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Replacing Common Core with Proven Standards of Excellence

October 1, 2014

Revised Statement: Replacing Common Core: Choices and TradoffsIntroduction The set of standards and assessments for K-12 education called the Common Core State Standards (CCSS) has already fallen short of expectations.


Revised Statement:

Replacing Common Core: Choices and Tradoffs


The set of standards and assessments for K-12 education called the Common Core State Standards (CCSS) has already fallen short of expectations. Unwise compromises by Common Core authors and developers led to academically weak standards that would have been ignored by many states had President Barack Obama’s administration not provided overwhelming fiscal incentives to adopt the standards sight unseen.

As policymakers around the country become aware of the flaws in Common Core, an increasing number of legislators are now or soon will be rejecting Common Core for better alternatives, such as the standards and tests offered by the organization American College Testing (ACT).

This paper begins by summarizing some of the many failings of Common Core as a set of academic standards, including its in-completeness, low standards, lack of a research basis, and threats to privacy. The story of how Common Core was “captured” by Washington, DC is recounted, as well as the laws that were broken along the way. Finally, use of ACT standards is proposed as an alternative to Common Core.

Why Common Core?

The old adage about the road to Hell being paved with good intentions may apply here. Americans want strong academic standards for their schools. Many want those standards to be national, but with a caveat: They generally do not want the national government dictating terms.

The Common Core State Standards were conceived and advanced by organizations outside of the national government, namely the National Governors Association and the Council of Chief State School Officers. Implicit in the CCSS title, the adjective “State” suggests these standards could be adopted by states on a voluntary basis.

Along came the U.S. Department of Education, which used its funding under the 2009 American Recovery and Reinvestment Act to provide incentives for states to adopt those standards or else lose some degree of access to federal funds for education. Some Common Core proponents saw the lack of national curricular standards as shameful. Education Secretary Arne Duncan, for example, used the term “insidious” to describe the freedom states have to set their own standards.1 Many others took a different view, seeing federal imposition of these standards as illegal. A middle-ground view sees national standards as potentially good if they are truly voluntary.

There exists at least one alternative to CCSS that states can implement now. That alternative not only has higher academic standards than CCSS but also is relatively immune to national government interference. That alternative is the ACT organization’s standards and batteries of tests, which include the ACT College Test and the ACT Aspire tests, which together cover grades 3-12.

Asora Education Enterprises has compared current state testing proficiency results to those of the Nation’s Report Card, more formally known as the National Assessment of Educational Progress (NAEP).2 We found a wide range of academic standards and testing practices exists across the United States.

In the course of studying state standards, we discovered the tests of the ACT organization track closely those of the NAEP. There is significant agreement between them regarding the percentage of students likely to succeed in college. Many educators label the NAEP tests as the gold standard of K-12 assessments. The ACT standards and tests are also held in very high regard by professionals in the field. We might even dub them the “platinum standard” of this field.

Americans want seemingly contradictory policies: They want national education standards, but they don’t want them imposed by the national government. Federal law agrees with that sentiment.

For example, it limits the role played by NAEP through prohibitions of local testing and reporting. Unfortunately, the U.S. Department of Education appears to have ignored or worked around federal law when it imposed heavy-handed incentives on states to encourage adoption of Common Core proposals.

We think ACT standards and its testing programs can provide Americans with much of what they desire for education standards. ACT is a non-profit, private organization relatively immune to federal pressure, yet it has such well-regarded content standards and testing programs that it can help satisfy the desire to have a set of standards that are simultaneously national, reputable, and voluntary.

K-12 standards and tests developed by other non-governmental organizations can play similar roles. For example, the non-profit College Board, the for-profit Pearson Education, and others are expanding their activities in these areas.

Common Core Is Incomplete

In addition to the dubious process by which they were implemented, the Common Core standards have serious academic deficiencies. In a number of content areas, standards are much less specific than one would expect.

In the subjects of mathematics and reading, the two areas where Common Core standards have been published, Common Core has reduced the amount of content students are required to master. This suggests students will have more time to study remaining topics, or perhaps they will be taught additional content that has not yet been determined or released.

In mathematics, mastery of several calculation skills is delayed by one or two grade levels when compared with the standards recommended by the National Mathematics Advisory Panel (NMAP).3 Common Core specifies only three years of high school mathematics, compared to the traditional four years of instruction recommended by NMAP.

In reading, which also includes content from English language arts (ELA), the reading lists of classical literature are markedly reduced from traditional curricula. Overall, Common Core identifies relatively few recommended works of fictional literature, well below CCSS’s 50 percent allocation for this type. In place of classic literature is the proposal that students read more non-fiction, but those reading lists are also remarkably short. One wonders how the authors of CCSS assessment systems will be able to test students against standards without specificity. Does Common Core’s proposal portend the English classroom becoming more like a study hall, or does it suggest something else? Whatever the answer, this is an incomplete specification.

The research base for Common Core is similarly incomplete. The Common Core State Standards adapted the ACT organization’s descriptor, “College and Career Readiness Standards,” and apparently did so when ACT was being considered as the assessment provider for the CCSS. Although it’s not certain, it appears CCSS and its two associated testing consortia are developing tests with other vendors. It seems apparent, however, that very few longitudinal studies were conducted: There simply has not been sufficient time to accomplish that feat.

Numerous education experts have criticized this weakness of Common Core and its related assessment programs. Christopher Tienken, professor at Seton Hall University, documented the lack of credible research supporting Common Core.4 Regarding how Com-mon Core went off-course, Jamie Gass and James Stergios of the Pioneer Institute provided a good review in The Weekly Standard’s blog.5 It is clear proponents and implementers of Common Core are supporters of “experiential education” and its motto, “21st century skills.” Gass and Stergios report that after Connecticut and West Vir-ginia enthusiastically embraced these experiential theories, most of their NAEP scores fell.

Common Core Is Inferior

Students should not be put at risk by forcing them to participate in unproven schemes and inferior programs. Here is a list of some of the more bewildering aspects of Common Core:

  • Common Core offers no standard for cursive writing, effectively making it optional. Printing and typing are still taught … at least for the next few years.
  • Common Core promotes marginal teaching methods such as experiential education, which at best should be an adjunct to instruction. The standards do not mention direct instruction, which has been validated by many studies.
  • One of the more bizarre recommendations in Common Core reading standards is advocacy of “cold reading.”6 Under this practice, teachers do not provide background information about historical texts prior to having students read them. The student reads it “cold,” as the standards recommend as a strategy for studying the Gettysburg Address. Obviously additional information would help the student become more proficient in the subject, yet Common Core disallows it. The standards cite no research supporting such a practice.
  • Common Core claims it includes teaching of “critical thinking,” “higher order thinking skills,” and “21st century skills,” but it never bothers to define what those are. That it fails to do so suggests its authors do not know what these empty phrases mean.

Scholars Sandra Stotsky and Ze’ev Wurman, who have challenged the quality of Common Core, have proposed a kind of “truth in advertising” requirement that states that adopted Common Core remove the “college and career readiness” label everywhere it ap-pears in their descriptions of the standards.7

Weaknesses of Common Core Math Standards

The stated goals of Common Core standards include preparation of high school graduates with prerequisite knowledge that enables enrollment in a calculus course when they enter college.8 Benchmark standards used for this are recommendations from the National Mathematics Advisory Panel (NMAP).9 NMAP was established in 2006 and is charged with proposing improvements to K-12 mathematics standards to prepare high school graduates for “higher levels of mathematics.” Common Core standards are insufficient to reach these goals. Here are some of the gaps and failures responsible for this inadequacy:

  • Common Core postpones proficiency in whole-number division from NMAP’s benchmark grade 5 to grade 6.
  • Common Core postpones teaching relationships between fractions and decimals from NMAP’s grade 5 to grade 7.
  • Common Core postpones the grade level for a first algebra course from NMAP’s grade 8 to grade 9.
  • Common Core reduces the number of years of high school math instruction from NMAP’s four to three - a clear indication students under Common Core will be left behind.
  • Euclidean approach recommended by NMAP with an experimental method that has had little success. Or, as some say, the pedagogy is “experiential.”

In other words, Common Core proposes 11 easy years of instruction in mathematics that will fall short of the National Mathematics Advisory Panel’s recommended 12 years of intensive work.

Weakening English Language Arts Standards

A sensible approach to improving student skills in English language arts (ELA) is to have students read more, write more, and gain higher proficiency in grammar, spelling, and rhetoric. Common Core standards, by contrast, embark on a path of unproven tradeoffs in which much less effort would be spent in some areas than in others.

A key flaw in Common Core’s ELA standards is its shift of reading emphasis from works of fiction, typically the classics of English literature, to non-fiction works.

It appears Common Core reading standards require approximately half of a student’s reading in English classes be non-fiction and the other half fiction. This change from the traditional emphasis on fiction seems to be primarily based on a misunderstanding of NAEP reading tests, which the designers of Common Core profess to admire. The NAEP tests focus about 70 percent of the questions on non-fiction and the other 30 percent on fictional literature.

Developers of Common Core standards for reading make the mistake of assuming tests, such as NAEP, measure reading skills primarily developed in English classes. In reality, a student builds reading skills in many other subject areas, including mathematics, science, and history. Those other subject areas focus almost entirely on non-fiction. When considering the many subjects taught in school, the emphasis in English classes should largely be on fictional literature. Otherwise, the overall percentage of focus on fictional literature across the school will fail to meet the 30 percent recommended by NAEP tests.

If schools attempt to align reading goals so that roughly half of all reading assignments focus on fiction and the other half on non-fiction, teachers will have to be retrained to become adequate instructors in non-fiction areas.10 It is unclear what will be taught, but there certainly will be a temptation to present politically or ideo-logically biased information.

If there is any conclusion to draw from what we’ve learned about Common Core’s reading standards, it is that its authors have not based their proposals on sound research. Until there is reliable research suggesting a better approach, the best near-term idea is to stay with traditional standards while improving instruction.

Privacy Concerns

Scholars and the general public are rightly concerned that states adopting CCSS and their associated assessment systems will expose students to invasions of privacy. Common Core is a gateway to the collection of enormous amounts of data about students, their home lives, and even their parents, much of which traditionally has been off-limits to government agencies.

Under CCSS, data sent to the assessment consortia are made available to the federal government and various private entities, but ironically, not to parents.11 Much of CCSS focuses on student attitudes and dispositions, not academic knowledge, and information of this sort is more sensitive and controversial, and therefore deemed confidential, than simply “test scores.”

Being able to track a child’s academic performance from preschool to college may provide educators and researchers valuable information to improve instruction or evaluate the effectiveness of different education “inputs” such as teacher quality, curriculum, and use of distance learning technologies. But such use of “big data” also invites abuse. Retailers are eager to use the information to market goods and services to parents, employers to steer curriculum to produce employees who are pre-trained to fill available jobs, and advocacy groups to achieve political or ideological agendas. Emmett McGroarty, Joy Pullmann, and Jane Robbins wrote in 2014,

As technology advances, initiatives from government, private entities, and public-private partnerships have sprung up to elimi-nate the technical obstacles to increased data-sharing. Although the ambitious inBloom project has faded in the face of withering parental criticism, other projects abound: the Workforce Data Quality Initiative, Unified Data Standards, MyData, Connect-Ed, student-unit records, and private companies’ education apps “donated” to schools in exchange for access to student informa-tion. This treasure trove of student data is a hugely tempting target for hackers, who have already begun their assaults.12

The same authors warn that “none of the privacy protections currently in place promises reliable protection of student data.”13

They call for laws that “grant parents control over the collection and disclosure of their children’s data. And parents must educate them-selves about what is really happening in the schools, so that they can know what types of data are being collected and what is done with it. Parents must be empowered to draw the line.”14

How Common Core Was Captured by Washington

Despite numerous claims that Common Core is state-based, the standards quickly transitioned from a voluntary program into one imposed by the U.S. Department of Education. This national gov-ernmental interference arose from the implementation of the fol-lowing programs developed by the Department of Education using funds from the American Recovery and Reinvestment Act (ARRA), the so-called “stimulus” legislation:

  • the Race to the Top Fund
  • the Race to the Top Assessment Program
  • the Conditional NCLB Waiver Program

Each of these programs provided funds and/or favors to states in exchange for their adherence to Department of Education priorities. The most prominent of these de facto mandates was participation in Common Core or some close facsimile of it. Among the criteria for a state to receive a grant from the Race to the Top Fund was the phrase, “adopting internationally benchmarked standards and assessments that prepare students for success in college and the workplace.”15

The Department of Education restricted grant applicants to those that promised to adhere to content standards substantially identical across all states; states would be allowed to add no more than 15 percent to those common standards.16 There was and is only one available system of standards that has those two characteristics: Common Core.

Another bucket of money, $362 million in funding, was available under the Race to the Top Assessment Program. A state could access grants under this program only if it belonged to one of a few “consortia of states” developing assessments against standards that, by the artful phraseology used to describe them, could only be Common Core State Standards17 or a very close, almost cloned, facsimile.

The Obama administration put another offer on the table to lure states into Common Core: Any states that did not find the requirements of No Child Left Behind beneficial could receive a waiver from many NCLB provisions after satisfying several conditions, one of which was that the state adopt “college and career ready” standards common to several states.

These three programs put money on the table and offered relief to states willing to play the Common Core game. Were these innocent incentives encouraging states to have exemplary educational policies, or were they coercive measures designed to induce adherence to Common Core? It is difficult to refute the latter contention.

What Laws Were Broken?

The Department of Education attempted to establish indirect control over curricula of states through Common Core, giving it some ability to deny its true role. The department used its Race to the Top grants and the issuance of waivers from requirements of No Child Left Be-hind (NCLB) to pressure states into adopting Common Core. Com-mon Core proponents argue those pressures were perfectly legal in-centives, but opponents are correct to label them coercive.

Legal analysts identify two critical areas of legal concern over Common Core:

  • Common Core violates the 10th Amendment to the Constitution, which reserves certain powers to the “States … or to the people.”
  • Common Core violates three federal statutes prohibiting federal control over school curricula.

With respect to education, the Constitution authorizes only local or state authority. Federal activities in education have mainly been in the form of grants to public school systems and for research. The NAEP, for example, represents an activity that might be justified by the Weights and Measures Clause or possibly the Commerce Clause, but many would argue otherwise. The establishment of the Department of Education is more difficult to justify by the language of the Constitution, but so far the Supreme Court has allowed it to exist.

Three federal statutes prohibit federal control of curricula and restate what the Constitution already implies:

  • The General Education Provisions Act prohibits federal government control of curricula used by “any educational institution.”18
  • The Department of Education Organization Act denies any officer of the Department of Education authority for the “exercise and direction, supervision, or control over the curriculum” of “any educational institution, school,” unless a specific federal law authorizes it.19
  • The Elementary and Secondary Education Act of 1965 limits federal control over curriculum in schools.20

The incentive programs discussed in the preceding section do not literally control curriculum, but they erect barriers and incentives of such magnitude that non-compliant states will suffer financially and programmatically. The “compliance” being sought here is participation in Common Core. To participate, a state is required to pledge adherence in a number of areas, including curricula.

Some states, such as Texas, reviewed the legal issues surrounding Common Core and decided to decline the inducements. As Gov. Rick Perry (TX-R) wrote in his letter to U.S. Secretary of Education Arne Duncan declining the offers:

In the interest of preserving our state sovereignty over mat-ters concerning education and shielding local schools from unwarranted federal intrusion into local district decision-making, Texas will not be submitting an application.21

The Texans did their homework. Most other states did not - or if they did, they evidently allowed financial considerations to cloud their judgment.

ACT to the Rescue

Many of the promises of Common Core State Standards, including that they would be voluntary, have been broken. Among those using Common Core, many are unaware their efforts are having the effect of subverting K-12 education standards. Many naively believe they are replacing poor standards with better ones. A closer look shows degradation masquerading as reform.

Those of us who have studied the academic proficiency of K-12 public school students have not observed any pervasive dysfunction in the traditional curricula. Instead, we find students have not learned the content intended for them. Our solution involves better testing, better instruction, and better student incentives, not wholesale changes to curricula.

Many educators and other stakeholders of American K-12 education recognize as substantial and rigorous the standards used in the Nation’s Report Card. States might consider them as they develop their own content standards, but NAEP’s limited use and the terms of legislation establishing it prevent it from being used locally. For it to do otherwise might be interpreted as an unwanted national curriculum.

There is, however, a well-respected, non-governmental alternative set of standards and tests that does not require a federally imposed curriculum or testing. We propose that states, local educators, private schools, homeschools, tutors, and anyone interested in academic performance levels of students in K-12 education use ACT standards and tests.

Asora Education Enterprises recently compared some ACT tests with those of NAEP. At the 8th, 10th, and 12th grade levels, Asora found the primary NAEP figure of merit, the proficiency percentage, is numerically close to ACT’s figure of merit, the percent on track to be college- and career-ready. A recent Asora report elaborates on this analysis.22

Several states already are using ACT tests as a primary assessment mechanism and would find it rather easy to abandon any commit-ment to Common Core. ACT content standards are more traditional, research-based, and supportive of college readiness than Common Core, which has not been validated by significant peer-reviewed re-search, as noted earlier.

Use of tests and content standards of ACT would lead to a number of benefits to students, parents, educators, and taxpayers. ACT tests are research-based and measure the likelihood a high school graduate will succeed in college. In the nomenclature of ACT tests, a student is “On Track” to be “college ready” if that student performs above specified cut scores on tests. For each participating school, ACT or states usually report how many students in each tested group or subgroup perform at a college-ready level or are on track. In many ACT subject areas, particularly mathematics and reading, criteria for being On Track are similar to NAEP’s criteria for being Proficient. As noted earlier, if NAEP can call itself the “gold standard” in K-12 testing, ACT testing systems may deserve the label “platinum standard.”

Citizens worried about national government overreach should not be as concerned about local public schools using ACT testing programs, because they are not controlled by Washington and are relatively immune to national government interference. Concern over overt federal control of education has placed limits on NAEPitself; NAEP is prohibited from local testing and is limited to using sampling methods to generate its own published statewide results. For those concerned about respecting the 10th Amendment of the Constitution, ACT is the right test.Ironically, it was well-meaning policymakers and governors at the state level who first proposed and participated in development of Common Core. The idea of having national standards in K-12 edu-cation, though controversial in some circles, could be implemented without federal control and could be optional for states. Some states might want to augment standards, and others might want to removeprovisions they find objectionable. ACT was a model for the developers of Common Core, but those in control of Common Coredecided to institute limitations antithetical to ACT’s standards. Math and reading were both dumbed down, and a ridiculous restriction on states augmenting Common Core standards limited such improvements by requiring Common Core constitute at least 85 percent of such a state’s expanded requirements.

ACT is rapidly expanding its K-12 testing programs to include all grade levels from 3rd to 12th. States that want to get away from the troubles of Common Core will easily be able to do so by using ACT.


In sum, Common Core State Standards, which some educators hoped would replace “dysfunctional” state testing systems with something more rigorous, are not only incomplete, they are eroding the nation’s K-12 content standards. Common Core is a failed system, both le-gally and academically.

Although well-intentioned at the time of its conception, Common Core has been derailed by unwise and possibly illegal tactics. The standards are unwise in the sense that reading and mathematics standards are significantly weaker than what many states had used previously. They are also illegal, because the U.S. Department of Education apparently has violated several federal laws by imposing curriculum nationally.

Fortunately, there is a suitable replacement already in operation: ACT has necessary standards and tests in place. It has experience and has validated its programs through careful research. Parents should talk to their children’s teachers, school board members, and state elected officials about their concerns regarding Common Core standards and ask them to consider replacing them with ACT tests and standards.

About the Author

David V. Anderson is a retired research physicist and Fellow of the American Physical Society. Previously, Anderson taught high school mathematics and physics. Since taking early retirement from the Lawrence Livermore National Laboratory, he has worked in a number of policy areas, mostly related to K-12 education.

His small education consulting firm, Asora Education Enterprises (, offers services in a number of areas, including:

  • School design. Asora has developed a business plan to establish networks of “bricks and mortar” schools that use blended instruction and franchising or licensing arrangements.
  • Assessment analysis. Asora has an applied mathematical mapping process that allows local student proficiency levels to be estimated in a way similar to reports issued by NAEP or ACT. The mapping process uses as input state-reported proficiency levels that are typically exaggerated, then makes estimates of performance against NAEP and ACT.
  • Research activities. Asora also engages in related research. It is available to work under contract and operates a speakers bureau that can make presentations in its areas of expertise.

David Anderson can be reached by email at or at 508/409-8597. His offices are in Attleboro, Massachusetts.


1 Arne Duncan, Beyond the Bubble Tests: The Next Generation of Assessments, Secretary Arne Duncan’s Remarks to State Leaders at Achieve’s American Diploma Project Leadership Team Meeting, September 2, 2010,

2 David V. Anderson, It Takes More Than a Village, Guidebook and Resources for Parents in Maryland, Virginia and Washington DC. Attleboro, MA: Asora Education Enterprises. Guidebooks for Bristol County, MA, Orange County CA, and Shelby County, TN, are also available at

3 Foundations for Success: The Final Report of the National Mathematics Advisory Panel, U.S. Department of Education, Washington, DC, 2008,

4 Christopher H. Tienken, “The Common Core State Standards: The Emperor Is Still Looking For His Clothes,” Kappa Delta Pi Record 48 (2012): 152, http:// pdf.

5 Jamie Gass and Jim Stergios, “The Beginning of Common Core’s Trouble,” The Weekly Standard, May 29, 2013,

6 Valerie Strauss, “Common Core’s odd approach to teaching Gettysburg Address,” Washington Post Blogs, November 19, 2013, http://www.

7 Sandra Stotsky and Ze’ev Wurman, “Common Core’s Standards Still Don’t Make the Grade: Why Massachusetts and California Must Regain Control Over Their Academic Destinies,” Pioneer Institute White Paper #65, July 2010, p. 27,

8 R. James Milgram and Sandra Stotsky, “Lowering the Bar: How Common Core Math Fails to Prepare High School Students for STEM,” Pioneer Institute White Paper #103, September 2013, p. 7,

9 Foundations for Success, supra note 3.

10 Mark Bauerlein and Sandra Stotsky, “How Common Core’s ELA Standards Place College Readiness at Risk,” Pioneer Institute White Paper #89, September 2012, p. 2,

11 Karen Gray, “Nevada Officials say Seeing Student’s Records Will Cost Dad $10,000,” School Reform News, September 2014, p. 10.

12 Emmett McGroarty, Joy Pullmann, and Jane Robbins, “Cogs in the Machine: Big Data, Common Core, and National Testing,” Pioneer Institute White Paper #114, May 2014,

13 Ibid., p. 1.

14 Ibid., p. 2.

15 Robert S. Eitel and Kent D. Talbert, “The Road to a National Curriculum: The Legal Aspects of the Common Core Standards, Race to the Top, and Conditional Waivers,” Engage 13 (1) (March 2012),

16 Robert Scott, “A Republic of Republics: How Common Core Undermines State and Local Autonomy over K-12 Education,” Pioneer Institute White Paper #102, September 2013, p. 8,

17 Robert S. Eitel and Kent D. Talberg, supra note 15, p. 11.

18 20 U.S.C. § 1232a (Title 20 of the United States Code, Section 1232a).

19 20 U.S.C. § 3403b.

20 20 U.S.C. § 7907a.

21 Robert Scott, supra note 16, p. 9. Mr. Scott served as Texas Commissioner of Education, 2007–2012.

22 David V. Anderson, Mapping NAEP Proficiencies to ACT’s POT, Asora Education Enterprises, June 9, 2014, page40/page40.html.

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