June 16, 2025 

Ross Santy 

Chief Data Officer 

Office of Planning, Evaluation and Policy Development 

400 Maryland Avenue SW 

Washington, DC 20202 

Re: Comment on Agency Information Collection Activities: National Assessment of Educational Progress (NAEP), Docket ID: ED-2024-SCC-0133 

Dear Mr. Santy: 

 On behalf of the undersigned organizations working to advance civil rights and educational opportunity, we write to provide public comment on the 30-day public notice from the Department of Education (ED) regarding the 2026 National Assessment of Educational Progress (NAEP) assessment.   

 We support the administration’s efforts to continue administering NAEP, as it is the only nationally representative and continuing assessment of what students know and can do.  

However, we have serious concerns about ED’s capacity to effectively manage this vital assessment given recent reductions in force and unilateral contract cancellations that have severely limited ED’s research and data infrastructure. Specifically, the 30-day notice reveals concerning issues with the administration’s plan for the 2026 NAEP: 

• The assessment planning process is behind schedule, and the administration is planning further delays. Given staffing constraints, disruptions with NAEP contracts, and shifts in the way the exam will be administered (to rely more heavily on school coordinators to ensure that the exam can be administered on school devices), the administration is setting itself up for widespread implementation challenges when the assessment is administered in early 2026.  

• The Confidential Information Protection and Statistical Efficiency Act (CIPSEA) is no longer among the privacy assurances that NCES is following when collecting data. While ESRA has strong privacy protections that – if followed – will continue to mitigate risks in data collection, the lack of transparency from the Department about why CIPSEA will no longer be followed, and what the Department is doing to correct this problem, could erode public confidence in NCES’s data collection activities. 

• It had been previously reported that the contract to support the NAEP Validity Studies (NVS) Panel has been cancelled. The NVS is important because it helps ensure that the exam continues to be valid and that the scores are worth paying attention to. It is not enough to commit to administering NAEP. The Department must also commit to continuous improvement of the assessment the NVS helped provide. This 2026 NAEP 30D notice does not address how the Department plans to ensure that NAEP continues to measure what it needs to measure. 

• In this administration of the assessment, school administrators participating in NAEP will not be asked to respond to any items about race and ethnicity. This leaves important contextual information out of the rich NAEP data that helps us understand the how and why behind the assessment data. School leaders of color bring cultural understanding that helps them better serve diverse student populations and can be more effective at improving student outcomes. 

 In short, this situation represents a “forced error” – the administration has committed to continuing NAEP while simultaneously implementing policies that undermine their ability to efficiently plan, properly administer, and continuously improve the assessment.  

 The American people deserve honest, reliable data about educational progress. NAEP has provided that information for decades. It can only continue to do so if it is operated by a federal data and research infrastructure that has sufficient staffing and resources. Current resource levels at the Department of Education undermine NCES’s ability to run NAEP effectively. 

 We urge the Department of Education to immediately restore the staffing and contracts necessary to implement NAEP with integrity.  

Sincerely, 

 All4Ed 

Brown’s Promise 

EdTrust 

Healthy Schools Campaign 

InnovateEDU 

National Center for Learning Disabilities 

National Parents Union 

National Urban League 

The Center for Learner Equity