis of the process that transpired and could tell you who supported and did not support our initial language. Both of us discussed this issue in depth with the OIG as they were trying to get their hands around the intent of the law. An interesting tidbit is that Sweet and I were, I believe, the last two individuals interviewed by the OIG even though we were the closest to the conceptualizing and drafting of the Reading First program. Weird. I would also ask Gene Hickok and Susan Neuman who were told in clear terms that the criteria could not be too prescriptive such as to “penalize” “home grown” and other publishers and vendors. It might also be helpful to review the early speeches and discussions provided by President Bush on Reading First. Note, his focus on supporting only that “which works”. Even his intent was not immune to negotiation. As an aside, when writing the criteria for the RF evaluation study, Sweet argued strongly in writing for the evaluation to be conducted by an independent source clearly distanced from the Department of Education. No dice. The Minority staff negotiated that requirement out of the language.
A point was also made about different congressional members supporting or no supporting different interpretations of the law. One problem is than most did not understand its intent. The major issues raised about the law being in conflict with the requirement that the feds cannot dictate, influence, etc curricula at the local level was never even questioned by any members who signed off on Reading First. Their staffs must have know that the law required the DoED to not fund or to withdraw funding from states and/or districts that were implementing programs that did not meet RF criteria. Bad habits are hard to break. Congressional members are used to formula funded entitlement programs, not formula funded programs with criteria for funding.
I am not sure if this response to the healthy discussion is helpful in clarifying or whether it further muddies the waters. I am sure you will let me know. I also want to contribute to the good discussion/debate on the RFIS interim report. I will get to this as soon as possible.
DeRosa and Millot have raised additional points that I would like to discuss. Forgive me for repeating information that I have presented before. The intent of RF was to reserve federal money for reading programs, approaches, and strategies (original language) that had been found to be effective under well defined conditions. As one who persistently and predictably argued for reading program specific evidence of effectiveness not only in NIH Research initiatives beginning 1n 1985 (when I was a consultant to the NIH) but also stressed repeatedly before congress beginning in 1997 and every year until 2005, I had no motive, politically or financially, to depart from this position and never did so (go to www.reidlyon.com for copies of testimony on these issues). Do I protest too much when individuals allege that I recommended a reduction in the rigor of the initial Reading First criteria? You bet. We had been working since 1996 to have well defined effectiveness criteria (not just the term "research-based" formally placed in federal legislative language. Our first attempt was in the drafting of the Reading Excellence Act with conceptualization and writing beginning in 1996 and funding in 1998. Specifically, NICHD worked with the Education and Work Force Committee to produce the definition of SBRR noted below (see Pl105-277, 112 stat. 2681-3930, 20 U.S.C, 6661a et seq).
‘‘(6) SCIENTIFICALLY BASED READING RESEARCH.—The term
‘scientifically based reading research’ means research that—
‘‘(A) applies rigorous, systematic, and objective procedures
to obtain valid knowledge relevant to reading
development, reading instruction, and reading difficulties;
‘‘(B) includes research that—
‘‘(i) employs systematic, empirical methods that
draw on observation or experiment;
‘‘(ii) involves rigorous data analyses that are adequate
to test the stated hypotheses and justify the
general conclusions drawn;
‘‘(iii) relies on measurements or observational
methods that provide valid data across evaluators and
observers and across multiple measurements and
‘‘(iv) has been accepted by a peer-reviewed journal
or approved by a panel of independent experts through
a comparably rigorous, objective, and scientific review.
A couple of points. First, note the similarity between the REA language and the RF language. Second, the language in B (i) was changed from "employs scientifically appropriate experimental procedures to establish effectiveness" to the language actually used in B (i). Third, these changes followed significantly lobbying by representatives from reading programs not meeting the initial B (i) criteria. Fourth, similar specific language was proposed for Reading First but again was softened in the final versions. While lobbying efforts in both 1996-1998 for REA and from 2001-2002 for RF were undertaken by several vendors with several congressional members, a consistent effort was made by one particular program to influence two senior legislators as noted below:
In June 2002, Undersecretary Gene Hickok testified before the U. S. Senate Health, Education, Labor,
and Pensions (HELP) Committee. In response to Senator Susan M. Collins’ question “Is there anything in
the guidance that the department has given so far that would preclude funding for Reading Recovery programs?”
“No, there is not.…Our only goal is to make sure that whatever is being done at the State
and local levels results in students being able to read by grade 3.…The goal would be preventative
programs so the need for intervention and remediation is limited, but that does
not mean that Reading Recovery or any other successful program that has got the science
and can demonstrate it in an application cannot be part of this.”
Source: Implementation of Reading Programs and Strategies, Hearing before the Committee on Health,
Education, Labor, and Pensions, United States Senate, Government Printing Office, S. Hrg. 107-517,
p.10. Also available electronically at http://www.readingrecovery.org/pdfs/HickockTestimony.pdf.
In July 2002, U.S. Senators Susan M. Collins (R-ME) and Edward M. Kennedy (D-MA) sent a “Dear
Colleague” letter to all members of the U.S. Senate and House of Representatives about Reading Recovery
and Reading First. In part it stated
“Because it’s so effective, we want to share some background on it, because we think it’s
exactly the kind of program that the new law is intended to support.…Reading Recovery
works to prevent reading difficulties among students and helps children at risk of reading
failure catch up to their grade level.”
Source: July 3, 2002 “Dear Colleague” letter. Available electronically at
It is important to note that the information disseminated by Collins and Kennedy did not include any independent studies of the effectiveness of reading recovery in the reference list.
There are two things that I am convinced of that may be relevant to this discussion. First, there was no conspiracy to provide and advantage to certain programs and a disadvantage to others. I, like Dean, do not understand why SFA lost market share. I am out beating the bushes to understand why. Did the feds place any pressure on states or districts to not adopt or withdraw the program? No. In all of the thousands of emails between the Reading First office, the TACs, myself, and others, there are no more than a handful (if that) of emails mentioning SFA, and all in a productive context. Did the TACs place any pressure on states or districts to not adopt or withdraw SFA? There are substantial emails between the TACs and SFA staff and they clearly do not indicate any obstruction to the adoption of the program. The evidence I am acquiring in the form of interviews and emails indicate no. The Florida TAC alone was in constant contact with SFA staff answering questions, ensuring that their staff were talking with the appropriate people on the ground, working hard to diffuse "he said-she said" misinformation occurring at the state and district levels, and very importantly, being supportive of SFA as a program eligible for RF funding. In my interviews with teachers, Reading First directors, and Reading First coordinators, I have not found any one that indicates a dislike for SFA. Some will tell you that their districts decided to use other programs but that was primarily related to the implementation criteria specified by SFA. Some concerns have been articulated that SFA is most effective at the K-1 level and less so at grades 2 and above, but I have not been able to find the data which corroborates that. Slavin continues to allege that SFA received calls and letters from school districts and schools claiming that they were being pressured to drop or not adopt SFA. All there has to be is one that could step forward to indicate that this problem did exist. Then an examination of how widespread the problem was - if it existed - could be carried out. One question I have is whether the broad adoption of SFA prior to RF was in any way related to the availability of funds for comprehensive school reform funding streams, thus limiting the number of programs eligible for funding. If the answer is yes, the question is whether SFA would have been implemented as widely pre RF had the funds not been restricted to CSR models. I know that a substantial number of Title I schools adopted SFA, but I do not know whether CSR funds augmented funding or provided a totally separate funding stream. At any rate, I do think an objective answer to the SFA allegation of discrimination against their program will be forthcoming.
Second, folks are making the Reading First language and implementation issues far too complicated. The final language in the law is what it is. It clearly states that programs must be "based on" SBRR (which is defined in the law). "Based on" implies program specific evidence is not required. To be sure, it would have been great if the guidance by the Department was very specific in making these distinctions, but they did not, apparently thinking that the public would understand the issues. I am sure the Department understood the distinction because of the congressional pressure on them to allow "home grown" programs to be eligible for RF funding - none of which had ANY evidence of effectiveness and could not meet that criterion (at the time, neither could other programs that also put pressure on Congress - see above).
In the end, what the OIG found was a litany of dumb mistakes and what I argue were errors of omission, e.g., inflammatory language, lack of transparency on the review process, little attention given to ensuring that clear COI criteria were in place, lousy supervision of two TA consultants, and I am sure several others. Were people working for the program and at the TACs dishonest or out for themselves? I do not believe so and there is no evidence that any actual ethical or procedural standards were broached in an illegal way. There certainly are ugly perceptions of conflict of interest issues, but I am waiting for, and searching for evidence that any actions taken constituted an actual conflict of interest or an illegality. I believe DeRosa and Millot are both attorney's so I defer to their interpretation on this matter, but to date I have seen no evidence of any attempt to corrupt or to create any unfair advantage for particular programs. The explanations I have received in response to why the implementation of "core comprehensive programs" was recommended was because of the need to provide consistency in addressing the five reading components within a district/school and the fact that the majority of teachers had not had the opportunity to become knowledgeable about the five components and the methods (explicit, direct, and systematic) required to deliver the instruction. This explanation makes common sense to me from a practical standpoint and I see no reason to infer that emphasizing core programs was the gateway to providing an advantage to particular core programs. It was the case that certain publishers and vendors jumped on the anticipated RF requirements early on and either re-designed their programs to meet the requirements and/or employed new language in their marketing efforts. And speaking of marketing, the large publishers were on the school scene immediately after (if not before) passage of RF far out pacing SFA and some smaller vendors in getting the sales.
In the end, I believe all of the Reading First issues will be sorted out. It will be more difficult than sorting out the reasons for the limited (in both quality and scope) IES RFIS evaluation. The reasons for those problems are transparent.
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