October 17, 2025
Zachary Rogers
U.S. Department of Education
400 Maryland Ave SW, Room 7W213
Washington, DC 20202-6450

Re: Comment on Proposed Priority and Definitions-Secretary’s Supplemental Priority and
Definitions on Promoting Patriotic Education Docket ID ED-2025-OS-0745

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Dear Mr. Rogers,

We provide these comments on the Department of Education’s proposed priority for
patriotic education and its associated definitions.

Summary

While this priority is situated in a shared belief that students benefit from an emphasis on
history and civics education, the proposed priority and its definitions require significant
modification. This proposed priority is one of many ongoing efforts by the administration to
override state and local control of education to impose a dishonest and politically
motivated curriculum. We identify opportunities for adjusting this priority and recommend
that recent grant cancellations be reversed. These changes would ensure that federal
investments live up to stated principles, as defined in the purpose for American History and
Civics-National Activities Grants, for an informed citizenry and recognition of the
educational needs of all students, with consideration for students from low-income
backgrounds and underserved populations.

The Need for History and Civics Educator Support

EdTrust supports the idea that the teaching of history and civic education in the United
States is critical and deserving of federal support. Civics education has not been prioritized
by the federal or many state governments for decades, despite the fact that parents across
the political spectrum agree that preparing students to be good citizens should be an
educational priority. Many teachers feel unprepared to teach civics and multiple
generations of Americans are unable to demonstrate strong civics competency.
But states and local programs would benefit from greater federal support that helps
teachers provide accurate and honest education, rather than be restricted by the narrow
definitions of patriotism outlined in this proposed priority.

Most teachers and principals believe there should not be legal limits on classroom
conversations about historical, social, and political issues, including gender and race, but
teachers are subject to censorship laws that ban these discussions in 20 states.
Censorship laws and other efforts, like this proposed priority, to whitewash the painful
parts of American history in favor of only stories that present our nation’s history in a positive light, undermine the free expression that is at the heart of the First Amendment,
constrain students’ learning opportunities, and diminish their sense of belonging and
ability to empathize. Two-thirds of teachers already limit any instruction that touches on
these issues, even when they are not subjected to censorship laws. Therefore, though the
goals of this proposed priority are important, we suggest a definition of “patriotic
education” that favors the open exchange of ideas and expansive views of history and
patriotism, rather than the narrow definitions outlined in the proposed priority.

Defining an Accurate and Expansive View of Patriotism

An accurate, expansive, and rich view of American history and patriotism is one that
recognizes both America’s failures and successes, allows students to see themselves
among our nation’s heroes, and recognizes the lingering effects of the more painful parts of
American history. It is not, as the Department proposes, one that is politically narrow and
inaccurate, and ultimately anti-American.

Consider its requirement that a patriotic education requires the teaching of an “ennobling”
view of America’s founding that is “unifying” and “inspiring.” It is far from “ennobling” to
learn that, at this country’s founding, enslaved Black Americans were counted as three- fifths of a person. It is far from “inspiring” to learn the history of how America’s early leaders systematically mistreated its indigenous population. The work of many of our civil
rights heroes, from the National Women’s Party’s militant tactics in support of women’s
suffrage, to Black leaders’ deliberate lawbreaking in pursuit of equal rights in the 1950s and
60s, was far from “unifying” at the time they undertook it, and in some cases, to this day.
Yet failure to teach students about any of these facts would be educational malpractice.
They are key moments in American history that led to important civil rights protections for
women and Black Americans.

Similarly, it would fail our nation’s students to imply that we have “admirably grown closer”
to our nation’s founding principles of life, liberty, and the pursuit of happiness, as laid out in
the grant priorities. Ruby Bridges — a historical figure who is still living — bravely integrated
her elementary school 65 years ago, yet more than a third of American students still attend
a highly segregated school. The final goal of an equitable American experiment has not yet
been achieved. It would be wrong to teach students it has, particularly when so many are
still living with the consequences of our failure to meet that goal.

Historical thinking requires the ability to handle varied and contradictory evidence, yet the
definition of the American political tradition for this proposed priority specifically centers
and limits the focus on the “influence of western civilization,” overlooking the vast
traditions and cultures that shape the “accurate, honest” definition of patriotism. Learning
about positive outcomes from the past can be as important as learning about our mistakes,
but this lesson too requires a recognition of change, not a singular view that America was
unimpeachable at its founding and no lessons needed to be learned since.

Supporting Local and Place-Based History and Civic Engagement

Federal competitive grant opportunities have always been carefully designed to avoid
defining educational content that would violate the General Education Provisions Act
(GEPA), 20 U.S.C. § 1232a, which reads:

No provision of any applicable program shall be construed to authorize any
department, agency, officer, or employee of the United States to exercise any
direction, supervision, or control over the curriculum, program of instruction,
administration, or personnel of any educational institution, school, or school
system […].

Yet, this proposed priority asserts a top-down determination of history and civics
curriculum that will “transmit to all American students a shared understanding of our
political, economic, intellectual, and cultural history.”

Given the changes the Trump administration has made at the Smithsonian and National
Parks, a commitment to officially declare that the perpetrators of massacre in our history
were actually heroes, and its broader efforts to dismantle programs that support students
of color, it’s clear there is a coordinated effort to whitewash the painful parts of American
history and hide the fact we, as a country, still have a long way to go.

This is particularly concerning in light of the Department of Education’s choice to meet the
above purpose through the development of the America 250 Civics Education Coalition, a
highly partisan and political venture to bring together organizations like the Heritage
Foundation, Turning Point Education, PragerU, Hillsdale College, and others under the
leadership of the America First Policy Institute, a conservative think tank. These
organizations are not experts in history or education. These are politically aligned
organizations that vilify LGBTQ+, immigrant, and Black and Latino communities and the
children within them. These organizations have made it clear that the history education
they imagine for students is an education that distorts facts and truth, and includes
claims: that America was a leader in abolishing slavery, despite being one of the last
Western countries to do so; that portrays Native Americans as warlike; that envisions the
country’s founders as godlike men while denigrating Progressive Era legislation and
American universities; that denies climate change is a social concern; that pushes
students to cite Biblical scripture in historical analyses; and that argues that women and
LGBTQ+ individuals should not have equal societal rights.

The United States citizenry is not fearful of an inclusive and rich history education that
confronts America’s accurate, honest past, and they trust teachers to decide what
students should learn. In a 2023 Gallup poll, a majority of respondents of all races and
political backgrounds supported teaching the history of racism in the U.S and its current
impacts. Seventy-five percent of respondents in a 2023 Ipsos poll agreed with the
statement, “Teachers are professionals who should be trusted to make decisions about
classroom curriculum.”

The funding for this proposed priority is concerning not just because it demonstrates a top-down and federal effort to define curriculum, but that it does so at the expense of programs
that would provide an accurate, honest history education. Programs that fund training for
future educators learning about Black, Mexican, and LGBTQ+ history have been cut in favor
of this new initiative. The premature cancellation of grants, targeting many grants awarded
during the Biden administration, appears to be a political project rather than a project that
is in the best interest of students. The fact that one National Council for History Education
(NCHE)-affiliated grant for a project that trained teachers in the St. Louis area in civil rights
education has been canceled while a similar NCHE-affiliated project in Broward County
has not, provides additional support that the canceling of grants is a political decision.

Defining a Forward-Looking Patriotic Education

We believe that federal grants should support locally determined explorations of history
and civic engagement rooted in the political, economic, intellectual, and cultural history of
student lives. Civic engagement is not an explicitly national project determined by political
powers at the federal level.

Trust in the federal government has waned for decades. As explained by the Pew Research
Center, social trust is critical to the American experiment and its success, because it
benefits the economy, it makes it easier for people to work together, and it is associated
with better-functioning democratic institutions.

As the proposed priority identifies, most Americans engage with one another at the local
level, such as through institutions like centers of faith, schools, and associations, but
participation at this local level has also been declining. Notably, there has been an
increase in civic deserts, “places without adequate opportunities for civic engagement —
places for discussing issues, addressing problems together, and forming relationships of
mutual support.”

Young Americans trust their peers and neighbors and one of the few social institutions that
are both present across communities and consistently trusted are public schools.

Many grant programs that support this localized approach to history education and civic
engagement are those that have been or may soon be canceled by the Department of
Education. For example, Senator Lisa Murkowski (R-AK) has written in support to appeal
the revocation of the See Stories grant for “Anchored Histories Teacher Professional
Development.” The project trains teachers and students in researching community history
and building social ties to that history through digital storytelling and archivism.

Highly regarded programs that have been identified as valuable to states and aligned to
state standards have also been identified for revocation of competitive grant funding. For
example, an Assistance in Arts Education program that had its final year of funding
rescinded because it included state-required language about a commitment to a diverse
candidate pool. The Milwaukee Roots Initiative, another National Activities Grant award that prioritized place-based engagement between educators, local historians, and
students to conduct historical inquiries, as emphasized in the Wisconsin social studies
standards, was also flagged for revocation.

Conclusion

States and local programs would benefit from greater federal support to provide accurate,
honest history education. However, a definition of “patriotic education” that narrowly
focuses on western civilization and an ennobling revisionism of U.S. history communicates
to educators, parents, and students that reality and truth do not belong in schools.
Combined with other efforts by the administration to empower political allies in developing
a patriotic history curriculum and to control the freedom of museums and other
institutions in shaping our collective memory, the proposed definition can accurately be
described as part of a propaganda project. The target of this propaganda project is not only
political, however, as this proposed priority is one of many administrative actions that will
harm Black, Latino, and LGBTQ+ students, and their families.

The Department of Education should reverse the cancellation of grants previously
awarded, particularly for programs that build civic engagement at the local level and are
supported by states, where autonomy over curriculum is legally required. A waning public
trust in federal institutions is only further damaged by canceling awards that build civic
engagement and patriotism. Applicants to grants utilizing this new proposed priority cannot
reasonably invest in projects that require hiring workers and extending sufficient resources
if there is a likelihood these same projects will have funding cut after the first year or two.

We also suggest a definition of “patriotic education” that favors the open exchange of ideas
and expansive views of history and patriotism, and that helps students develop critical
thinking skills through the ability to handle varied and contradictory evidence. In the
expressed interests of American families and educators, we suggest a civic-minded
definition that reflects our multi-cultural representative democracy and that acknowledges
how engagement with difference in our society has been our strength.

Thank you for your consideration.

Sincerely,

All4Ed
Applied Learning Insights LLC
EDGE Partners
Education Law Center-PA
EdTrust
Integrated Schools
League of Education Voters
National Coalition on School Diversity
National Parents Union

National Women’s Law Center
Public Advocacy for Kids (PAK)
The Civil Rights Project/Proyecto Derechos Civiles at UCLA