June 20, 2025
Zachary Rogers
U.S. Department of Education
400 Maryland Avenue SW, Room 7W213
Washington, DC 20202–6450
Re: Comments on the Secretary’s Supplemental Priorities and Definitions
(Docket ID ED-2025-OS-0020)
The National Parents Union (NPU) appreciates the opportunity to provide feedback on the Department of Education’s proposed priorities and definitions for discretionary grant programs. With more than 1,800 affiliated parent organizations in all 50 states, Washington, D.C., and Puerto Rico and membership of more than 1.7 million, the NPU is the united, independent voice of modern American families. We channel the power of parents, families and kinship providers into powerful policies that improve the lives of children, families and communities across the United States.
We are dedicated to improving student outcomes through a system that: embraces accountable public school choice; ensures high standards for academic instruction; promotes innovation and research and development; and, holds all educational providers responsible for results. We believe these goals are best achieved through a robust federal-state partnership, where the federal government plays a key role in upholding civil rights, funding research and innovation, and ensuring a baseline of quality and accountability for all students.
As an organization committed to public school choice, accountability, and evidence-based literacy instruction, the National Parents Union does offer qualified support for some elements of the proposed competitive grant priorities while expressing serious concerns about their broader implications for federal education leadership and equity. While we strongly endorse the focus on evidence-based literacy, with some qualifications, and certain school choice expansions, we cannot support the systematic dismantling of federal education oversight that Priority 3 represents. We also find the Department’s priorities as stated in this notice to be greatly at odds with other decisions it has made on key Department of Education programs.
We offer the following comments on the three proposed priorities, providing support where the proposals align with our mission of ensuring every child has access to a life of opportunity and critique where they diverge.
What We Support: Priority 1 represents the kind of federal leadership we need in education. The emphasis on evidence-based literacy instruction grounded in phonological awareness, phonics, vocabulary, fluency, and comprehension aligns perfectly with decades of reading science research. The priority’s focus on explicit, systematic instruction addresses the literacy crisis as highlighted, for example, by declining NAEP scores. This commitment to the body of evidence known as the “science of reading” would help ensure that federal dollars are invested in strategies proven to work, rather than ineffective methods that have failed generations of students, particularly the most vulnerable. We also appreciate and support the focus on educator preparation programs which would help ensure systemic change.
While we strongly support the priority’s focus, its definition of federal action – to “advance, increase, or expand” or “focus on” evidence-based literacy – needs additional emphasis in key areas and an alignment with other Department policies.
Where There Need to Be Improvements. To ensure implementation of policies aligned with the Department should:
Use Funding to Encourage Adoption and Reporting: The Department should use its authority to encourage states receiving federal literacy funds to adopt high-quality instructional materials aligned with the science of reading and to publicly report on implementation progress and student proficiency data, disaggregated by subgroup. Despite prohibitions in ESSA against federal mandates that control or dictate curricula, there are several legitimate ways the federal government could encourage and support high-quality instructional materials without violating the law:
The key distinction is between providing resources, incentives, and information versus mandating specific content or materials. The federal role becomes one of supporting informed local decision-making rather than directing those decisions.
More Clearly Articulate Focus on English Learners and Students With Disabilities. The priorities here fail to address the needs of English language learners and students with disabilities. When it comes to English Learners (ELs), the current evidence base has been developed primarily with monolingual students; therefore there is a need to better understand effective literacy-based practices for ELs. Specifically, literacy frameworks adopted by states in recent years—primarily under the banner of “the science of reading”—lack several critical components essential for comprehensive literacy development. These include: formal structure of language – study of morphology and syntax that supports deeper understanding of how language works; integrated instruction – connection of reading instruction with oral language development, writing, and academic content; and, bilingual literacy development – instruction that takes advantage of cross-linguistic connections and enhances metalinguistic awareness. Research is critically needed on how to integrate these additional components with the reading skill development identified in the current evidence base.
Reverse Decisions Made on Literacy Programs and Teacher Training. Unfortunately, your Administration has moved to eliminate or consolidate important programs in the areas of both literacy and teacher training. President Trump’s FY26 budget proposal, for example, calls for eliminating $194 million in Comprehensive Literacy State Development (CLSD) Grants. This program helps states develop literacy instruction programs for students from birth through high school, emphasizing low-income families, English learners, and students with disabilities. The FY26 budget also aims to de-fund and consolidate the Innovative Approaches to Literacy Grants program. These are two of 18 programs slated for consolidation into a smaller “K-12 Simplified Funding Program” which would result in an overall reduction of funding and a dilution if not outright obliteration of any focus on the science of reading. While the budget states that a minimum of 7.5% of SFP funds ($150 million) would be reserved for literacy programs, this would still be a 33% cut from existing funding levels for the two programs.
The Administration also has proposed the elimination of $890 million in funding for the Title III English Language Acquisition program under the Every Student Succeeds Act (ESSA) Title III provides grants to state education agencies to support English Learners in developing English language proficiency and achieving academically. Eliminating Title III funding, and for all intents and purposes essentially repealing the program, would greatly reduce the resources and guardrails available to schools to support English learners and severely impact their ability to learn English and succeed in school.
Similarly, your administration has canceled millions of dollars in grants for teacher development programs, including the Teacher Quality Partnership (TQP) and Supporting Effective Educator Development (SEED) programs. These grants aim to support teacher teacher preparation and support through various methods like scholarships, teacher residencies and internships, mentoring, and professional development.
It is hard to take seriously the Administration’s purported commitment to advancing the science of literacy when one juxtaposes the language in the proposed competitive grant priorities against your proposed decimation of some of the most important federal programs and guardrails that could serve that purpose.
What We Support: We agree that empowering families with educational options in the public school system can be a powerful catalyst for innovation and student achievement if those options are held accountable for results and adherence to civil rights. The parents that we represent greatly desire to have those options, with those key conditions. We thus strongly endorse the specific focus on expanding access to high-quality public school choice, including public charter schools, magnet schools (which your notice does not mention), innovation zones and innovation schools, public laboratory schools, course-based choice, dual enrollment, and open enrollment.
Polling that NPU conducted earlier this year revealed that the majority of parents support policymakers:
Expanding or replicating charter or innovation schools with a proven record of success in areas like STEM, CTE, and evidence-based literacy is a sound investment. We also support expanding access to dual enrollment, apprenticeships, and competency-based models that create flexible, career-aligned pathways for students. These options create healthy competition that can spur improvement across the entire public education system.
Significant Concerns. Our support for this priority is qualified by a significant concern: the lack of a corresponding emphasis on accountability and civil rights. The proposal broadly promotes a variety of choice mechanisms, including private school vouchers and Education Savings Accounts (ESAs) without acknowledging that these options frequently operate outside of state accountability and public transparency systems. For this reason, we strongly believe that public dollars should only be invested in public schools.
Accountability Must Follow the Dollar: Our organization’s guiding principle is that choice and accountability are inextricably linked. Federal funds should not be directed toward programs, public or private, that are not required to administer the same state assessments, report student achievement data, and adhere to the same health, safety, and civil rights laws as traditional public schools. Without these guardrails, there is no way for parents or taxpayers to verify that students are receiving a quality education, potentially exacerbating the very achievement gaps these priorities aim to close.
Focus on Public System Improvement: The priority’s background section frames education choice primarily as an escape from a failing system. While choice is a vital tool, a strong federal role should also focus on using choice as a lever to improve the traditional system. Federal grants should prioritize choice initiatives that are designed to foster collaboration, share best practices with district schools, and lift student achievement for all.
While we support public school choice, Priority 2’s broad embrace of private school vouchers through education savings accounts and its failure to advance a vision for systemic change raises serious accessibility and accountability concerns. Unlike charter schools and other public school choice models, private schools using public funds lack transparency, accountability measures, and civil rights protections that should accompany taxpayer investment.
Fundamental Concerns: Priority 3 represents, on the one hand, a dangerous abdication of federal responsibility that would undermine systemic change and civil rights protections. While we agree with the principle that states and local leaders possess critical insights into the needs of their communities and that “one-size-fits-all” federal mandates can be inefficient and counterproductive, the complete devolution of federal education authority would create a patchwork system that fails our most vulnerable students.
Conversely, we are concerned about Proposed Priorities (a) through (h) i.e. “prioritizing projects or proposals that will be carried out by one or more of the following…” Each competitive grant has stipulations about eligible entities and required or recommended participants in decisionmaking. This provision would seem to have the federal government tipping the scales in favor of certain entities over others and give state leaders unilateral authority in determining decisionmaking authority and the operation and management of federal grants. That is an incredible degree of overreach for a Department ostensibly in favor of a reduced federal role and limited bureaucratic interference.
Overall, however, we fundamentally disagree with the premise of this priority and its stated goal of facilitating the “transition toward closure” of the Department of Education. This position is astonishingly antithetical to achieving the goals outlined in the first two priorities and would abdicate the federal government’s essential responsibilities. The argument for a strong federal role is not an argument for bureaucracy, but for leadership, quality, fairness, and accountability.
In particular, we are deeply concerned about weakening the federal role in supporting fundamental accountability and transparency provisions in the Every Student Succeeds Act (ESSA) and the ways in which competitive grants could improve state assessment and accountability systems.
ESSA prohibits federal mandates in a number of areas including academic standards, teacher evaluation systems, and curricula and gives states ample autonomy to form accountability systems that reflect the needs of their local communities. Nonetheless, federal law creates basic guardrails to ensure that the data provides a reliable comparison of schools; that it is publicly reported for families, educators, and the general public; and that steps are taken to identify, assess, and support the schools that pervasively fail to provide students with a high-quality education. While state autonomy is imperative to create accountability systems tailored to local contexts, there is also a vital federal role in enforcing fundamental guardrails for transparency and school improvement.
A January 2024 GAO report on accountability under ESSA cited failures at every level of government. At the federal level, ED was falling short on monitoring and oversight. States were found to be out of compliance with key requirements of the law, including that school improvement plans be based on a needs assessment, identify resource inequities, and include evidence-based interventions. Only 42 percent of school improvement plans addressed all three of those ESSA-mandated elements, and there were few signs that many of those were doing them particularly well.
District and school leaders particularly seemed to be struggling to align school policies and practices with evidence of success. As stated in the GAO report:
“All seven of the school officials we spoke with were unaware of [ED’s] [What Works] Clearinghouse. . . . [M]any school officials need help understanding why a new approach is needed as their default is to continue with the status quo. . . . [T]wo district officials and one school official stated that they turned to educational product vendors or paid consultants for assistance in selecting interventions.”
It’s clear that states are struggling to fulfill their most basic responsibilities of assessing and supporting their lowest-performing schools. There is an obvious need for the federal government to enforce these basic requirements and to provide additional support, including through priorities in competitive grant programs, when states lack the capacity or will to drive meaningful school improvement. We ask that going forward, the Department withhold from granting flexibility, including through waivers, of these key guardrails.
The Department of Education serves three irreplaceable functions:
Dismantling the Department of Education would cripple the nation’s ability to ensure educational equity, hold systems accountable for results, and drive evidence-based reform. The goals of promoting literacy and expanding accountable choice are best served by a strong federal-state partnership, not by the unilateral withdrawal of the federal partner.
These priorities reflect both promising directions and dangerous retreats from federal education leadership. We urge the Department to strengthen Priority 1’s evidence-based approach, refine Priority 2’s choice provisions to focus on accountable public options, and completely reconsider Priority 3’s dismantling of federal oversight.
Education is too important to leave to chance, and educational excellence, for all students, is too critical to abandon. America needs federal education leadership that combines rigorous standards with flexible implementation, not the wholesale retreat from responsibility that these priorities collectively represent.
The path forward requires maintaining federal leadership while empowering states and localities to innovate within accountable frameworks. Only through such balanced federalism can we ensure that every student, regardless of zip code, receives the high-quality education they deserve.