In Part I of our two-part response to the Department of Public Instruction’s Common Core Demystified, (CCD) we confronted DPI’s claims that Common Core Standards are state-led and DPI’s assertion that teachers will maintain control of the curriculum and how subjects are taught. In part II, we explore DPI’s claim that Common Core does not require specific data collection efforts and that the implementation of Common Core standards is “no different in cost than implementing North Carolina’s ongoing revisions to its longstanding standard course of study.”
CCD states that Common Core does not require student data collection. Specifically, the document states:
North Carolina schools do not ask students questions about religious affiliation. State and federal privacy laws apply to certain health and income student data collected by the public schools. But again the Common Core testing does not require data collection on students.
CCD goes out of its way to say Common Core standards do not require student data collection. That may be technically true. It is what is left unsaid, however, that is significant.
Common Core does not specifically require student data collection. However, CCD fails to say an ambitious program of student data collection already exists and while Common Core Standards may not require data collection, teachers and students are expected to benefit from such efforts. Student data collection was built partly with the help of federal stimulus funding and also Race-to- the-Top funds, a federal grant which advocated heavily for the adoption of Common Core Standards.
For example, all states that accepted stimulus funding agreed to build broad state longitudinal data systems (SLDS) as a condition of receipt of the funds. In addition, all states that applied for Race to the Top funding were given additional points based on their commitment to the development of student data collection. Improving data-driven decisions at all levels was a critical element of North Carolina’s Race to the Top application. So while Common Core may not specifically require additional data collection, the standards link to Race-to-the-Top and as such tie them to a large existing state and federal student data collection effort.
A 2007 Federal grant allowed North Carolina to develop a new DPI longitudinal data system called the Common Education Data Analysis and Reporting System (CEDARS). CEDARS established unique staff and student identifiers and linked and automated data sets that had previoiusly been housed in separate systems.
So do North Carolina schools collect data about students? Yes. CEDARS includes the 12 elements of the P-16 data system. However, North Carolina’s Race to the Top grant will allow the state to significantly enhance data quality, data accessibility and ensure that the data is being used to inform decisions. The primary tools for improving data-driven decisions are the NC Education Cloud and the State Instructional Improvement System (IIS). The cloud is expected to provide LEAs additional technology tools at reduced costs. In addition IIS will provide educators with a dashboard of tools to gauge instructional improvement.
What kind of data might be collected in the future? According to the National Education Data Model (NEDM) relevant data may include health care history, disciplinary record, family income range, family voting status, and religious affiliation. The data model is comprised of 400 data points in all. NEDM does not represent data elements that are collected but represents a map of data that states and schools may wish to collect.
Until recently federal student-privacy law protected personally identifiable information from disclosure to outside entities. However in January of 2012, the Department of Education eliminated the protections contained in the Federal Educational Rights and Privacy Act that required parental consent for the transmission of any student-level data. The new law allows the transmission of student data without parental consent to any authorized representative of government or state agencies — for the purpose of evaluating an education program.
Under this process, parents have no right to object and would probably never know that the data has been shared. Government agencies have free access to a wealth of personal data. This is a situation that raises many significant questions: How will data be safeguarded? Who will have access? Who owns the data?
In short, it may technically be true that Common Core does not require additional student data collection. Common Core standards, however, are inextricably tied to larger efforts (i.e. stimulus bill, Race to the Top) to build a student data system to track and analyze students and a new law that raises significant questions about student’s private information and how that information will be shared. It’s a distinction without much of a difference.
Lastly, CCD implies that implementing Common Core Standards will require no additional costs. Specifically, CCD states:
Implementing Common Core Standards is no different in cost than implementing North Carolina’s ongoing revisions to its longstanding Standard Course of Study. This is part of the work that North Carolina’s public school system does annually.
To say the least, this is a surprising statement. One of the biggest questions surrounding Common Core is cost. No one really knows how much the standards will cost to implement.
Where is all the money going? Money will be needed for textbooks and materials, professional development and technology and infrastructure to support the implementation of standards. Two of the highest costs will be professional development and technology, much of it for electronic assessments. Common Core will require teachers to be totally retrained. In addition, technology must be added to facilitate additional testing.
A 2012 study by AccountabilityWorks estimated that implementing Common Core nationally over the next seven years would cost approximately $16 billion to implement. The same study estimated that Common Core would cost North Carolina upwards of about $525 million to implement over the same time period — or about $75 million annually.
Another study done by the Fordham Institute, an organization that supports Common Core Standards, estimated that the cost of implementing the Standards in North Carolina would be about $300 million over the same period.
Whichever estimate one chooses — and both estimates are considered to be conservative — the costs are expected to be significant. Worse yet, there are currently no additional funds at the state or LEA level to provide for these expenses.
Against these concerns DPI continues to assert Common Core Standards are no different than the cost of implementing ongoing revisions to regular standards. Such statements are difficult to embrace. The scope of these changes dwarf annual changes in the Standard Course of Study.
Where’s the money coming from? North Carolina’s Race to the Top grant is providing some money for professional development and training for Common Core. That money runs out next year, however.
In a recent letter to constituents, State Superintendent June Atkinson said the Department of Public Instruction did a cost/benefit analysis of the impact of Common Core standards on the education budget. Atkinson even said :”We have experience in knowing the costs of implementation of the new standards.”
If that’s the case, DPI should provide the analyses. DPI should provide the estimate of how much it will cost the state and its 115 LEAs to implement Common Core.
In addition to figuring costs for professional development, books and instructional materials, technology and infrastructure, school districts must also address the costs of assessment.
The Department of Public Instruction has estimated the costs of Common Core assessment to be $24 – $27 per student. Current assessment costs are $10 per student. That’s a net increase in student testing charges of $14 to $17 dollars per student. You have to wonder if the costs of improvements to local infrastructure and upgrades were factored in those costs.
Assessment may also necessitate the upgrading of technology infrastructure. Common Core assessments in North Carolina will all be taken on computers. To run smoothly the state and LEAs will have to address concerns about bandwidth and technology infrastructure. These problems may be particularly acute in rural areas.
It’s hard to say how much all this will cost. It should be noted that Florida budgeted an additional $450 million and California budgeted an extra $1 billion to meet the new technological requirements for Common Core assesssments. That said, it’s difficult to conceive how implementation and assessment could be completed without significant additional investment.
Under the current arrangement states that agree to implement Common Core can add an additional 15 percent new content. Fifteen percent of what? That is a question that has yet to be answered. Still, states that choose to exercise that option will incur yet more costs, mostly for professional development and instructional materials.
In January 2012 the Center for Education Policy surveyed the states on the cost and burden of implementation. CEP reported that 30 of 32 states reported difficulty in garnering adequate implementation resources. A significant number of states reported major challenges regarding online assessment and providing professional development. Since Januauary the number of states reporting difficulties with test assessment and professional development for Common Core implementation has grown.
The evidence suggests the implementation of Common Core standards in North Carolina will be an expensive effort, requiring far more resources and funding than associated with normal revisions to Standard Course of Study. If DPI can document this to be untrue, now would be a good time to provide the evidence for believing so.
 The 12 elements of a P-16 education data system are: 1 Unique student identifier; 2. Student level enrollment, demographic and program participation information; 3. Student level exit, transfer, dropout or continuation to postsecondary institution information; 4. Ability to communicate with postsecondary data systems; 5.State data audit system assessing data quality, validity and reliability; 6. Yearly individual student tests records; 7. Information on students not tested by grade and by subject.; 8. Teacher identifier with ability to match teachers to students; 9. Student level transcript information to include courses completed and grades earned; 10. Student level college readiness test scores; 11. Data on student transitions to secondary to postsecondary including information on remedial coursework and 12. Additional data necessary to address preparation/alignment for student success in postsecondary education. (See Public Law: 110-69)
 See National Education Data Model, available at: http://nces.ed.gov/forum/datamodel/Information/howToBrowse.aspx