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April 20, 1998

Ms. Sharon Bobbitt
U. S. Department of Education
555 New Jersey Avenue, NW
Room 508c
Washington, DC 20202-5651

Subject: Proposed Rules; Standards for Conduct and Evaluation of Activities Carried Out by the Office of Educational Research and Improvement (OERI); Evaluation of the Performance of Recipients of Grants, Cooperative Agreements, and Contracts

Dear Ms. Bobbitt:

The following comments concerning the subject proposed rules are provided for your consideration:

    a. Section 702.1 (b). I don't believe standards can ensure the highest standards of professional excellence. They may measure the results of the activities being evaluated, which may not be of the highest standards.

    b. Section 702.3 (a). This statement is too broad. Recommend that it be deleted.

    c. Section 702.4 (d) (1). Since there may be more than one interim assessment, it should be clear here.

    d. Section 702.5 (a) (b) and (c). Recommend you define the terms in these rules. It will ease the work for the readers.

    e. Section 702.10 (d). Based on my experience in conducting a national selection program, I recommend that peer reviewers come from agencies external to the Department of Education.

    f. Section 702.23(a). It seems to me that the interim assessment(s) and its findings and recommendations would be an important source of information for the final assessment and should be included under paragraph (a).

    g. Section 702.24. This section could be shortened. There are too many items under the same criteria headings (i.e., Implementation & Management, Quality, Utility, etc.). Recommend that you consider one set of criteria for these programs.

One area that is not addressed in these proposed rules is what happens if the assessments show a weak program. Is the funding stopped?

Thank you for the opportunity to respond to this program. You have done a fine job putting these rules together. If you have any questions, please call me at (937) 775-2425.


Leon J. Testas
Associate Director

cc: W. Sellers

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