Letter: Comments on Arkansas 2022 Approved Social Studies Standards

Editor's Note: The National Association of Scholars (NAS) and the Civics Alliance work to ensure that every state has academic standards that promote first-rate education and protect school children from political indoctrination. We promote reform of content standards in every state, along the lines modeled by the Civics Alliance’s American Birthright: The Civics Alliance’s Model K-12 Social Studies Standards, and we have been asked by Arkansas citizens to comment on the Division of Elementary & Secondary Education’s 2022 Approved Social Studies Standards. We conclude that 1) the Department’s standards adoption process does not meet acceptable standards of openness and public accountability; 2) the basic structure of the Standards, particularly the requirement that it conform to the College, Career, and Civic Life (C3) Framework for Social Studies State Standards, requires Arkansas to provide inferior and politicized social studies instruction; and 3) the Standards include substantial amount of solid factual content, but teachers will not be able to make proper use of this content until the Department reforms the Standards’ larger structure.

We have sent the following letter to the Arkansas Secretary of Education, Jacob Oliva.

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Jacob Oliva, Commissioner of Education
Cabinet Secretary, Arkansas Department of Education
Division of Elementary and Secondary Education
Four Capitol Mall, Room 304-A
Little Rock, AR 72201

February 8, 2022

Dear Secretary Oliva,

The National Association of Scholars (NAS) and the Civics Alliance are delighted at how Governor Sanders and her administration have dedicated themselves at once to education reform and improper radicalization. The Governor’s complementary Executive Orders, Executive Order to Prohibit Indoctrination and Critical Race Theory in Schools¹ and Executive Order to Respect the Latino Community by Eliminating Culturally Insensitive Words from Official Use in Government,² promise ambitious and successful work to improve Arkansas’ public schools, and Arkansas as a whole.

NAS and the Civics Alliance work to ensure that every state has academic standards that promote first-rate education and protect school children from political indoctrination. We promote reform of content standards in every state, along the lines modeled by the Civics Alliance’s American Birthright: The Civics Alliance’s Model K-12 Social Studies Standards,³ and we have been asked by Arkansas citizens to comment on the Division of Elementary & Secondary Education’s 2022 Approved Social Studies Standards.⁴ (Hereafter Standards.) We conclude that:

1. the Department’s standards adoption process does not meet acceptable standards of openness and public accountability;
2. the basic structure of the Standards, particularly the requirement that it conform to the College, Career, and Civic Life (C3) Framework for Social Studies State Standards,⁵ requires Arkansas to provide inferior and politicized social studies instruction; and
3. the Standards include substantial amount of solid factual content, but teachers will not be able to make proper use of this content until the Department reforms the Standards’ larger structure.

Arkansas Standards are better than those of states such as Minnesota and Rhode Island.⁶ The Arkansas Standards’ substantial factual content is a solid accomplishment by Arkansas’ Department of Education. Yet it is not enough by itself to provide adequate social studies standards. The fundamental politicization of the C3 Framework, which aligns with radical pedagogies such as Critical Race Theory, means that the Department of Education will not be able to fulfil Governor Sanders’ Executive Order to Prohibit Indoctrination and Critical Race Theory in Schools until it decouples the Standards from the C3 Framework and undertakes systematic reform of the basic structure of the Standards.

We strongly urge the Department to engage in this systematic reform, of the Standards’ basic structure, as well as in systematic reform of its standards adoption process. We urge you to initiate an immediate review of the existing Standards, and to begin a new process, independent of the Department’s permanent administration, to replace it with Standards adopted upon a new basic structure. We urge you finally to recommend to Governor Sanders that she lend her public support to this reform, so as to rally the citizens of Arkansas to support these reforms.

A Secretive Standards Adoption Process

The Department, to the best of our knowledge, made no provision for public comment on the Standards before they were approved by the Board of Education.⁷ Nor did they notify state legislators to provide them the opportunity to comment on the Standards. The Department did not even put a PDF of a draft version of the Standards on the website.

The Department does not match the criteria for public openness and accountability of its peers across the nation. Just since 2021, Louisiana, South Dakota, Virginia, and Rhode Island have all released draft social studies standards to the public for inspection and comment. Louisiana provided a web page portal for detailed public comment, as well as facilitating detailed overview by state legislative committees. South Dakota and Virginia both provide for multiple public hearings over the course of several months. Florida conducted a 2021 Standards Listening Tour for the public.⁸ Again, to our knowledge, the Department made no provision for public or legislative comment or input.

Not only did the Department fail to match its peers’ criteria for public openness and accountability, it would not seem to have followed Arkansas’ statutory requirement that “The department shall include, at a minimum, the following elements in the periodic review and revision of Arkansas academic standards: … Public dissemination of revised academic standards.”⁹ Given that the Department provided for no public dissemination of its Standards during the review and revision process, the Standards may not even be legally valid.

Nor, in our own case, did the Department facilitate our ability to comment on the Standards before they were approved. We sent in four separate emails between September and November 2022, asking about whether there was a webpage with a draft Standards PDF, a public comment period for the social studies standards, or a process for submitting a public comment—and received no response until January 2023, after the Standards had already been approved by the Board.¹⁰ The Department’s dilatoriness gives the strong impression that the regular bureaucracy wished to prevent any individual or organization from commenting publicly on the Standards until after the Board approved it. This impression is strengthened by the fact that we have found no record of any other organization or individual that was able to provide public comment during the Standards adoption process. The Department lacks not only procedures to ensure public openness and accountability but also, to all appearances, an institutional ethic of public openness and accountability.

We wish to underscore that the Department’s behavior not only fails to match those of its peers but also would appear to have departed from Arkansas’ statutory requirements. The Department’s secretiveness may have led it to issue Standards that lack legal validity.

We also wish to underscore that this behavior took place before the inauguration of Governor Sanders, and before your appointment as Secretary and Commissioner.

Structural Flaws: C3 Framework

A great many of our critiques below of the Standards’ structural flaws cannot be taken in isolation from the Standards dependence on the C3 Framework. The C3 Framework, unfortunately, imposes radicalism and mediocrity on social studies standards. We have critiqued the C3 Framework extensively elsewhere, and conclude:

The C3 Framework substitutes process for content, yokes social studies instruction to the failed Common Core curriculum, politicizes social studies instructions, and subordinates all of social studies instruction to action civics, which replaces civics education with vocational training for left-wing community organizing.¹¹

No Arkansas statute mandates that the Arkansas Department of Education use the C3 Framework. It has been imposed on Arkansas by the Department’s administrative decision—and it can and should be removed, along with every Departmental educational resource that depends upon or forwards the C3 Framework.¹²

We note that Arkansas statute does require, “Study and consideration of academic standards at the national and international level, as appropriate”¹³ But “Study and consideration” does not require acceptance. In any case, Arkansas may instead study and consider an alternate national academic standard such as the Civics Alliance’s American Birthright: The Civics Alliance’s Model K-12 Social Studies Standards.¹⁴

Structural Flaws: Substantive Details

The Standards’ structural flaws include the following:

Confusing, Repetitive Format: The Standards embed factual content within complicated pedagogical frameworks, distributed across 15 separate PDF files, each of which includes Disciplinary Concepts, Dimensions, and Knowledge and Skill Performance Expectations. Teachers will have difficulty comprehending the Standards, and parents and policymakers, who should be able to hold teachers accountable for teaching according to the standards, will find the Standards virtually impossible to understand.

Misguided Skills and Inquiry Emphasis: The Standards emphasizes “skills,” and concepts such as “decision-making models,” at the expense of factual content. The Standards also echoes the latest fashion in education schools, “inquiry-based learning,” which facilitates an unfortunate tendency to include tendentious “questions” that imply answers that fit radical polemic. These emphases not only render the Standards bulky and unreadable but also will steer teachers and school districts to waste scarce classroom hours teaching mandated skills and “inquiry-based learning” rather than in teaching factual content.

Vague Reading and Writing Expectations. Arkansas’ Disciplinary Literacy Standards Resource for History/Social Studies, which unfortunately appear to derive from Arkansas’ adoption of the Common Core, contain no firm reading or writing expectations.¹⁵ Arkansas’ Standards should have firm and clear expectations, which parents may use to hold their schools and their teachers accountable. Social studies instruction should include:

Reading Expectations, which build toward students capable by graduation from high school of reading an intellectually and stylistically sophisticated 200-page history book, which demonstrates that they are prepared for an undergraduate history course; and

Writing Expectations, which build toward students capable by graduation from high school of writing an intellectually and stylistically sophisticated 10-page history paper, which demonstrates that they are prepared for an undergraduate history course.

Misguided Commitment to “Action Civics”: The Standards too frequently subordinate civics education to “action civics,”¹⁶ also known as “protest civics,” which substitutes vocational training in progressive activism for classroom civics education.¹⁷ The Standards possess, for example, a Grade 4 “Inquiry project on a local or global issue” and “Making a Difference: Finding Solutions that Improve Our World”¹⁸

Politicization: The Standards includes politicized instruction, sometimes married to action civics. In Grade 5, for example, the Standards requires “Evaluate the sustainability of resources achieved through civic actions.”¹⁹ This item alone imposes the radical environmental activism of sustainability in combination with action civics in the guise of civic actions.

Confusing K-4 Format: We sympathize with the desire to increase curricular autonomy for school districts, but individual grade bands are a much clearer ways to organize material. The Standards’ format also means that Arkansas doesn’t dedicate a K-4 year explicitly to American history and geography.

K-4 Progressive Structure: The K-4 structure, in too many of the strands, follows the progressive pedagogical progression from community to state to nation. While the K-4 standards do possess good national material, Arkansas should integrate national material—the stories of America and Americans—throughout the K-4 sequence.²⁰

Absent Core Disciplinary Concepts: Liberty, Documents of Liberty, and Common American Culture: Arkansas does not include Liberty, Documents of Liberty,²¹ or Common American Culture²² as core disciplinary concepts. These need to be included explicitly as core disciplinary concepts, to ensure proper organizing principles for social studies instruction—and to ensure that social studies instruction does not casually cast these aside.

World History Substituted for Western Civilization: The Standards cannot provide a coherent presentation of Western Civilization’s ideals and institutions of liberty, which Arkansas students need if they are to understand the Declaration of Independence and the Constitution, because they substitute a disjointed and vague World History course for dedicated instruction in the history of Western Civilization.

Distorted Geography: The Standards’ Geography largely provides cues for environmental or open-borders activism. The only subsection that provides actual Geography instruction is Geographic Representations.

Distorted Economics: The Standards’ Economics instruction uses the phrase needs and wants. This distinction, foreign to economic theory, allows activists to smuggle in a polemic for an expansive welfare state in the word needs, to justify government intervention in every aspect of the economic realm denominated as needs.

“Media Literacy” Distortions: The Standards includes media literacy instruction, which frequently is used to forward default credulity in the radical polemic embedded in the establishment media, and to forward default skepticism in news that contradicts radical polemic.

Distorted Electives. The Standards includes several electives subject to substantial distortion.

Psychology: The Psychology Elective does not include coverage of the irreproducibility crisis, which has cast doubt on much psychological research—not least for its subordination to politicized groupthink.²³

Sociology: The Sociology Elective reflects the pervasive politicization of the discipline; e.g., “Examine factors that contribute to and maintain social inequalities.” And “Propose alternative responses to inequality from a variety of sources from multiple perspectives.” ²⁴

World Geography: The World Geography Elective consists entirely of cues for radical activism.²⁵

Evanescent Radical Jargon: The Standards does not use this as heavily as some of its peers, but it does use some—enslaved people, Indigenous peoples, etc. The Standards should remove all such jargon.

Semiliterate Prose: The Standards uses “impact” throughout, when it should use “affect” or “effect.” The authors of the Standards reduce confidence in their command of history when they demonstrate shaky command of the English language.

Solid Factual Content

We believe Arkansas has made a particularly good choice to provide three years of dedicated United States History instruction, in Grade 7, Grade 8, and high school.²⁶ These three years provide better instruction in American history than most states provide.

The Standards include large amounts of solid, factual content throughout, which provide clear expectations for teachers and students. We approve of many of these choices. Where we disagree in detail about the choices and omissions, we would suggest revision along the lines of American Birthright.²⁷

We do not go into greater detail about the Standards’ content because the Arkansas Board of Education has already approved these Standards. We do not believe that the Department should allow the content of these structurally distorted Standards to remain unchanged, but we do not think this letter is appropriate for detailed content criticism.

Arkansas Standards’ combine severe structural distortions with a base of solid factual content. That base provides Arkansas a good start for systematic revision of its Standards—but does not provide it an excuse not to engage in that systematic revision.

Recommendations: Standards Reform

We do not believe the Department should simply proceed toward implementation of the Standards in Arkansas’ public schools. The Standards possess substantial structural distortions and politicization, and they were approved without public consultation, in a manner that may have failed to fulfil Arkansas’ statutory requirements for public dissemination. We make the following recommendations to the Department, and to Governor Sanders:

Establish an Independent Standards Committee: The Department, the Board, and/or Governor Sanders should rescind the approval of these Standards. The Department, the Board, and/or the Governor should establish an independent committee to draft new social studies standards, with a remit to produce lucid, brief, depoliticized social studies standards that focus on factual content instead of skills and discard the C3 Framework straitjacket. We suggest American Birthright as a model—but also suggest that the Committee look at social studies standards in Louisiana, South Dakota, and Virginia.²⁸ This committee’s new draft Standards should be published on the Department’s website and undergo an extensive process of comment and review by the Arkansas public and policymakers.

Establish a Public and Accountable Standards Adoption Process: The Department administratively, or the state legislature by statute, should require that academic standards adoption be governed by the following procedures:

1. The Department of Education will draft the academic standards in consultation with a politically diverse cross-section of the public.
2. The Department of Education will report to the governor and the legislature on its success in consulting with a politically diverse cross-section.
3. The Department of Education may not provide preferential access to any portion of the public, or to any professional, for-profit, or not-for-profit organizations, in the drafting of academic standards.
4. The Department of Education will provide a three-month period of public comment for all academic standards, including at least four public meetings in different parts of the state. It will establish a website allowing for easy public comment, and it will make a good faith effort to address all public comments.
5. The Department of Education will publish a revised version of the academic standards no later than three months after the close of public comment, for submission to the Board of Education for final approval.
6. The Department of Education, in each stage of the drafting and public comment of academic standards, will provide easily accessible redlined PDFs of the entire academic standards on its website, which allow the Board of Education and the public to see how precisely the current draft differs from the previously approved academic standards, and from the previous draft of the academic standards.
7. The Department of Education may not require any school district to adopt its academic standards.

Detach Arkansas Social Studies Standards from the C3 Framework: The Department administratively, or the state legislature by statute, should detach Arkansas social studies standards from the C3 Framework.

Detach Arkansas Social Studies Literacy Standards from the Common Core: The Department administratively, or the state legislature by statute, should detach Arkansas’ Disciplinary Literacy Standards Resource for History/Social Studies from the Common Core standards.

Set Parameters for Academic Standards: The Department should require future academic standards to:

• adopt a straightforward bullet-point format;
• use lucid, everyday language;
• focus on factual content; and
• relegate any material on skills and inquiry to separate, optional Curriculum Frameworks.

New Core Disciplinary Concepts: The Department should add Core Disciplinary Concepts of Liberty, Documents of Liberty, and Common American Culture to the Standards, and revise them accordingly throughout.

Revise K-4 Social Studies Standards: The Department should adopt individual grade bands for the Grades K-4 standards, to improve clarity and accountability. The Department also should replace the progressive progression in the Grades K-4 standards, from community to state to nation, with instruction throughout these grades in American national symbols, historical and geographical facts, and common stories.

Western Civilization: The Department should revise the Standards to contain discrete, sustained coverage of Western Civilization throughout K-12 instruction, to provide students the coherent narrative of the ideals and institutions of liberty contained within the histories of the ancient Middle East, Israel, Greece, Rome, Medieval Christendom, the Renaissance, the Scientific Revolution, the Enlightenment, and medieval and early modern England. This instruction should include a dedicated and required class in high school. The Department administratively, or the state legislature by statute, should replace the Arkansas high school graduation requirements of 1 credit in World History with 1 credit in Western Civilization.

World History: The Department should revise the Standards to contain discrete coverage of World History, either as an elective or as a required course, to introduce students to the histories of Asia, Africa, and Latin America.

Remove Commitments to Action Civics: The Department should remove all action civics prompts and requirements from the Standards.

Remove Politicization: The Department should remove all politicization from the Standards, with a particular focus on Geography, Economics, Media Literacy, Sociology, and evanescent radical jargon.

Recommendations: Accompanying Measures

Social studies standards reform should work in tandem with broader support for education reform. We urge the Department of Education, and Governor Sanders, to undertake several broader measures:

Licensure Requirements, Professional Development and Textbooks: We suggest that the Department of Education and Governor Sanders work to update Arkansas’ licensure requirements, professional development, and textbook standards to align with the revisions we propose for the Standards.

Dual Enrollment Course Standards Revision: We suggest that the Department of Education and Governor Sanders ask state policymakers to enact laws that ensure that dual enrollment social studies courses (dual course, dual credit, concurrent enrollment) align with the revisions we propose for the Standards, as well as with Governor Sanders’ Executive Order to Prohibit Indoctrination and Critical Race Theory in Schools.

Statutory Reform: We suggest that the Department of Education and Governor Sanders ask state policymakers to enact laws that provide statutory underpinnings for the revisions we propose for the Standards.²⁹

Conclusion

The Arkansas Department of Education should detach the Standards from the C3 Framework, systematically reform the Department’ standards adoption process, and systematically reform the Standards’ basic structure. We urge you to initiate an immediate review of the existing Standards, and to begin a new process, independent of the Department’s permanent administration, to replace it with Standards adopted upon a new basic structure. We urge you finally to recommend to Governor Sanders that she lend her public support to this reform, so as to rally the citizens of Arkansas to support these reforms.

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