CCLS Contributor Appendix A, Dr. Moats Circa 2012 : CCSS Rest on Assumptions That Have Not Been Validated Through Research or That May Even Contradict the Findings of Research

Last week, I stumbled across an amazing article and immediately shared it with parents and educators. That article is important to share with good reason.

Dr. Louisa Moats, the nationally-renowned teacher, psychologist, researcher and author, was one of the contributing writers of the Common Core State Standards (CCSS) ELA. Dr. Moats was once a supporter of the CCLS. She even lectured in support of them circa 2010. In fact, she authored and contributed to the ELA Appendix A and was part of the CCLS development team.

But, like many other professionals, academics and educators, Dr. Moats no longer supports the CCLS and has been trying to speak out against it.

Indeed, in the Psychology Today piece dated 2014, she lambasted the CCLS.

A little about Dr. Moats:

Education & Bio

Harvard University Graduate School of Education, Ed.D. (1982) Reading and Human Development

Peabody College of Vanderbilt, M.A.
 (1969) Learning Disabilities/Special Education

Wellesley College, B.A.
 (1966) Music
Dr. Moats has been a teacher, psychologist, researcher,graduate school faculty member, and author of many influential scientificjournal articles, books, and policy papers on the topics of reading, spelling,language, and teacher preparation. After a first job as a neuropsychologytechnician, she became a teacher of students with learning and readingdifficulties, earning her Master’s degree at Peabody College of Vanderbilt.Later, after realizing how little she understood about teaching, she earned adoctorate in Reading and Human Development from the Harvard Graduate School ofEducation. Dr. Moats spent the next fifteen years in private practice as alicensed psychologist in Vermont, specializing in evaluation and consultationwith individuals of all ages and walks of life who experienced reading,writing, and language difficulties. At that time, she trained psychology interns in the Dartmouth MedicalSchool Department of Psychiatry. Dr. Moats spent one year as resident expertfor the California Reading Initiative; four years as site director of the NICHDEarly Interventions Project in Washington, DC; and ten years as researchadvisor and consultant with Sopris Learning.


Dr. Moats was recently a contributing writer of the CommonCore State Standards. In addition to the LETRSprofessional developmentseries, Dr. Moats’ books include Speech to Print: Language Essentials forTeachers(Brookes Publishing); Spelling: Development, Disability, andInstruction (Pro-Ed); Straight Talk About Reading(with Susan Hall,Contemporary Books), and Basic Facts about Dyslexia.

In that 2014 interview with Psychology Today, Dr. Moats offers a scathing analysis of the CCSS. She says:
“The standards obscure the critical causal relationships among components, chiefly the foundational skills and the higher level skills of comprehension that depend on fluent, accurate reading.  Foundations should be first!  The categories of the standards obscure the interdependence of decoding, spelling, and knowledge of language. The standards contain no explicit information about foundational writing skills, which are hidden in sections other than “writing”, but which are critical for competence in composition.”
“The standards treat the foundational language, reading, and writing skills as if they should take minimal time to teach and as if they are relatively easy to teach and to learn. They are not. The standards call for raising the difficulty of text, but many students cannot read at or above grade level, and therefore may not receive enough practice at levels that will build their fluency gradually over time.”
A hallmark of CC and PARCC testing, is computer based learning and assessments. She further says:
“We should not be requiring 3rd graders to compose on the computer.”
And:”raising standards and expectations, without sufficient attention to known cause and remedies for reading and academic failure, and without a substantial influx of new resources to educate and support teachers, is not likely to benefit students with mild, moderate, or severe learning difficulties.”
Read the entire Psychology Today interview with Dr. Moats, here.

Several people read the article I posted and asked why it took Dr. Moats so long to speak out. Turns out, she has spoken out about concerns relating to the CCLS previously. But, she has been speaking out against the trajectory of the standards since 2012 apparently, I have learned.

Indeed, I found a “loftier” journal piece from her circa 2012 that strongly criticizes CCSS and the trajectory of the measure particularly for students with reading disabilities: Reconciling the Common Core State Standards with Reading Research

I started to emphasize and bold parts of the article and realised most of what she writes is important. So, consider the whole piece “bolded” and most of the points are worth emphasizing, in fact.
Please take a moment to read the following and digest her message as it relates particularly to students with special needs. It is a very important one (please share):

Why the Common Core Standards Were Developed

The United States’ Common Core State Standards (CCSS) Initiative ( began at mid-year in 2009 after the presidential election and the change of leadership in the U.S. Department of Education. Several chronic, national concerns led the new administration to encourage development of a set of standards to which most states would voluntarily subscribe. Those concerns included a) growing dissatisfaction with widely differing academic expectations across the 50 states; b) student mobility and lack of consistent measures to compare students across settings; c) evidence that too many high school students were inadequately prepared for college-level work; and d) increasing pressures on the United States to compete more successfully in the global marketplace, where U.S. secondary students appeared to be falling behind those of other countries. Through a collaborative effort sponsored by the Council of Chief State School Officers (CCSSO) and the National Governors’ Association (NGA), English language arts and mathematics standards were drafted, reviewed, published, submitted for public comment, revised many times, and finally adopted by all but a handful of states by the end of 2010. Although adoption of the CCSS has been voluntary, states are required to embrace the standards if they are to be eligible for some federal programs, such as Race to the Top grants. Beginning in the 2014–15 school year, participating states must implement assessments aligned with the CCSS in Grades 3–8 and high school in English language arts and mathematics. Compliance with and implementation of the CCSS is now the central focus of states, districts, schools, publishers, and professional developers across the country.

The CCSS were designed to bolster the college and career (or workplace) readiness of students leaving high school. The developers of the CCSS argued for significant shifts in instruction after analyzing high school reading comprehension results from the ACT. The ACT college-admission testing program reported that high school students who go on to college but who do not succeed typically miss items on ACT reading comprehension tests that require interpretation of complex text. The CCSS development team, led by David Coleman (now President of the College Board), argued that students in middle and high school were being exposed to less and less rigorous textbook material and were being required to do less challenging reading than they were in the 1970s. The leadership team concluded that texts given to secondary school students needed to be more challenging and more complex, that teachers needed to do a better job teaching advanced and sophisticated reading comprehension, and that “close” and “deep” literary and informational text reading should be the main outcome of standards-based instruction. The standards-writing effort, consequently, was undertaken in reverse sequence – from the end-goal of advanced, college-level academic reading and writing (and math) backwards to its presumed underpinnings at each grade.

Organization and Features of the CCSS

The new standards require that students analyze a variety of complex texts, conduct frequent research, use technology to gather information, use academic vocabulary in speaking and writing, and create eloquent arguments with clear evidence – in both speaking and writing. Reading material, by the intermediate grades, is to be at least 50% informational (nonfiction, expository) text and up to 70% informational or nonfiction text by grade 7. Writing standards, even in the primary grades, focus on genre composition: narration, informational text, and opinion or argumentation. Reading is viewed as a knowledge-building activity, rather than one for which background knowledge is prerequisite. A standard receiving strong emphasis is one requiring students to derive evidence from a text during teacher-supported “close reading.”

The CCSS in English language arts are presented in these categories:

Alignment across grade levels was a primary goal of the standards-writing process.

Although classification of standards into categories may be necessary for indexing and ordering of goals within a content domain, the organization of the CCSS obscures many important interdependencies and relationships among the named skills. It is not clear why “Speaking and Listening” standards are separate from “Language,” for example, until one realizes that the “Language” standards pertain almost exclusively to written, not oral, language. The language standards at each grade level presume oral language competence and mastery of foundational reading and writing skills. There is no category for “Writing Foundations” to parallel “Reading Foundations” and thus the foundational skills of writing, including handwriting, spelling, punctuation, capitalization, grammar, usage, and sentence composition, are either overlooked, underestimated in importance, or awkwardly forced into other categories with no explicit link to composition. To further mask important skill domains affecting higher order learning, the reading foundations are placed after the text comprehension standards, implying that they are secondary to, incidental to, or less deserving of instructional emphasis than the literary and informational text reading standards. Although advancement of reading comprehension and engagement of students with high-quality texts is obviously a worthy goal, the educational path to that goal is by no means clear from the organization of the CCSS document. The door is wide open for teachers, curriculum developers, and states to determine how the standards will be assessed and implemented, because the standards document is agnostic with regard to best practices based on research.

The CCSS document reflects the influence of widely ranging opinions from all collaborators who submitted critiques and comments, including those of state departments of education, professional groups, university professors, advocacy groups, and publishers. Thus, the CCSS purported to be consistent with research on learning to read, write, and do math, but actually reflected current and popular ideas (and misunderstandings) about learning that were acceptable to a wide range of stakeholders in 2010. In this sense, the document represents a political (and philosophical) compromise. The CCSS, unfortunately, embody assumptions that have not been validated through research or that may even contradict the findings of research. For example, as Brady (2012, in this issue) notes, proficiency in rhyme production, as required in the CCSS, is not a prerequisite for learning to segment phonemes in spoken words and map them to graphemes. The requirement that first-graders read as much informational text as narrative may not make sense for students just learning to decode who need to take baby steps through our complex phonics system. Contrary to statements in the CCSS, fluency is not achieved at the end of second grade unless students are already proficient; rather, significant growth in fluency continues through grade 3 and levels off at about grade 5 (Hasbrouck & Tindal, 2006). In the area of written composition, the act of dictating or illustrating, as allowed by the CCSS in kindergarten, is not writing. Writing requires mastery of written symbol production (handwriting, spelling, punctuation) – which requires systematic instruction and practice before written composition is possible. Of most concern for students who struggle with language, reading, or writing, the CCSS state that all students should read text at grade level or above. This aspirational goal, while admirable, may lead to destructive consequences for the 40% who are below grade level and who are deemed “at risk” for reading failure according to predictive science (Torgesen, 2004). Of particular relevance to the community concerned with dyslexia, the standards provide no guidance and no links to research on individual variation and avoid recommending interventions for students who are functioning below grade level. The implication that these students will learn to read better if they are simply handed more complex and difficult texts, and asked to function like students who learn to read easily, is wishful – and harmful – thinking.

Realities of Language-Based Reading Disabilities

The lofty goals of the CCSS and the realities of student learning as we understand them from research may not easily be reconciled. Students who struggle with reading, including those with dyslexia, comprise at least 30% of the population (Fletcher, Lyon, Fuchs, & Barnes, 2007). About 34% of the population as a whole is “below basic” on the National Assessment of Academic Progress in fourth grade. Often, up to 70–80% of students in high poverty areas enter school at risk for reading failure. Mixed in as “poor readers” are all those who simply have not been taught how to read or who do not speak English. These facts imply that raising standards and expectations, without sufficient attention to the known causes and remedies for reading and academic failure, and without a substantial influx of new resources to educate and support teachers, is not likely to benefit students with mild, moderate, or severe learning difficulties. Rather, the stage is set for those students to suffer adverse consequences, such as forced grade repetitions, denial of promotion or diplomas, and irrelevant requirements that do not, in fact, enable students to be more ready for college or career.

What do we know about the prevention and amelioration of reading disabilities and related academic problems? First, there are too many cases for special education to handle, and regular classroom instruction is as critical to changing growth trajectories as remedial instruction. Regular classroom instruction (Tier 1 in a Response-to-Intervention model) that reduces reading failure includes systematic instruction in phoneme awareness, phonics (with spelling), passage reading fluency, vocabulary, and comprehension – strands that ideally complement and support one another. Most importantly, students must spend time reading – not simply being read to – from text of the appropriate level of difficulty. Second, if we do not catch students early (by second grade at the latest), improvement in their relative standing is much less likely and costs much more. Although many reading disabilities can be remediated or ameliorated by the end of first grade with systematic, explicit, phonics-emphasis instruction (Ryder, Tunmer, & Greaney, 2008; Mathes et al., 2005), intensive effort on the part of teachers and students is required to achieve modest gains once students are beyond kindergarten and first grade. In a classic study, Torgesen and colleagues (Torgesen et al., 2001) showed that poor readers in grades 3 to 5 needed 70 hours and more of instruction, about 2 hours per day, to bring their basic reading skills up to the level predicted by their verbal reasoning abilities, and those students continued to be dysfluent on follow- up. Morris and colleagues (2012) recently showed that high school poor readers can improve .5 standard deviations in reading after expert, intensive, closely monitored, theoretically sound, comprehensive, integrated instruction was delivered for 70 hours. The teachers in these studies were experts in the subject matter, were well trained in the methodology and remedial strategies, and worked with well-defined populations of students. Consistently, research shows that painstaking, incremental, informed instruction can advance the skills of students who are below average. Aspects of reading instruction promoted by the CCSS (reading of harder, complex texts; reading aloud; reading in the content areas; writing arguments) may be appropriate for older students who already know how to read and write, but may serve only to frustrate less-skilled students if the text is impossible for them to read independently and if insufficient attention is devoted to building the requisite language skills that enable improvement.

Where Are We Headed?

The CCSS present a series of high-level academic learning goals guided by the intent to prepare more students for college-level reading and writing. Curriculum and instructional design, however, is in the hands of publishers, professional interpreters, and state department officials. The door is wide open for interpretations that are not optimal for students with learning difficulties. If early efforts to implement the CCSS are any indication, research-based instruction appropriate for poorer readers is getting short shrift. The widely used Common Core Curriculum Maps (, for example, offer holistic, theme-oriented lessons organized around the reading of high quality texts, not around the systematic instruction of reading and writing skill. They presume that most students will pick up the fundamentals through incidental exposure. There is no clear directive about the prominent role that phonological awareness, phonics, or spelling instruction plays in preventing reading failure and enabling text comprehension. The section on “Reading Foundations” is disconnected from the main lessons, relegated to the back of the book, and unaligned with the holistic, theme-based lessons, such that simultaneous instruction of both approaches would be practically impossible. Holistic and literature-focused instruction is back with a vengeance, in spite of evidence that this approach is associated with higher rates of reading failure overall and lack of progress in poorer readers.

Confirming this trend away from systematic, explicit, skills-emphasis instruction is a directive recently issued by the Kansas Department of Education ( entitled, “A cautionary note about unpacking, unwrapping, and/or deconstructing the Kansas Common Core Standards.” Using seventh grade standards as an example, the document warns that “Unpacking [standards] often results in a checklist of discrete skills and a fostering of skill-and-drill instruction that can fragment and isolate student learning in such a way that conceptual understanding, higher order thinking, cohesion, and synergy are made more difficult.” “Holistic, integrated learning” is said to be the goal of standards-based instruction. No exception is made for the novice or unskilled learner (e.g., Brady, Braze, & Fowler, 2011), no reference is made to the changing nature of reading over time (e.g., Vellutino, Tunmer, Jaccard, & Chen, 2007), and no research base is invoked to explain the presumed dangers of a component-skills approach. It is to be taken as a matter of faith or philosophy that instruction in the component skills of literacy detracts from the real business of reading.

As practitioners search for guides to implementing the CCSS, they are unlikely to find in one package all the tools necessary to address a wide range of individual differences. No single series of model lessons and no single curriculum guide can describe the variations in content and methodology necessary to reach all students (see Connor, Morrison, & Katch, 2004; Connor, Morrison, & Underwood, 2007). With the CCSS’s emphasis on informational text, complex text, reading aloud, and inquiry-based learning, more of the nation’s attention is currently focused on higher-level comprehension, leaving almost no room for discussion of beginning reading and the needs of students with reading difficulties. The teacher-directed, systematic, sequential, explicit approaches that work best (Archer & Hughes, 2011; Clark, Kirschner, & Sweller, 2012; Rosenshine, 2012) are receiving much less discussion than they deserve. The risk, of course, is that even larger numbers of students will fail to become independent readers and writers.

Currently, the standards document obfuscates important relationships among word recognition, spelling, fluency, and comprehension (e.g., Mehta, Foorman, Branum-Martin, & Taylor, 2005) that provide the rationale for a multi-component approach. For example, from the standards document, a reader cannot learn that speech sound blending supports word recognition, that spelling supports vocabulary, that understanding of morphology speeds word recognition, or that oral language capacities are the underpinning for written language. One would not realize that handwriting, spelling, and sentence composition support higher level composition (Berninger & Wolf, 2009). Thus, it is vital that consumers of the standards document recognize its limitations as an instructional guide and look elsewhere for trustworthy, research-based guidance on curriculum and professional development.

The International Dyslexia Association has published many Fact Sheets that describe the methods, principles, and approaches best supported by research. These can be downloaded at

Directing Advocacy Toward What Works

At this point in our national discussion of education for students with reading difficulties, we need to be vigilant and vocal about the consequences of the CCSS roll-outs for students who do not learn written language easily and naturally. That group is a very large minority and in some districts and schools, the majority. If current trends continue, we may find that students with poor reading and writing skills, including those with dyslexia, are even more likely to be subjected to instruction that is inappropriate in pacing, emphasis, and design. Idealistic visions of student potential, coupled with unattainable standards, a “one size fits all” approach, and a disregard for decades of research on reading acquisition and individual differences may exacerbate student failure and suffering in our accountability-driven systems. The CCSS will only become a helpful resource if expected outcomes are adjusted for students’ capabilities and future goals, and if it can be demonstrated that the recommended shifts in instruction benefit all students – not just those who can learn to read easily and quickly. The directives of the CCSS must be better validated before we allow them to drive yet another upheaval in educational practices.

Advocacy for students with reading difficulties (again, a large minority) should strive to bring attention, training, and resources to teacher training on research-based practices, and to challenge ideas that are contrary to research or that are completely unproven. While supporting the broader goal to upgrade public education in the United States, we should be cautious in embracing the CCSS’s vision of “readiness” for college and career. Many kinds of educational experiences, widely differing from one another, are probably needed to prepare students for the workforce. Resources will be needed not just for elevating higher order reading, writing, and language skills, but for educating students appropriately across the entire spectrum of learning abilities.

Preparation of teachers is a key issue in improving literacy outcomes. Only a few teachers are well prepared to teach reading, language, or writing to students with literacy learning difficulties. The International Dyslexia Association has adopted rigorous professional preparation standards for teachers of reading (Knowledge and Practice Standards for Teachers of Reading, and is currently using them to evaluate university-based and independent teacher preparation and certification programs (see Liptak, 2012, in this issue). IDA is also planning to develop and promote a competency exam for teachers of reading that will be consistent with the IDA Knowledge and Practice Standards. Only by ensuring that all teachers are prepared to teach students with reading and language difficulties can we hope to improve student outcomes through the entire distribution of reading ability.

Current interpretations of the CCSS document may well create more obstacles for students than already exist. Advocates for students with dyslexia and related difficulties – indeed, all novices – are encouraged to be vocal supporters of meaningful, research-based education that safeguards students’ self-esteem and enables optimal progress. The CCSS may play some role in guiding that process, but should not be the overriding or dominant influence on the content or methods of education for students with reading difficulties. Rather, the CCSS should be appreciated as a document with strengths and limitations, interpreted with reference to research, and utilized cautiously until the standards are proven to influence improvements in teaching and student outcomes.

Free edition of her journal paper is here.

Lots of people are talking about the Common Core State Standards (CCSS). Are these standards really a good thing for students with learning disabilities? Dr. Louisa Moats, raised some questions about how the CCSS may not help our students. In a commentary published in New Times for Learning Disabilities in June of 2012, she cautioned advocates and educators not to slip into a trap of our own making. For a copy of her article, available for free, read it, and see what you think.

Common Core Standards (CCS) are not built upon the empirical reading research. Louisa Moats and Marilyn J. Adams started out helping to write the CCS because they hoped to make sure phonemic awareness/decoding skills, systematic reading instruction, cognitive progression of writing skills, and other important skills were placed into the CCS.  That did not happen. Read the Huff Po article here.


Which begs the question, how did the standards survive so long and why are they continued to be promoted with no evidentiary value? Because “the CCSS purported to be consistent with research on learning to read, write, and do math, but actually reflected current and popular ideas (and misunderstandings) about learning that were acceptable to a wide range of stakeholders in 2010.”

Speaks volumes.

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