All4Ed Comments on USED Discretionary Priorities

June 20, 2025

All4Ed appreciates the opportunity to comment on the U.S. Department of Education’s (Department) proposed supplemental priorities and definitions. While many of the comments below express concerns with the proposed priorities, there are areas where All4Ed agrees with the Department – namely in the areas of prioritizing literacy and providing students with options that will prepare them for postsecondary education through career-connected learning.

We offer the following comments and recommendations to strengthen these priorities in ways that are research-based and reflective of what our nation’s learners need and deserve. We appreciate your consideration of our input.

Proposed Priority 1: Promoting Evidence-Based Literacy

While All4Ed disagrees with the Department’s broader framing regarding the role and reach of federal education funding, we strongly agree that ensuring all students become proficient in reading and writing must be a national priority. We support the Department’s proposed priorities under sections (1)(a) and (1)(b), which emphasize evidence-based literacy instruction.

At the same time, we urge the Department to implement (1)(b) with care. While prioritizing programs supported by strong and moderate evidence is important, the research base remains limited for certain student populations, including multilingual learners and students with specific learning needs. We urge the Department to include an explicit focus on how evidence-based literacy practices are implemented in classrooms serving 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. Rigidly applying evidence thresholds may inadvertently exclude innovative or promising approaches that meet the needs of these learners. The Department should ensure that applicants serving specific populations are not disadvantaged simply because the existing research base has not kept pace with the diversity of students in our classrooms.

Proposed Priority 2: Expanding Choice

Recommendation: Strike policy that would allow Federal funds to support private schools.

Rationale:

All4Ed recognizes that public school choice, when implemented responsibly and equitably, can offer students meaningful opportunities to access educational environments that best meet their needs. However, the proposed priority extends far beyond public school choice by promoting the use of federal resources for private school enrollment, education savings accounts (ESAs), and other privatization mechanisms that redirect public funds to private schools that are not held to the same civil rights, accountability, and transparency standards as public schools, including requirements to serve the nation’s students with disabilities.

This direction is at odds with public sentiment. A recent bipartisan and nationally representative survey commissioned by All4Ed and conducted by Lake Research Partners and The Tarrance Group found that Americans overwhelmingly prefer strengthening public schools over subsidizing private education. When asked to choose, 68% of voters said they would rather increase federal funding for public schools, while only 24 % preferred increasing funding for private school vouchers. This preference spans political affiliation, geographic region, and racial background, underscoring broad-based support for public education as the nation’s shared civic commitment.

In addition to lacking public support, the expansion of voucher programs is not backed by evidence of improved student outcomes. A growing body of rigorous research has found that vouchers fail to deliver academic gains and, in many cases, actually harm student achievement. In Louisiana, for example, students participating in the state’s voucher program experienced steep declines in both math and reading performance when compared to their peers in public schools. Similarly, research on Indiana’s Choice Scholarship Program found that students who switched from public to private schools using vouchers performed significantly worse in both math and English language arts after the transition. In Ohio, evidence showed that voucher recipients underperformed in core subjects relative to matched peers who remained in public schools.

Moreover, even if voucher programs were effective at boosting student achievement, which the evidence suggests they are not, their impact would still be severely limited by geography. In many parts of the country, especially rural communities, private schools are not a viable option for most families. According to an analysis by the Urban Institute, a significant share of rural school-age children face limited proximity to private schools, with roughly one-third living at least ten miles from the nearest private school. These disparities underscore the deeply inequitable nature of voucher programs: they are most accessible to families who already have educational alternatives, and least accessible to those in geographically isolated or under-resourced areas who could benefit most from public investment.

The evidence shows that vouchers are both ineffective and inaccessible to many learners. Expanding them through a federal priority would represent not only a misalignment with research and public will, but a diversion of public dollars from the very schools that serve over 90% American students.

Recommendation: Combine elements of Proposed Priority 2 into a new priority focused on career-connected learning.

Recommended Language:

Priority 4: Expand Career-Connected Learning

Proposed Priority: Projects or proposals that are implemented through partnerships among state or local educational agencies, institutions of higher education (including community colleges), employers, and (optionally) other community partners, and offer students each of the following:  

• the opportunity to earn at least 12 postsecondary credits through dual or concurrent enrollment;
• the opportunity to earn an industry-recognized credentials that are—
  • developed and offered or endorsed by a nationally recognized industry association or by an organization that represents a sizable portion of the industry sector;
  • sought or accepted by multiple employers within an industry or sector as a recognized, preferred, or required credential for recruitment, hiring, retention, or advancement; and
  • lead to job entry, wage gain, or career advancement.
• access to high-quality work-based learning experiences, including pre-apprenticeships and apprenticeships that are paid, provide academic credit, or both; and
• comprehensive postsecondary and career counseling.

Rationale

All4Ed supports several of the components of Proposed Priority 2, including:

• (a)(i)(2) Career and technical education
• (g) dual or concurrent enrollment programs (as defined in 20 U.S.C. 7801(15)) or early college high schools (as defined in 20 U.S.C. 7801(17)) or other programs where secondary school students begin earning credit toward a postsecondary degree or industry-recognized credential prior to high school graduation
• (j)(iii) Pre-apprenticeships
• (j)(iv) Apprenticeships
• (j)(iv) Work-based learning

Individually, each of these components, when implemented effectively, has demonstrated substantial benefits for student achievement, postsecondary access, and long-term success.

Dual enrollment and early college programs have one of the strongest evidence bases among college- and career-readiness strategies. A review by the What Works Clearinghouse found that dual enrollment programs have positive effects on college enrollment, degree attainment, and high school academic achievement. Similarly, the American Institutes for Research found that Early College High School students were significantly more likely to enroll in college, persist beyond the first year, and complete a postsecondary degree. These outcomes were particularly pronounced for low-income students and students of color. Research also indicates that the benefits of dual enrollment are greatest when students earn at least 12 credits before high school graduation.

Work-based learning opportunities deepen students’ understanding of careers, connect academic content to real-world application, and build critical workplace competencies. A study by the Metropolitan Policy Program at Brookings and Child Trends found that participation in work-based learning during high school was associated with significantly higher job quality at age 29, including better pay, benefits, and job satisfaction. These experiences do more than expose students to careers—they foster lasting economic and personal outcomes.

Career and Technical Education (CTE) is also a proven strategy for improving outcomes. A 2022 meta-analysis conducted by the CTE Research Network found that CTE has statistically significant positive impacts on academic achievement, high school completion, employability skills, and college readiness.

Postsecondary and career counseling is an essential component of high-quality pathways. High school students and families benefit significantly from access to personalized, informed guidance as they navigate complex postsecondary and workforce options. Research shows that college and career advising interventions, particularly those that offer structured guidance and planning support, can meaningfully increase college enrollment and persistence. Young people benefit most from advising that helps them explore options, understand labor market returns, and connect their interests to long-term goals. Effective counseling serves as the connective tissue across pathway components, ensuring students not only participate in dual enrollment or work-based learning, but do so in a way that aligns with a coherent postsecondary plan.

To most effectively prepare learners for the future, school districts, institutions of higher education, and employers in states as diverse as Texas and California are coming together to integrate these opportunities and provide students with seamless pathways that produce measurable results. For example, students participating in the Rural Pathway Excellence Partnership in Texas are earning industry-based credentials at twice the rate of their peers. And students who entered high school with low levels of academic preparation and participate in Linked Learning in California were more likely than peers to graduate from high school and enroll in postsecondary education, according to a 7-year longitudinal evaluation by SRI International.

Taken together, these findings point to the urgent need to invest not just in individual initiatives like dual enrollment or work-based learning, but in integrated, evidence-based pathways that combine rigorous academics, work-based learning, high quality industry-recognized credentials, and personalized guidance. When these elements are aligned through cross-sector partnerships, students are better equipped to navigate postsecondary transitions, earn credentials with labor market value, and succeed in both college and career. Given that the majority of good jobs today and into the future require some form of postsecondary education and training, the both/and of college and career is essential for young people—and by college, we mean the entire array of postsecondary options, not just four-year college. Elevating this comprehensive, integrated approach to a standalone federal priority would reflect both the research and the will of the public. According to a bipartisan national poll commissioned by All4Ed, three-quarters of voters believe it is extremely or very important for K–12 schools to provide career-connected learning opportunities and to build partnerships with colleges and employers that help students succeed after high school.

Recommendation:  Strike or revise (a)(i)(5) to ensure a “patriotic education” includes an accurate representation of American history and promotes civic responsibility—not a nationalist ideology.

All4Ed recognizes and affirms the value of instilling a sense of pride and belonging in our country’s democratic ideals. We believe students should be taught that America has achieved extraordinary progress and built one of the most dynamic and free societies in the world. Civic education should inspire students to engage in the democratic process, understand their rights and responsibilities, and appreciate the principles that have allowed our country to flourish, including freedom of speech, equal protection under the law, and the separation of powers. We should prepare students to engage in civil discourse, evaluate diverse sources of information, understand the Constitution and Bill of Rights, and appreciate the role of dissent in American progress. These are the foundations of informed patriotism.

We recognize that patriotism, when grounded in truth, can unify and uplift. However, the term “patriotic education,” as referenced in proposed priority (a)(i)(5), is deeply ambiguous and risks politicizing curriculum in ways that can undermine both academic integrity and student engagement.

History should not be sanitized. All4Ed’s bipartisan poll found that 76% of voters, including 66% of Trump voters, believe it is extremely or very important to teach “students an honest, accurate, and age-appropriate education that includes both the good and the bad of our history so we can avoid making he same mistakes and create a better future.”  

Our nation’s progress has come through struggle and sacrifice. We are not where we should be, and our students deserve to learn the full story of our history and our present, so that they can effectively lead our future. This includes the remarkable resilience of our democratic institutions and the ongoing challenges we face. The genocide of Indigenous peoples, the enslavement of Black people, the decades of systemic segregation and Jim Crow laws, and present-day injustices including police brutality against BIPOC people, xenophobic, anti-immigrant and antisemitic attacks, and violence against LGBTQIA+ individuals are part of our history.

Teaching these truths is not anti-American. Instead, it affirms a deeper patriotism, one that believes America can and must continue to improve.

Proposed Priority 3: Returning Education to the States

Recommendation: Strike Proposed Priority 3 in its entirety. In particular, eliminate subsection (f), which improperly elevates the authority of executive state officials in determining grant eligibility.

All4Ed strongly disagrees with the underlying premise of Proposed Priority 3, that education must be “returned” to the states. Education is, and has always been, primarily a state and local responsibility. In fact, the federal role in education is intentionally limited by law, and current statute already protects states’ rights in numerous areas.

The Elementary and Secondary Education Act, reauthorized by the Every Student Succeeds Act in 2015, makes clear that the federal government cannot dictate such elements of education policy as state academic standards, curricula, assessments, or teacher evaluation systems. These prohibitions were explicitly written into law by a bipartisan Congress to prevent federal overreach.

Relevant statutory language includes:

• 20 U.S.C. § 6311(b)(1)(G)(ii): “Federal control -The Secretary shall not have the authority to mandate, direct, control, coerce, or exercise any direction or supervision over any of the challenging State academic standards adopted or implemented by a State.
• 20 U.S.C. § 6575: “Prohibition against Federal mandates, direction, or control – Nothing in this subchapter shall be construed to authorize an officer or employee of the Federal Government to mandate, direct, or control a State, local educational agency, or school’s specific instructional content, academic achievement standards and assessments, curriculum, or program of instruction.”
• 20 U.S.C. § 6611(e): “Prohibition –  Nothing in this section shall be construed to authorize the Secretary or any other officer or employee of the Federal Government to mandate, direct, or control any of the following:
  • The development, improvement, or implementation of elements of any teacher, principal, or other school leader evaluation system.
  • Any State or local educational agency’s definition of teacher, principal, or other school leader effectiveness.
  • Any teacher, principal, or other school leader professional standards, certification, or licensing.”

The Department does not need to return education to the states because the states already control the design and delivery of public education. The Department’s role is to provide federal resources to supplement state and local investments in education, protect students’ civil rights, invest in research and development to help states’ education systems improve and innovate, and ensure that federal funds are used in compliance with statutory requirements.

We are particularly concerned with subsection (f) of the proposed priority, which would encourage the Department to prioritize applications submitted by or through “entities identified, designated, or endorsed by a Governor or chief State education official for purposes of implementing the project or proposal.” This language is inappropriate and should be struck for several reasons:

1. Federal grant eligibility is determined by Congress, not by executive officials at the state level. Many Department programs specify eligible entities in statute, such as local educational agencies, institutions of higher education, or nonprofit organizations. Allowing governors or state education chiefs to unilaterally designate entities risks undermining Congressional intent and inviting inconsistency across states.
2. It introduces the potential for politicization and exclusion, especially in states where partisanship may influence which entities are deemed eligible or prioritized. This could disadvantage rural districts, community-based nonprofits, or partnerships not aligned with state leadership, even if they are statutorily eligible and well-qualified.
3. It may lead to administrative confusion and legal challenges, particularly if a governor designates an entity that does not meet statutory eligibility criteria, or if multiple entities are competing for priority status within the same state.

Proposed Definitions

Recommendation: Define the term “industry-recognized credential,” used under Proposed Priority 2 (g).

Recommended language:

Industry-recognized credential means a credential that is—

• Developed and offered by, or endorsed by, a nationally recognized industry association or organization representing a sizable portion of the industry sector, or a product vendor;
• Awarded in recognition of an individual’s attainment of measurable technical or occupational skills; and
• Sought or accepted by multiple employers within an industry or sector as a recognized, preferred, or required credential for recruitment, hiring, retention, or advancement.

Rationale

Evidence suggests that high school students can benefit from earning industry-recognized credentials. For example, a study of Florida’s Career and Professional Education (CAPE) Act found that students who earned an  industry-recognized credentials were more likely than their peers to enroll in community college and attain an associate degree. The study also found that these students were slightly less likely to enroll in a four-year university.

However, research also shows that the overwhelming majority of industry-recognized credentials currently earned by students offer limited value in the labor market. An analysis of credential data from 30 states conducted by ExcelinED and The Burning Glass Institute found that fewer than 20 percent of credentials earned by high school students aligned with those that were in demand by employers. Of the ten most frequently earned credentials, only three appeared among the top ten most in-demand. Many of the commonly earned credentials had little relevance to actual workforce needs.

Given these findings, it is essential that federal policy prioritize access to high-quality industry-recognized credentials that are both rigorous and aligned with real labor market demand. Incentivizing the acquisition of credentials simply for their presence on paper is insufficient. Instead, federal investments should support systems that help students earn credentials that employers value and open doors to good jobs.

Conclusion

Thank you for the opportunity to provide comments on the Department’s proposed supplemental priorities and definitions. As outlined above, All4Ed supports aspects of the proposal that are grounded in evidence and aligned with the needs of today’s learners, particularly those advancing literacy and career-connected learning. At the same time, we urge the Department to reconsider provisions that lack public support, conflict with statutory authority, or would undermine opportunity for students. We welcome further dialogue. Should you like any additional information as you refine these priorities, please contact Rebeca Shackleford, Director of Federal Government Relations (rshackleford@all4ed.org).