My comments to Docket ID 5000 k.docx

My comments to Docket ID: ED-2016-ICCD-0138  International Early Learning Study (IELS) 2018 Field Test Recruitment (Due to a 5000 character limit on comments, I reduced my comments down, the attached document is what I submitted)

This is important because if they get they field test done the main study will be slip through without a hitch done. in 2018, they will claim lack of opposing comments means the public is all for the main study.
In their support document for this study "the goal of the study is that the "results from the IELS will allow national policymakers to compare the skills and competencies of children from different nations as they are readying to enter primary school and to evaluate whether changes might be needed in the U.S.’s ECEC (Early Learning Early Care) system"
Notice they say not parents, not teachers, not principles, not school boards, not States but NATIONAL POLICY MAKERS. Theses policymakers will use this study no matter what it proves or disproves to push government controlled "schooling" onto younger and younger children.
The data from this study will give the statist the cradle to career data they need for the data driven model that puts compliant children on the college track and independent or religious children on the worker track. This was the design all along, Dave Coleman and Bill Gates the designer and the father of common core both worship at the altar of big data. School choice won't save us, because all educational paths will be require pass the accountability requirements.
There are only 5 comments, we need more to save them from putting another brick in the wall.

I answered the five questions suggested by the Department, all were reasons I opposed the field test that were based on why I opposed the main test scheduled for 2018

 (1) Is this collection necessary to the proper functions of the Department?

 A, The justification for the field test study is only as valid as the justification for the main study Since the main study is not adequately justified, the test study is not justified.

B, The abstract and the supporting documents explain how the International Early Learning Study (IELS) will be implemented and the supporting documents, but not why it is proper or necessary. The mere fact that the Organization for Economic Cooperation and Development (OECD) developed a new study does not justify the  taxpayer funds and other resources to participate in it.

C, In the Statement Part A (Supporting SSA) under A, JUSTIFICATION, A.1 Importance of Information, The IELS is said to be  justified because "concerns related to international economic competitiveness, the changing face of our workplace, " and " recent investments in early childhood education and care (ECEC) require a closer examination of what US children know as they enter school and how their knowledge compares to that of children in other nations with different ECEC experiences" 

The authors of this justification fail to make the connection on exactly how a random sample of one nations early childhood environment relates to a nations economic competitiveness. In fact, I have seen very little evidence that the 15 year old International Student Assessment (PISA), has contributed to our competiveness and that assessment was based on more reliable older students.

The statement goes on to say that simply knowing what other nations are doing with ECEC, will make us more competitive with other nations. Why then do other nations, knowing what we do in ECEC,  not make them more competitive with us.

D, The SAA claims that the goal of the study is that the "results from the IELS will allow national policymakers to compare the skills and competencies of children from different nations as they are readying to enter primary school and to evaluate whether changes might be needed in the U.S.’s ECEC system"

If that is the goal of this study, every American and I should oppose it completely. We do not live in a nation that has national policymakers. The education is left to the individual states. If the US Department of Education claims itself to be the National policymakers then they are violating the very law that created the Department. Moreover, it is the very height oh hubris for any policymakers to make judgments on the early childhood education and the care for every child in America. Policymakers forcing young children to be institionalized, so they can be subjected to non-validated experimental education schemes is immoral and probably illegal.

E, There are already numerous studies on early childhood education. A Compilation & Analysis of Early Childhood Research Regarding Effect, Fade Out, Academic & Emotional Harm « shows how a policy of promoting early childhood education may not be the universal answer.

 (2) will this information be processed and used in a timely manner;

In the  SSA under A, JUSTIFICATION, , It is claimed that " Data at critical points during the education career of U.S. students are used by policymakers in efforts to guide and examine the American education system, Consequently, generating comparative data about students in school and about adults in workplace and in community has become an important focus for NCES

Moreover, It is apparent that the IELS will merge student level data from this study into an existing NCES database for comparison later in the life of the student. The SSA states  "NCES’s Early Childhood Longitudinal Studies (ECLS) program (which) provides national data on children’s developmental status at birth and at various points thereafter.

This means although the student's data is kept and crossed referenced, there will be no benefit of this study until the student completes the PISA assessment when they are 15. This is not timely from the student's perspective.

B. This is an admission that the National Center for Education Statistics (NCES), has a established a national student level database. This violates  the " GENERAL PROVISIONS of the Education Sciences  Reform Act of 2002 SEC. 182. PROHIBITIONS. ... Nothing  in  this  title  may  be  construed  to  authorize  the  establishment  of  a  nationwide  database of individually identifiable information  on individuals involved in studies or other collections of data under this title."

This admission of unauthorized activity alone is enough to reject further data acquisitions by the NCES, which has already broken the trust that the American people have placed in them.

 (3) is the estimate of burden accurate;

No, the estimate of burden is not accurate because it only give the annual burden hours for the field test which is  useless, unless the main test is completed The burden hours need to include the main study.

No OMB estimate is provided for the field test study or for the main study. Until the OMB study is complete, published and commented upon, for both the trial and the maim study, and no funds should be spent on either.

(4) how might the Department enhance the quality, utility, and clarity of the information to be collected;

A, The Department cannot enhance the quality, utility, and clarity of the information to be collected because they are collecting the data from five year old children. Only someone who never had children would claim they could get policymaking data from a child who believes that Dora the explorer is as real as their kindergarten teacher. Only someone bent on collecting data for some nefarious reason would try to collect it from a child who one day wants  to be a fireman and the next day wants to be the fire truck (as a Transformer).

(5) how might the Department minimize the burden of this collection on the respondents, including through the use of information technology.

A. The supporting documents make it clear that the data gathered will be about the students family environments and their upbringing. The study's key phrases are "child's non-cognitive skills, the children's individual characteristics and their home backgrounds and experiences, contextual data about their home learning environment, competencies in executive function/self-regulation, and social emotional skills."

Parents and guardians should be aware of this before they consent to allow their child to participate in the study. Neither of the parental consent forms (implicit or explicit) mentions the intrusive nature of the study into their own home and family

There should be no implicit form and the explicit form should clearly define the nature of the questions. The consent forms needs to mention that all their child's answers and personal data will be kept in a student level longitudinal database that will hold their children's personal information forever.


B, In the SAA A.11 under Sensitive Questions it says "Several items in the background questionnaires may be considered sensitive by some of the respondents, such as parents’ education and occupation and family possessions.", but they are going to be asked anyway.

Therefore, each parent or guardian should be supplied with the entire pool of questions that his or her child could be asked. This test and the main test should not proceed until the questions are vetted, Moreover, the parent or Guardian should get a full transcript and a recording of their child's interrogation.

C. Since each child will be interrogated by a third party contractor, they probably do not know, safeguards that are more stringent must be in placed on the contractors. Currently the only requirement on the Collection Contractor" is that they sign a non-disclosure agreement and they undergo a background check.. That is inadequate for someone asking personal question to five year olds

 IELS is conducted by the National Center for Education Statistics (NCES)

§  Compilation & Analysis of Early Childhood Research Regarding Effect, Fade Out, Academic & Emotional Harm «
"", 2/12/2017
Compilation & Analysis of Early Childhood Research Regarding Effect, Fade Out, Academic & Emotional Harm Karen. R. Effrem, MD – President The following compilation of early childhood studies paints a very different picture than the rosy portrait of significant and long lasting benefit put forth by proponents, especially of the new unconstitutional program being put forth in the conference proposal for the reauthorization of the Elementary and Secondary Education Act. This list contains studies dating back to 1985 and is broken into four categories, with pertinent quotes from different studies being placed into multiple appropriate categories: 1) No or Small Effect – There are several studies that tout longer -term success compared to the usual fading out after the preschool year and even statistical significance over control groups of poor children. However, when more closely examined, their benefits are not practically significant, they may be explained by other factors like parent involvement, and these programs are too small, too specialized, and or too expensive to be brought to scale. 2) Fade Out – Many studies on this list, including the most recent one from Tennessee, show some improvement in the ephemeral concept of kindergarten readiness, but those benefits are gone by the time the program participant reaches kindergarten to third grade with problematic deterioration in academics an or behavior lasting longer than any perceived benefits. 3) Academic Harm – The quotes listed in this section depict evidence that children participating in these programs actually suffer academic deterioration in later grades, compared to their peers not participating in these programs. 4) Emotional Harm – The studies in this section show evidence that participation in these programs results in deterioration in the very behaviors that big government preschool proponents seek to impose on our youngest children. The emotional distress suffered by children in these programs is likely a prime reason for the epidemic of psychiatric diagnosis and drugging with extremely dangerous and ineffective psychotropic drugs in these children.

§  Education Longitudinal Study of 2002 (ELS:2002) - Overview: Purpose
"", 2/12/2017
The Education Longitudinal Study of 2002 (ELS:2002) is a longitudinal survey that is monitoring the transitions of a national sample of young people as they progress from tenth grade and twelfth grade to schooling beyond high school and to the world of work.

§  Longitudinal study - Wikipedia
"", 2/12/2017
A longitudinal study (or longitudinal survey, or panel study) is a quasi-experimental research design that involves repeated observations of the same variables (e.g., people) over long periods of time, often many decades (i.e., uses longitudinal data).

"", 2/12/2017
Basic elements that are encompassed in the ELS:2002 research instruments can be classified in three broad categories: background information, process information (information about dynamic influences on the student, in the home, school, and community environment, as he or she moves through secondary school and beyond into the world of postsecondary education and the adult workforce), and outcome information (the eventual outcomes of the transition process).

§  PISA 2015 Results (Volume I) - Books - OECD iLibrary
"", 2/12/2017
The OECD Programme for International Student Assessment (PISA) examines not just what students know in science, reading and mathematics, but what they can do w

§  PL107-279.pdf
"", 2/12/2017
GENERAL PROVISIONS of the Education Sciences Reform Act of 2002 SEC. 182. PROHIBITIONS. ... Nothing in this title may be construed to authorize the establishment of a nationwide database of individually identifiable information on individuals involved in studies or other collections of data under this title.

§ - Notice Document
"", 2/12/2017
The IELS will measure young children's knowledge, skills, and competencies in both cognitive and non-cognitive domains, including language and literacy, mathematics and numeracy, executive function/self-regulation, and social emotional skills.

§ - Supporting & Related Material Document
"", 2/12/2017
Supporting Statement Part A, Supporting Statement Part B


Safari Woman
Wow I just this very minute left there, having left that tab open I came to it again - I went there when I first saw it - but I don't remember - can people still enter their comments? (I added the link to the bottom of your blog - if you want to remove it just hit edit and delete the item where it s...
  • February 13, 2017
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Joseph Ryan
Yes comments are open until tomorrow at 11:59 PM. I had to cut my down to 5000 characters.
  • February 13, 2017
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Safari Woman
okay I lost the original link -- so where do you go to comment?
  • February 13, 2017
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