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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:
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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.
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.
Sincerely,
Leon J. Testas
Associate Director
cc: W. Sellers
