[This is a detailed rebuttal of S.418, a reading bill in SC, by Diane Stephens, Distinguished Professor Emerita, John E. Swearingen, Sr. Professor Emerita in Education, University of South Carolina]

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To members of the House and Senate Education Committees:

On April 19, 2023, I sent you a letter about the success of the South Carolina Reading Initiative (2000-2010). SCRI focused on helping teachers broaden their knowledge base so they could make informed scientifically-based curricular decisions based on student’s strengths and needs. Then I sent a second, shorter letter (see attached), because I thought shorter letters had a better chance of being read. This is my third letter and was based on a close read of S.418. (For your convenience, a copy of this letter, in word, with page numbers is attached as are copies of my first two letters).

Please postpone action on S.418 until there is time for everyone to provide informed feedback.

Meanwhile, here is my informed feedback.

I worked with struggling readers for 48 years. Although each individual is unique, when I listen to them read and ask them about what they read, I’ve learned that readers (K–adult) generally fall into two distinct categories: 

Category #1. The reader does not yet accurately use the visual information on the page. For example, the text shows a child about to put a spider in a box. The text is: Sally put a bug in a box. The child read, “Sally put a spider in a box.” The child was attending to some of the print (Sally, put, a, in, a, box) and to the picture (of a spider) but not attending to the word bug. The teacher can subsequently draw attention to the word bug and help the child use their knowledge of sound/symbol relationships to figure out that the word is bug; knowledge the child previously learned from the teacher.

An older student read, “Mr. Baker is a weatherman. He takes a lot about the weather.” However, the text was “He talks a lot about the weather.” 

In this case, the student was using four of the letters t, a, k, s and not attending to the l. The teacher can subsequently draw the student’s attention to all the letters and letter sounds in the word.

Category #2: What the student says when reading aloud fluently is an exact match to what is on the page, but the student can neither retell what they read, nor can they answer questions about it.

These students need to learn that reading is supposed to make sense—that they are supposed to be thinking when reading, not just call words. Teachers use a variety of strategies to help with this.

Teachers need autonomy to decide the best way to respond to these two different kinds of readers.

Therefore, while the proposed language for 5-155-110 (2) is:

(2) classroom teachers each school district periodically reassess their curriculum and instruction to determine if they are helping each student progress as a proficient reader and make modifications as appropriate. No PK-5 textbook or instructional materials that employ the three-cueing system model of reading, visual memory as the primary basis for teaching word recognition, or the three-cuing system model of reading based on meaning, structure and syntax, and visual, which is also known as “MSV” should be used in reading instruction

I suggest:

(2) Classroom teachers and school district periodically assesses their curriculum and instruction to determine if they are helping each student progress as a proficient reader and to make modifications as appropriate.

Rationale

Teachers need to be responsible for evaluating their curriculum and instruction. This should not solely be a district responsibility.

As this section it drafted, it implied that there is an instructional method called the three-cueing/MSV and there is not such a method. The information about three-cueing/MSV represents a misunderstanding about three of the cues to which all readers pay attention.

“M” refers to meaning and it is certainly critical that students focus on meaning in order to comprehend. The category #2 student above needed help learning that reading is supposed to make sense. Certainly, legislators do not intend for teachers to stop helping children with comprehension.

“V” stands for Visual. This is also referred to as “phonics” (the relationship between phonemes/sounds and graphemes/letters). The readers in Category #1 needed help paying more attention to the print on the page. Certainly, legislators do not intend for teachers to stop helping children with phonics.

“S” stands for structure/grammar and some students pay so little attention to meaning that they insert words that are grammatically incorrect. For example, if the sentence was “I looked out my window and saw the __ at the bird feeder,” some students might provide the word “black.” Teachers then respond appropriately based on what they know about the person as a reader. Certainly, legislators do not intend for teachers to stop helping children with grammar.

In addition to the above changes, I suggest that:

2.  While the proposed language for 59-155-110 (6) is:

(6) classroom teachers receive pre-service and in-service coursework which prepares them to help all students comprehend grade-level texts in foundational literacy skills, structured literacy, and the science of reading; how to analyze data to inform reading instruction; and provide scientifically-based interventions as needed so that all students develop proficiency with literacy skills and comprehension; classroom teachers certified in early childhood, elementary, or special education must complete board approved coursework in foundational literacy skills, structured literacy, and the science of reading or successfully complete the scientifically research-based reading instruction assessment approved by the board

I suggest:

(6) Early childhood, elementary, and special education teachers receive board-approved, scientifically based, pre-service and in-service coursework that prepares them to help all students comprehend grade level texts. This includes instruction in foundational literacy skills, reading assessment (so they know how to analyze data to inform reading instruction), and the reading interventions needed so that all students develop reading proficiency.

Rationale

First, it is not clear to me why the legislature would not want teachers to help all students to comprehend grade level texts, so I suggest that language not be deleted.

Second, the meaning of the term “structured literacy” is not commonly used in the reading research literacy and using it here is unnecessarily confusing.  What, for example, would “unstructured literacy” be?  See also suggestion for 59-155-120 (13).

Third, “science of reading” is often used to refer to a particular ideology and is not synonymous with “scientifically-based reading research “—research which has been shown in be effective in multiple peer-reviewed studies (see National Reading Panel Report, 2000).

Fourth, this paragraph could be more concise so that the meaning of the section is clearer.

3.  While the proposed language for 59-155-120 (4) is:

(4) “Foundational literacy skills” means phonological awareness, phonemic awareness, phonics, fluency, vocabulary, and reading comprehension; this definition of foundational literacy skills specifically excludes the “three-cueing system”, which is any model of teaching students to read based on meaning, structure and syntax, and visual cues, which may also be known as “MSV”.

I suggest:

(4) “Foundational literacy skills” means phonological awareness, phonemic awareness, phonics, fluency and reading comprehension.”

Rationale

For reasons noted above, the wording “this definition of literacy skills excludes the ‘three-cuing system,’ which is any model of teaching students to read based on meaning, structure and syntax, which may also be known as ‘MSV” should be deleted. The “three cuing system” is not a method and certainly the legislature does not intend for teachers to stop helping children with meaning, grammar, and phonics.

4.  While the proposed language for 59-155-120 (7) is:

(7) “Reading interventions” means individual or group assistance in the classroom and supplemental support based on curricular and instructional decisions made by classrooms teachers who have proven effectiveness in teaching reading and a literacy endorsement or reading coaches who meet the minimum qualifications established in guidelines published by the Department of Education.

I suggest:

(7) “Reading interventions” means individual or group assistance in the classroom and supplemental support based on curricular and instructional decisions made by classrooms teachers who have proven effectiveness in teaching reading and who have a literacy endorsement or by reading coaches who meet the minimum qualifications established in guidelines published by the Department of Education.

Rationale

These changes clarify the meaning.

5.  While 59-155-120 (12) currently offers a definition of Science of Reading as:

 “.. the body of research that identifies evidence-based approaches for explicitly and systematically teaching students to read, including foundational literacy skills that enable students to develop reading skills as required to meet state standards in reading.

I suggest instead that the definition of Scientifically-based Reading Research be used instead:  

(12) “Scientifically-based reading research” (SBRR) refers to research that appears in peer-reviewed journals of reading and whose findings are consistently established across a substantial number of peer-reviewed studies. SBRR identifies evidence-based approaches for explicitly and systematically teaching students to read, including foundational literacy skills that enable students to develop reading skills as required to meet state standards in reading.

Rationale

“Science of reading” is not equated in the reading research literature as synonymous with “scientifically-based reading research” – although it is used interchangeably in this bill. Using the broadly understood term, scientifically-based reading research (SBRR), clarifies the basis on which decisions about curriculum and instruction should be based and avoids potential confusion.

6. While the proposed language for 59-155-120 (13) is:

(13) “Structured Literacy” means an evidence-based approach to teaching oral and written language aligned to the science of reading founded on the science of how children learn to read and characterized by explicit, systematic, cumulative, and diagnostic instruction in phonology, sound-symbol association, syllable instruction, morphology, syntax, and semantics.

I suggest that (13) be eliminated.

Rationale

“Structured literacy” is not a term commonly used in reading research. The definition provides no new information and using it here is unnecessarily confusing.  59-155-120 (4) already stipulated that foundational literacy skills “means phonological awareness, phonemic awareness, phonics, fluency and reading comprehension.” That seems both clear and sufficient.

7.  While the proposed language for 59-155-130 (1) is:

(1) providing professional development to teachers, school principals, and other administrative staff on reading and writing instruction and reading assessment that informs instruction the science of reading, structured literacy, and foundational literacy skills based on the science of reading

I suggest:

(1) providing professional development to teachers, school principals and other administrative staff on scientifically-based reading research on both reading instruction and reading assessment.

Rationale

Teachers need to know about reading assessment so they can adequately address the strengths and needs of their students. And, as noted earlier, in this bill, “science of reading” is treated as the equivalent of scientifically-based reading research (SBRR) and using them interchangeable is a potential source of confusion. SBRR is consistent with the language used in reading research. “Structured literacy” is not commonly used in the reading research literature and using it here is unnecessarily confusing. 59-155-120 (4) already stipulated that foundational literacy skills “means phonological awareness, phonemic awareness, phonics, fluency and reading comprehension.” That seems both clear and sufficient

8.  While the proposed language for 59-155-130 (3) is:

(3) working collaboratively with institutions of higher learning offering courses in reading and writing for initial teacher certification in early childhood, elementary, and special education, and those institutions of higher education offering accredited master’s degrees in reading-literacy to design coursework in the science of reading, structured literacy, and foundational literacy skills leading to a literacy teacher add-on endorsement by the State. Institutions of higher learning that offer initial teacher certification in early childhood, elementary, and special education must provide the Department, and publicly report on their website and to all potential teacher candidates, the success rate of the institution’s teacher candidates who attempt the scientifically research-based reading instruction assessment approved by the board required for teacher certification

I suggest:

(3) requiring institutions of higher learning that offer initial scientifically-based reading research teacher certification in early childhood, elementary, and special education to provide the Department, and publicly report on their website and to all potential teacher candidates, the success rate of their teacher candidates on the board approved scientifically-based reading research reading assessment required for teacher certification.

Rationale

Again, the universally accepted meaning of scientifically-based reading research is not the equivalent of the science of reading. “Structured literacy” is not commonly used in the reading research literature and using it here is unnecessarily confusing. 59-155-120 (4) already stipulated that foundational literacy skills “means phonological awareness, phonemic awareness, phonics, fluency and reading comprehension.” That seems both clear and sufficient

9. While the proposed language for 59-155-130 (4) is:

(4) providing professional development in reading grounded in the science of reading, structured literacy, and foundational literacy skills and coaching for already certified reading/literacy coaches and literacy teachers

I suggest:

(4) providing professional development in scientifically-based reading research reading and coaching for already certified reading/literacy coaches and literacy teachers

Rationale

Again, it is preferable to use the commonly accepted term “scientifically-based reading research.”  There also seems to be no reason to repeat the terms “structured literacy, and foundational literacy skills”. “Structured literacy” is not commonly used in the reading research literature and using it here is unnecessarily confusing. 59-155-120 (4) already stipulated that foundational literacy skills “means phonological awareness, phonemic awareness, phonics, fluency and reading comprehension.” That seems both clear and sufficient

10. While the proposed language for 59-155-140 (A) (2) is:

(2) The state plan must be based on reading research and proven-effective practices, aligned to the science of reading, structured literacy, and foundational literacy skills and applied to….

I suggest:

The state plan must be based on scientifically-based reading research and applied to . . .

Rationale

Again, the use “scientifically-based reading research” instead of “the science of reading”, is that standard wording used in reading research. “Structured literacy” is not commonly used in the reading research literature and using it here is unnecessarily confusing. 59-155-120 (4) already stipulated that foundational literacy skills “means phonological awareness, phonemic awareness, phonics, fluency and reading comprehension.” That seems both clear and sufficient

11.  While the proposed language for 59-155-140 (B) (2) (a) is:

(2) (a) Each district PK-12 5 reading proficiency plan shall document how reading and writing assessment and instruction for all PK-5 students is aligned to the science of reading, structured literacy, and foundational literacy skills

I suggest:

(2) (a) Each district PK-5 reading proficiency plan shall document how reading and writing assessment and instruction for all PK–5 students is aligned with scientifically-based reading research.

Rationale

Same comment regarding scientifically-based reading research, “structured literacy” and the fact that foundational literacy skills have already been defined.

12.  While the proposed language for 59-155-140 (B) (2) (f) is:

(2) (f) Each district PK-12 5 reading proficiency plan shall explain how the district will provide teacher training in reading and writing instruction the science of reading, structured literacy, and foundational literacy skills

I suggest:

(2) (f) Each district PK-5 reading proficiency plan shall explain how the district will provide teacher training in reading and writing instruction based on scientifically-based reading research

Rationale

Same comments regarding scientifically-based reading research, the use of the term “structured literacy” and the fact that foundational literacy skills have already been defined.

13. While the proposed language 59-155-160 (5) (D) is:

Retained students must be provided intensive instructional services and support, including a minimum of ninety minutes of daily reading and writing instruction, supplemental text-based foundational literacy skill instruction, and other strategies grounded in the science of reading . . .

I propose:

Retained students must be provided intensive instructional services and support, including a minimum of ninety minutes of daily reading and writing instruction, supplemental foundational literacy skill instruction, and other strategies based on scientifically-based reading research.

Rationale

Same comment regarding scientifically-based reading research, the use of the term “structured literacy” and the fact that foundational literacy skills have already been defined.

15.  While the proposed language of 59-155-170 (B) is:.

These practices must be mastered by PK-5 teachers through high-quality training and addressed through well-designed and effectively executed assessment and instruction implemented with fidelity to research scientifically-based instructional practices presented in the state, district, and school reading plans. All PK-5 teachers, administrators, and support staff must be trained adequately in reading comprehension the science of reading, structured literacy, and foundational literacy skills in order to perform effectively their roles enabling each student to become proficient in content area reading and writing.I

I suggest:

These practices must be mastered by PK–5 teachers through high-quality training and addressed through well-designed and effectively executed assessment and instruction implemented with fidelity to scientifically-based instructional practices presented in the state, district, and school reading plans. All PK–5 teachers, administrators, and support staff must be trained adequately in scientifically-based reading research in order to effectively perform their roles and to enable each student to become proficient in content area reading and writing.

Rationale

Same comment regarding scientifically-based reading research, the use of the term “structured literacy” and that foundational literacy skills have already been defined.

With deepest thanks for all the hard work you do,

Diane Stephens, Ph.D.

Distinguished Professor Emerita

John E. Swearingen, Sr. Professor Emerita in Education

University of South Carolina