The following is a public comment given by Sutherland Institute on May 19, 2021, regarding a proposed rule from the U.S. Department of Education. On April 19, 2021, the department proposed a rule that would allow applicants for K-12 grants to be prioritized if they help develop “culturally responsive teaching.” The Department of Education – an agency of the federal executive branch – engages in federal rulemaking (creating regulations) pursuant to laws created by Congress, a process which requires the agency to publish the proposed rule in the Federal Register and receive comments during a public comment period. 

Sutherland Institute supports a renewed emphasis on civics education. However, because the proposed rule, which would modify the priorities for civics and history federal grants, further establishes a role for the federal government in education and fails to meet the substantive policy features we believe are essential for improvement in this area, Sutherland Institute opposes this proposed rule.

Federalism

Sutherland Institute recognizes that education reform – including civic education reform – is the responsibility of state and local governments.

To ensure that education policy reflects the values and issues of parents and teachers on the ground and in various regions and cultures, we believe that policies to improve education should be enacted at the state and local level – by governmental bodies which have the closest proximity to families. Likewise, federal intervention in education comes with increased bureaucracy for state and local education leaders charged with implementing federal policies.

Policy Features

Furthermore, Sutherland Institute believes that policies to improve civics and history education should emphasize civics and history that is comprehensive, scholarly, accurate, and transparent for parents.

Comprehensiveness

History and civics education needs to be comprehensive in covering the breadth and depth of the American experience, including both flaws and triumphs. Sutherland supports the inclusion of robust, comprehensive and diverse voices in American history. When it comes to championing new perspectives in history and civics education, we believe that commitment to the marketplace of ideas, honest pluralism, critical thinking skills, and open debate will equip students to navigate a complex world of history, civics, race, and lived experience.

Scholarship

Scholarship should be at the center of history and civics education reform. The best historical references and context should be offered to our students, including access to primary source documents and the work of historians. Classroom curriculum should be created by educators. Scholarship also includes the ability to examine and discuss multiple viewpoints and seek for knowledge.

Accuracy and Transparency

Furthermore, serious controversy or inaccuracies in educational resources or curriculum should be identified for parents, educators and students. The rule as currently drafted recommends – without the mention of scholarship errors or controversies – the works of The New York Times’ 1619 Project and the resources from the Smithsonian’s National Museum of African American History, which have made claims about “hard work” and being “polite” as evidence of systemic oppression. 

The rule does not mention the current public debate among states about the merits and concerns of concepts derived from antiracism and Critical Race Theory. Parents have the fundamental right to educate their children as they see fit. In keeping with that spirit, greater efforts to identify public debates around education materials will equip parents in their constitutionally protected role.