Comment from Kathryn Dewsbury-White
Kathryn Dewsbury-WhiteSupportAdvocacy
Summary: A not-for-profit education association advocating for assessment literacy supports the regulation's focus on rigorous peer review. They argue that competitive proposals for public funding should be evaluated by highly qualified experts to ensure policies are based on scientific evidence rather than political ideology.
(200.205) I serve a not-for-profit education association focusing on assessment literacy. Our mission is to advance quality practice and support schools in their use of quality, balanced assessment systems. Cognitive science, like other sciences, evolve. It is important to our republic that we provide an education for our children that is informed by scientific evidence. To that end, it is imperative that reviewers of competitive proposals are the very best trained and informed about the most current scientific evidence in the field when evaluating proposals for which public dollars are awarded. It is essential proposals are evaluated in a strict peer review process by highly qualified reviewers. Our organization can attest to the dollars wasted on poor public policy that is enacted by, sometimes well intended, but assessment illiterate decision-makers. It is estimated we spend 1.0-1.5 billion dollars nationally and annually on Interim Benchmark assessment products. At the same time, we have no conclusive research evidence that the use of these products contributes to student achievement. The ideology of a given federal administration should not be part of pre or post issuance review by federal agency heads who designative political appointees.