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Texas Education Consumers Association

E-mail comments to eca@fastlane.net

"My children are important because of what they are in God,
not what they are in society."  
Rosanna Ward written in a paper on STW at Oral Roberts University

This report is a MUST READ for everyone concerned with school-to-work. The report describes the introduction of school-to-work in our nation, and focuses on how it is impacting classrooms, both in Texas and in other states. The document is heavily foot-noted, making it easy for readers to locate the original sources.

The report was prepared by the Texas Public Policy Foundation, a nonpprofit, nonpartisan research organization based in San Antonio. It was distributed February 3, 1998, at a Heritage Foundation panel discussion on school-to-work. The panelists included Lynne Cheney, Jennifer Marshall, and Chris Patterson. Several grassroots people attended this discussion, and were kind enough to send TECA a copy, which I have reprinted here. If the TPPF publishes this document on their web page, I will remove it from this site and substitute a direct link.

J. Donovan, Coordinator


Is Government Micromanaging?

Executive Summary

I. A Federal Education Plan

II. A Model for Education

III. Flawed Teaching Methods

IV. Origins & Beneficiaries

V. Installing STW

VI. Conclusion -- the Coming Collision

End Notes


Discussion Panel 2/4/98
Washington, D.C.

Is Government Micro-managing
the Lives of Our Children?

Featured Panelists

Senior Fellow, American Enterprise Institute

Education Policy Analyst, Family Research Council

Director of Education Policy, Texas Public Policy Foundation

Conservatives and liberals alike are concerned about how ill prepared today's youth are for entering the job market after graduating from high school. In 1994 the Clinton Administration proposed and Congress supported the School to Work Act to address this problem. The School to Work program, however, steers very little money towards true reform. Instead of solving this dilemma by focusing on strengthening the core curriculum, raising standards, and improving discipline, the program directs precious resources towards local partnerships, and interagency collaboration.

In particular, the program integrates vocational awareness into academic subjects for kindergarten through 12th grade and requires students to participate in vocational training during their education. Students are forced to choose a career pathway by 8th grade.

Is this program big government's latest move to micromanage our children? Will federal education dollars enable Washington to determine the future of our children?


Working Paper in Education Policy

Presented at
The Heritage Foundation Symposium

February 3, 1998

Chris Patterson
Director of Education Policy
Texas Public Policy Foundation


Executive Summary

This year is the fourth year of the seven year federal initiative, the School-to-Work Opportunities Act of 1994. Today, thirty-seven states have initiated School-to-Work programs with federal funding and all fifty states have received planning grants. The School-to-Work Act provides "start-up" funding for states to build comprehensive programs of education and workforce development for the purpose of creating a national system. Administered by the U.S. Department of Education and Labor, the Act defines a structure that includes work-based learning, school-based learning and connecting activities. The goal of this system is to produce a quality workforce that will revitalize the economy of states and the nation. The Federal Government claims that this system will benefit business and students. Businesses will be furnished a ready, skilled workforce. Students will be provided a rigorous education that culminates in a highly skilled, highly paying job.

This report describes the introduction of School-to-Work programs throughout the nation, and identifies the emerging problems of implementation. The report describes the introduction of School-to-Work nationally within the context of Texas. Throughout the nation, School-to-Work:


Although these changes are occurring throughout our nation, these changes are not sought by the public, nor initiated by the public. As School-to-Work changes the roles of student, parent, school, business and the government, the divergence between the public and their government has grown increasingly evident. As government-initiated reforms introduce changes that are unwanted by the public, a collision appears inevitable between conflicting interests.

The Texas Public Policy Foundation (TPPF) is a nonprofit, nonpartisan research institute based in San Antonio, Texas dedicated to the core principle of limited government.


Education is becoming the fault line that is dividing the winners from the losers
in this economy to a far greater extent than ever before.
U.S. Labor Secretary Robert Reich


Texas and the United States struggle to meet the twin challenges of improving both education and the economy. Increasing the "intellectual capital" of American workers is key to our nation's prosperity and ability to compete within the global market, according to U.S. Labor Secretary Robert Reich.2 Clearly, the economic strength and vitality of both state and nation depend on the capacity to develop a highly skilled workforce. The federal School-to-Work Opportunities Act of 1994 was designed to address both problems. The Act provides a national framework and funding for education reform that is intended to provide Americans with the education and skills required for our nation to compete successfully in a global economy.3 Targeting workforce education, School-to-Work (STW) is an integral element of a set of comprehensive economic development strategies established by the U.S. Departments of Education and Labor.4.

School-to-Work Components

All fifty states have received federal funds to plan STW programs and thirty-seven states have been funded to implement their programs.5 States are required to implement specific mandatory components of the federal Act, including:

School-to-Work's Purpose

By introducing these activities into classrooms throughout the nation, the United States has embarked on a national program of human resource and economic development based on those of competing industrialized nations.12 STW serves as the foundation of a national system to educate and certify labor to meet national economic strategies.13 STW establishes a new partnership between education and industry for the preparation of youth for employment, work entry, and worker re-training.14


Critics claim that STW:

Critics of STW include parent groups, family and/or religious-oriented organizations, and public policy institutes. Examples include: Eagle Forum, Family Research Council, Evergreen Freedom Foundation of Washington, Oklahoma Council of Public Affairs, Cascade Policy Institute of Oregon, the Family Foundation of Virginia, Parents Involved in Education of California, Pennsylvania Parents Commission, and the Kansas Education Watch. Recently, experts from the Heritage Foundation and the American Enterprise Institute have joined the list of critics.

A review of STW by the U.S. Department of Education's Office of Educational Research and Improvement warns that parental attitudes about their children's futures poses a serious threat to STW.21 "Parents' attitudes about what they want for their children represent one of the greatest barriers to successful implementation of school-to-work."22 A recent poll conducted by Public Agenda confirms that almost 80% of parents surveyed in California feel that young people would have better job prospects if they attend college rather than taking a job immediately following high school graduation.23


One movement that has the potential to bring together the high standards, proven instructional strategies,
exposure to work and incentives for study is referred to by many as "school to work".
-American Federation of Teachers

Advocates claim that STW:

Although support for STW is frequently described as "grassroots,"31 the proponents and supporters of STW are notably educational organizations, nonprofit foundations, manufacturers of educational products and corporate associations. These include the National Governor's Association, Education Commission of the States, the National Education Association, the American Federation of Teachers, the National Parent and Teacher Association, National Association of School Boards, the Carnegie Corporation, the De Witt Wallace-Readers Digest Foundation, the National Association for Supervision and Curriculum Development, Pew Charitable Trusts, the Committee for Economic Development, the National Alliance of Business, the Association of Manufacturers, the National Coalition for Advanced Manufacturing, the U.S. Chamber of Commerce, the American Business Conference, the U.S. Conference of Mayors, the National Conference of State Legislators, the Center for Occupational Research and Development (CORD) and Manpower, Corp.


School-to-Work is a method of teaching.32
-Norma Paulus, Superintendent of Education, Oregon

Shifting Focus from Intellect to Vocation

School-to-Work changes the purpose of education from intellectual development to vocational preparation.33 The purpose of the STW Act is to establish an educational framework that prepares students for work.34 It is intended to serve as the core of systemic broad-based reform of education.35 A model for this framework of education reform has been developed by the Southern Regional Education Board (an agency established by the federal government to provide research and assistance to states for education reforms advanced by Goals 2000 and the STW Act). High Schools That Work "phase(s) out the go-nowhere general curriculum" with: Integrated academic and vocational curriculum, individualized learning plans, contextual (applied) learning that focuses on problem-solving, interdisciplinary courses, social service support, flexible scheduling, instruction sequenced around a career major, vocational experiences, worksite mentoring, comprehensive counseling and skill certification.36 Since this program was launched in 1987, it has expanded to 650 sites in 21 states.37 There are more than twenty-four school districts in Texas using the High Schools That Work design.38

The Federal Mandate for Outcome-Based Education

The U.S. Department of Education funds research from the National Center for Research in Vocational Education (NCRVE) to disseminate "best practice" information about educational reforms for STW. Designing Classrooms That Work by the NCRVE identifies critical elements of curricula and instruction for STW programs. These critical elements that "federal legislation and school reformers are urging" upon schools include integrated (academic-vocational) curricula focusing on "generic" skills such as problem-solving and teamwork (instead of "school-based, subject-specific curricula"), contextual learning that "emphasize(s) real-world" (work-related) applications, student-directed instruction, cooperative learning, and authentic assessment.39 All of these elements are components of progressive educational reforms (most commonly identified as "outcome-based" education) that research has proven are ineffective teaching methods.40


What has changed education today is that we no longer see teaching facts
and information as the primary outcome of education.
-Shirley McCune, Senior Director
of the Mid-Continent Regional Educational Laboratory

Performance-Based Curriculum

The most comprehensive implementation of STW has occurred in states that have introduced STW as the focus of systemic, broad-based reform of curriculum and school change.42 STW introduces a very specific framework for curricula. Assessments (and, it must follow, curricula) must be performance-based to integrate STW with requirements of the Goals 2000: Educate America Act.43

What is Outcome-Based Education?

The term "performance-based" learning can be interchanged with the terms "mastery learning" or "outcome-based education."44 Described as the dominant form of educational change introduced to public schools over the past decade, performance-based education45 (otherwise known as progressivism and popularized by John Dewey46) has been introduced to many states with Goals 2000 funding. This type of education is characterized by the following pedagogical components: accessing skills, developmentally-appropriate practices, applied (contextual) learning, authentic assessment, heterogeneous grouping (by age and/or ability), constructivism (discovery learning), student-centered instruction, cooperative learning, interdisciplinary learning, contextual instruction, problem-solving skills, critical (not factual) thinking, and a focus on process (not a specific or correct outcome).47. "Whole language" and "new math" are outgrowths of this pedagogy.48 Based upon the "best practices" disseminated by federally supported STW sources, it is clear that the educational framework of STW is outcome-based (progressive) instruction.

Does Public Demand Exist for Outcome-Based Education?

Although outcome-based education and progressive reforms dominate school reform in the United States, parents do not support these changes. Research conducted by the Education Commission of the States indicate that most parents think the changes being introduced to schools are "on the wrong track."49 Research conducted by Public Agenda indicates that parents want schools to increase the focus on academics, teach traditional (subject-specific) knowledge and skills (i.e. math facts, mental computation, phonics, grammar and spelling), increase the rigor of educational standards, base promotion of standardized tests, group students homogeneously (by grade and/or ability) and prepare students for college.50

It may be that the divergence between public expectations for education and how schools are actually being changed accounts for the absence of parental involvement in School-to-Work reforms. Research published by the National School-to-Work Learning Center finds that parents are "conspicuously absent" from STW programs.51 The U.S. Department of Education reports that parents are concerned that STW limits opportunities for students, diverts students from academic learning and weakens preparation for college.52


The debate over teaching methodology continues...sometimes in the face of facts.53
-Representative Ron Sunseri, Oregon House of Representatives

Project Follow Through

Research has conclusively identified the specific pedagogical practices that are effective for student learning. The U.S. Department of Education conducted the world's largest, longest and most expensive educational experiment, Project Follow Through,54 which began in 1967 and concluded in mid-1995. The study cost at least one billion dollars, involved over 180 school districts,55 engaged almost 10,000 students (from kindergarten through third grade) in the study (plus students outside the study utilized as control populations) and examined 22 different types of educational programs.56 The purpose of Follow Through was to identify effective educational models for educating disadvantaged children.57

Effective educational models and teaching strategies were identified by this landmark study. The study also delineated the two educational philosophies and pedagogical approaches most common in American schools. All but two of the study models represented progressive educational approaches that are based upon the precepts of "natural growth," "developmentally appropriate practices," cognitive/conceptual orientation, supportive environments, "learning to learn," child-centered learning, affective focus, and problem-solving structure.58 The other two models represented behavioral approaches that focused on the acquisition of basic academic knowledge, identified specific academic objectives and arranged specific sequence of instruction necessary to attain the objectives (direct instruction).59

Project Follow Through conclusively demonstrated that direct instruction is significantly more effective in improving academic achievement than progressive educational models for disadvantaged children.60 Students who participated in direct instruction models:

Students in progressive educational models did not demonstrate the academic or affective gains achieved by students in direct instruction.63 On the contrary, students in the progressive programs either showed no improvement or, in many cases, scored below students in classrooms that did not participate in the study.64

Longitudinal (long-term) follow-up of Project Follow Through students indicated that the gains attained by direct instruction were sustained and additional benefits from direct instruction were derived. Students who participated in direct instruction had better attendance and higher college acceptance than their classmates.65

Project Follow Through validates what works to improve academic learning and self-concept for disadvantaged students: Direct instruction, focus on academics, phonics instruction, memorization of math facts and skills, subject-specific content, homogeneous grouping, teacher-directed instruction, organized and sequential building of knowledge and skills, and immediate response to faulty learning.

Project Follow Through fail to support the philosophy and pedagogy adopted by most educators today66 and fail to support the programs that our government continues to fund.67 The most important finding of Project Follow Through, however, is that progressive educational approaches (as exemplified by STW) are detrimental to all students, but most detrimental to disadvantaged children.68

The findings of Follow Through specifically apply to disadvantaged children. These findings, however, are consonant with the conditions necessary for the academic success of all students.69 A large body of research has been established that refutes the efficacy of progressive educational practices established for STW.70 Not only does research indicate that progressive practices have an adverse impact on academic learning, research also indicates that such practices have actually diminished the intellectual development of American students with high intellectual potential.71


If an unfriendly foreign power had attempted to impose on America the mediocre educational performance that exists today, we might well have viewed it as an act of war. 72

-A Nation at Risk, National Commission on Excellence in Education

A Nation At Risk

Flawed educational methodologies and conspicuous lack of parental support fail to slow the implementation of STW. The origin, originators and objectives of STW explain this failure.

The origin of STW, and the entire wave of education reform that our nation still rides, is widely believed to have begun after the publication of A Nation at Risk.73 Achievement tests of American students had dropped steadily for two decades and a study was commissioned in 1983 to develop recommendations to stem the "rising tide of mediocrity."74 Efforts were undertaken throughout the nation to improve public education. In 1985, U.S. Secretary of State George Shultz signed a formal agreement with the Soviet Union to develop and exchange curricula and teaching materials for elementary and secondary schools.75 The Academy for Educational Development (an independent non-profit service funded by numerous sources, including several departments of the U.S. government, the Carnegie Corporation, UNESCO and the World Bank) assisted this effort76 with a series of projects involving the multinational exchange of educational information and training.

The Legislative Agenda

A report published by Marc Tucker of the Carnegie Task Force on Teaching, entitled A Nation Prepared, stimulated the development of The National Center on Education and the Economy in 1988 (led by Marc Tucker and funded by the Carnegie Foundation) to deploy these recommendations.77 In 1990, the Center added Hillary Rodham Clinton to its board and published American's Choice: High Skills or Low Wages.78 This report called for American schools to teach students the skills needed for the workplace and paved the way for the recommendations issued by the newly formed SCANS Commission (created by the U.S. Department of Labor) that identified the skills schools should teach in the 1991 report entitled What Work Requires of Schools: A SCANS Report.79   [See the letter from Tucker to H Clinton outlining the plans for take-over of the whole of American education.]

The recommendations for education reform forwarded by these two reports were immediately adopted by the State of Oregon. Oregon passed legislation (Education for the Twenty-First Century Act) that restructured education around occupational clusters and included the key components of what was to later be federally legislated as School-to-Work.80 Recommendations for educational restructuring issued by both the SCANS Commission and the National Center on Education and the Economy were based upon European models of primary and secondary schools.81 In 1990, the U.S. Department of Labor funded 15 youth apprenticeship demonstration sites scattered throughout the nation to explore European models of education.82 At the request of President George Bush, the New American Schools Development Corporation (NASDC) was established in 1991 to develop designs for several model schools.83 NASDC unveiled 10 designs for schools that all incorporated integrated curricula (academic and vocational) and outcome-based education that culminated in certificates of mastery.84 One of the designs was sponsored by the National Alliance for Restructuring Education, a program of the National Center on Education and the Economy.85 Piecemeal restructuring of public schools around the basic principles of STW continued until the election of 1992.

A Master Plan for Human Resource Development

Dear Hillary: I still cannot believe you won. The subject we were discussing was what you and Bill
should do now about education, training and the labor market policy.

-Marc Tucker, National Center on Education and the Economy

When William Clinton was elected President of the United States in 1992, the patchwork of education reform was gathered into a seamless web. An 18-page congratulatory letter from Marc Tucker (National Center on Education and the Economy) to Hillary Clinton following "the election describes his vision for a national human resource development plan as a "seamless web" that "literally extends from cradle to grave and is the same system for everyone-young and old, poor and rich, worker and full-time student."87 Before the inauguration of William Clinton to the presidency, the National Center on Education and the Economy published the Human Resources Development Plan for the United States.88 This publication was to serve as the framework for legislation later known as Goals 2000: Educate America Act and the School-to-Work Opportunities Act of 1994, programs to fund the transformation of public education and the workforce.89 Before these acts had been passed, Marc Tucker published the guidelines entitled A School-to-Work Transition for the United States and States Begin Certificates of Initial Mastery for implementing the reforms.90

The Academy for Educational Development was contracted by the U.S. government to operate the National School-to-Work Learning and Information Center.91 The Center serves as a repository for information on STW and as a broker for technical assistance in systems building, school-based learning and connecting activities.92 Assisting the human development needs of over 100 nations in the world, the Center has developed special expertise in national, as well as multinational educational projects.93



School-to-Work came to Texas like a thief in the night. One morning parents will wake up to learn that the American Dream has been stolen from their children...unlimited educational opportunity has been replaced by limited job training options determined by regional workforce needs. The State Board of Education didn't approve this radical transformation of the public education system, and we are powerless to change it.94
-Bob Offutt, Texas State Board of Education Member

One of the critical issues related to STW is authority. Who holds the authority to education? Who makes decisions about what is taught and how it is taught? The larger question is -- Who holds the authority to change the purpose of education by implementing STW? Identifying authority for educational decisions is hotly and lengthily debated. Although the phrase "local control" is often cited, authority for educational decisions has passed from local school districts to state legislatures and state bureaucracies.95

Lack of Legislative Oversight

Concern that the public and their representatives have been removed from educational decision-making is expressed by local school board members, state board representatives, and even state legislators. Senator David Fowler of Tennessee recently stated that STW "had left the station and was moving full steam ahead" without the Tennessee Legislature.96 Representative Harold J. Vorhees of Michigan recently stated that STW is a "bureaucracy-to-bureaucracy agreement" that never went through an Education Committee in either the Senate or the House.97 Representative Ron Sunseri of Oregon questions "[w]hat in the world (is) the federal Department of Labor doing dictating standards in education . . .[?]"98 In Ohio, State Board of Education Representative Diana Fessler notes that "the only thing that is needed (to implement STW in every state) is the federal money."99

The decision to implement STW is generally made by a governor and state agencies. Texas offers a characteristic example. On August 18, 1996, Governor George W. Bush submitted an application for a STW implementation grant. This application contracted to meet the requirements for STW funding established by the federal act.100 STW was not approved by the State Board of Education,101 the Texas Legislature has not voted to adopt STW and the state education code has not been amended to legislate the specific provisions of STW. Members of the Texas Legislature have, however, been urged to review education reforms initiated by state agencies that "emanate from federal legislation" by State Board of Education Member Bob Offutt.102

Implementation of STW is generally conducted by a partnership of state bureaucracies with one agency given statutory authority to ensure systemic implementation. In Texas, authority for implementing STW is assigned to an Interagency management Team 103 that consists of the Texas Workforce Commission, the Texas Education Agency, the Texas Council on Workforce and Economic Competitiveness and the Texas Higher Education Coordinating Board.104 The Texas Council on Workforce and Economic Competitiveness has "the statutory authority, with the Governor's concurrence, to develop and enforce policies to ensure systemic implementation of STW."105

Local Implementation

Local implementation of STW is conducted by twenty-eight local workforce boards (working in conjunction with the local STW partnerships Texas developed in 1995).106 Local boards (and/or partnerships) serve as local grant administrators for STW.107 The boards are responsible for developing and maintaining a STW plan that complies with the state plan and establishes a strategy for formally enrolling students (including out-of-school youth) in structured academic- and work-based learning.108 Plans are required to lead to higher education or "high-skill, high-wage careers" and further training.109 Local Workforce Boards are expected to assist local school boards to develop STW programs.110 Local boards are responsible for helping establish the skills and standards for "relevant" school-and work-based learning. 111 Because STW officials possess remarkable authority for education, the absence of elected representatives of the public is significant. No members of local workforce boards nor the Interagency Management Team are elected representatives. The only elected representative with statutory authority over STW in Texas is the Governor.


Everything that follows is cast in the frame of strategies for bringing the new system into being, not as a pilot program, not as a few demonstrations to be swept aside in another administration, but everywhere, as the new way of doing business.112
-Marc Tucker, National Center for Education and the Economy

Funding School-to-Work

It is beyond the scope of this report to explore the changes beginning to occur in the economy and workforce as a consequence of STW. However, the initial cost of STW implementation can be examined. Because STW funding is "seed money" for a system that must build its own funding, the cost of STW is relevant to the examination of economic impact.


For the first year of STW implementation, Texas received $10 million dollars in STW funds113 of the $61.3 million awarded for the 5 year implementation.114 To implement STW in its first year, Texas plans to use $213 million dollars in matching funds that will be derived from other state and federal funding sources (such as Goals 2000, Communities in Schools Funds and State Career and Technology Education Funds).115 The cost of STW is currently borne by federal STW and other federal and/or state funding, however, the state recognizes the need to look beyond current funding sources. Texas' implementation grant states that "Texas does not plan to tax business to force participation as is done in Europe, but workforce areas will be required to raise private funds to supplement and continue School-to-Work as federal funding disappears."116

Other States

The cost of funding STW varies greatly from state to state. For example, New York State received $10 million for the first year implementation117 and contracted to match federal STW funding dollar for dollar.118 Ohio has received $9 million dollars of the awarded $45 million of federal STW funds. Ohio expects full implementation of STW to cost $1 billion dollars (requiring $955 million dollars from the private sector).119 The State of Washington pledged $318 million dollars of state funds in 1995 to complement the federal STW funding for its five year grant.120

Business Participation in School-to-Work

STW is a system of workforce and economic development that begins with education.121 Although the STW Act does not specify changes required of the workforce or the economy, the statutory requirements for education are intended to stimulate changes in labor and the economy. It is reasonable to presume that businesses will be at least encouraged to hire job applicants whose skills have been certified, otherwise certification is purposeless. It is reasonable to presume that businesses will be expected to contribute to the costs and activities of STW, otherwise STW would not be sustained. A statement by Michigan State Representative Harold J. Vorhees about national economic development concludes, "[p]lanned economies and their partner, planned education, are a failure around the world."122


How are schools restructuring themselves (schools within schools, block scheduling, etc.) to achieve the goals of education reform and STW? 123

-Implementation State Site Visit Protocol, National School-to-Work Office


As described in Section II of this report, the federal STW Act identifies specific curricular and instructional strategies that are required components of STW programs. The federal government also distributes curricular and instructional guidelines for developing STW programs. As states begin education reforms to introduce STW, a uniformity of curricula and instruction is evident. An overview of the reforms being implemented in public schools of Texas to introduce STW can furnish insight about reform on the national scale.


New state curriculum standards were adopted in 1997 that "redefine the three R's."124 The Texas Essential Knowledge and Skills (TEKS) identify what students are expected to know and do. Texas' new expectations for learning are written as performance-based standards.125 According to a report issued by the Texas House of Representatives House Research Organization, the new state standards contain expectations for learning that are outcome-based education.126

As pledged by Texas' STW Implementation Application,127 TEKS integrates vocational and academic instruction. In science, for example, third grade students are required to "connect Grade 3 science concepts for careers."128 Additionally, the Texas Education Agency has issued curricular guidelines for school districts to develop vocational awareness and career training into all academic subjects taught in kindergarten through twelfth grade.129

Conforming with "best practices" for STW that are distributed by the federal government, the Texas Workforce Commission has distributed and conducted training programs on curriculum and instruction. Connecting School to High Performance describes characteristic components of outcome-based education, such as group grading, cooperative learning, contextual instruction, authentic assessment substituted for unfair standardized tests, creating group interdependence, no wrong answers, heterogeneous grouping, facts as sub-skills, academic content as secondary to the educational outcomes of critical thinking, effective communications, and decision-making.130

Career Pathways

The Texas Education Agency issued a report in January 1997 that recommends all high schools in Texas:131

The Texas Education Agency recommends school districts in Texas adopt the seven career concentration areas identified below.132

The Texas Education Agency reports that approximately 60% of students in Texas are currently enrolled in career concentrations that plan their high school instructional program.133

Although policy recommendations are not mandates, and school districts are not compelled to comply with state educational policies, such state recommendations are in fact adopted by school districts. Because "school accountability system and teacher evaluations are linked to state policy, state recommendations are usually interpreted as carrying the weight of law."134

The voluntary nature of career pathway choices in Texas must be questioned. A state guideline entitled Career Pathways Toolbook directs that "career pathways provide a plan for all students" (emphasis in original) even though "there may be students who are not able to make a sincere career pathway decision," and "there may be some faculty and/or parents who do not agree." The report stresses that it "is important to continue with the career pathways concept in order to allow the majority of students to benefit."135

Skill Certificates and Work-Based Learning

The federal STW Act requires all STW programs to provide work-based learning, as well as school-based learning (as described above).136 Work-based learning includes a planned program of job training or work experiences, paid work experience, workplace mentoring, and instruction in workplace competencies.137 Successful completion of all STW programs is intended to lead to an occupational skill certificate.138 The Texas Skill Standards Board is charged with the responsibility of developing skill certificates and promoting their use among employers. 139 This Board is also to assist Local Workforce Development Boards in establishing statewide/regional Certificates of Initial Mastery.140

The Texas STW Implementation Grant identifies how students in Texas will meet requirements for work with such activities as cooperative education, internships, apprenticeships, clinical experience, job shadowing, mentoring, school enterprises, and community services.141 With these activities, Texas will work to "reduce mismatches between students/education, education/workplace needs".142 This statement is best understood in the context of the purpose of STW: Workforce development where "employer needs and skill standards drive the STW system." 143 This statement, then, should provoke the following questions. "What jobs do employers need in my child's workforce area?" and "What level of education is required for these jobs?."

The Texas Workforce Commission's Strategic Plan for 1997-2001 partially answers these questions. A chart indicates that the business sector in Texas now requires the following labor:144

The type of jobs dominating the Texas economy at present are low-skilled jobs requiring only basic literacy skills. This perspective is mirrored nationally. Statistics published by the U.S. Bureau of Labor Statistics predict that cashiers, janitors/cleaners/retail salespersons, waiters and waitresses and registered nurses will have the largest numerical increase in employment during 1994-2005.145 Because labor demands in Texas and throughout the nation are not for highly skilled, highly paid workers, the "relevant" education that is appropriate for employer demand is not college. Several reports issued by the state of Texas indicate that the projected need for college graduates falls between fifteen to thirty percent.146 It is beyond the purview of this report to explore the educational, economic, personal, social and political significance of this aspect of STW.

Comprehensive Guidance

Texas complies with the STW Act's requirements that all students engage in comprehensive guidance that teaches students workplace competencies, such as developing positive work attitudes and participatory skills. The Texas Education Agency issued a guideline in 1997 that directs schools to provide individual and group counseling for all students as regularly scheduled sessions. A Guide for Program Development Pre-K Through 12th Grade identifies the psychological competencies that are to be taught and tested within the classroom, including self-concept, evaluating personal decisions, adhering to group goals, healthy relationships, managing conflicts, need for personal flexibility, and cooperative relationships.147

Opportunity for All Students to Participate in STW

Texas technically complies with the STW Act's prohibition against forced participation but has, in fact, established a system that offers students no choice. Students in pubic schools have no alternative curriculum to the Texas Essential Knowledge and Skills, which integrates academic with occupational instruction. The state does not formally mandate participation in career pathways, but the state presses this responsibility onto school districts through policy recommendations.



This is civil rights action brought under 42 U.S.C. **1883 and 2201. Plaintiffs are parents of and students in the public schools of Oregon, and members of two local school boards concerned with coercive, invasive and discriminatory practices which have been implemented in the public schools of Oregon.148
-Case No. 96-6232-TC: Complaint for Injunctive and Declaratory Relief

The State of Oregon has introduced a system of STW similar to Texas' system. Texas cited Oregon's plan as a model reviewed in developing its own.149 Oregon developed a statewide system for education centered around STW rather than a specific program for STW.150 Oregon's system provides career awareness in elementary and middle school, counseling, school-sponsored work experience, integration of academic and vocational instruction, and provides for structured learning around occupational concentrations.151 The "Certificate of Initial Mastery" is a requirement for the Oregon system152 that has not been officially incorporated into the Texas STW system, although several Texas state documents call for its adoption.153 Like Texas, Oregon's STW plan states that "School-to-Work opportunities will be available to all students." (Emphasis in original).154 The notion that this statement indicates voluntary and optional participation for students in Oregon is dispelled by the legal challenge identified above by several Oregon parents who have unsuccessfully requested that their children be removed from the STW program.155


The Legislature finds that the performance-based education act of 1993 shifts public education from a knowledge-based, subject-driven system to a role-based, behavior-driven system. Given performance-based education, regardless of what name it carries, the definition of learning changes from the acquisition of knowledge to the 'changing of behavior.'" The Legislature finds that the emphasis on behavior changes undermines the role of the parent by establishing the school as the purveyor of attitudes, values and beliefs.156
-Senate Bill 5890, State of Washington, 55th Legislature, First Reading 2/18/97

In the State of Washington, STW is an integral part of education reform that is integrated with all aspects of curriculum and instruction.157 The STW plan in Washington includes opportunities for all students to participate, comprehensive counseling, certificates of mastery, integration of academic curriculum with occupational objectives for kindergarten through 12th grade, school-sponsored work experience, and performance-based curriculum (outcome-based education).158 The 55th Legislature is now considering Senate Bill 5890, which calls for the defunding of Goals 2000, which contains the components of STW and performance-based learning.

New York

School-to-Work is the engine that is driving education reform in NYS.159
-New York State Commissioner of Education

Like other states, New York's STW Plan is provided for all students (bold print in text).160 New York's plan states that it is "converting its existing mosaic of programs, projects and activities into a statewide school-to-work system that is a fundamental part of the educational structure in all schools."161 In New York, STW will provide all students (kindergarten through 12th grade) with an academic program that "infuses general workplace skills and competencies and career awareness activities into the curriculum."162 Like Texas, Oregon, Washington and all other states, New York is introducing the following STW components to public education: comprehensive counseling, career pathways called majors, school-sponsored work experience, integration of occupational and academic curriculum, and certification of workplace skills.163 New York's STW Plan states that STW "concepts must be integrated into all instructional programs from the kindergarten level through post-secondary education."164 Like Texas, New York has structured public education so that all students participate because there is no other alternative in public education.

Other States

The survey findings suggest that states are pursuing similar strategies and are crafting innovative approaches to overcome the many barriers to school-to-work implementation.165

Coordinators in self-labeled "local control" states report difficulties in building a statewide system, without intruding on the traditional prerogatives of local school districts...166

Some coordinators describe teachers, parents and educators as reluctant to part with traditional views concerning the boundaries of academic education and vocational education. The School-to-Work coordinators cite the continuing preeminence of college preparation within mainstream secondary education.167
-National Governor's Association StateLine State School-to-Work System Development-1996

A report issued by the National Governors Association at the end of 1996 charts the compliance of states with federal STW mandatory implementation components. The report indicates:168


This report has examined the education reforms introduced by School-to-Work and identifies the following effects of STW on public education in the United States:

The implementation of School-to-Work illuminates the conflicting goals for education that are held by the public and government. Parents and the public at large do not support School-to-Work and inevitably their opposition will increase. In fact, public opposition mounts even as this report is written. How and when the public will reject this system cannot be determined by this report. It is clear, however, that eliminating federal funding of such education reforms holds the greatest promise for preventing the coming collision between the American people and their government.


  1. Lynn Olson. The School-to-Work Revolution, Addison-Wesley, Reading. Massachusetts, 1997, p. 3.
  2. E. D. Hirsch, Jr. The Schools We Need-Why We Don't Have Them, Doubleday, New York, NY, 1996, p. 19.
  3. Executive Summary, Report to Congress, Implementation of the School-to-Work Opportunities Act, United States Department of Education and the United States Department of Labor, Washington, D.C., September 1997 (page not numbered).
  4. Ibid (page not numbered).
  5. Ibid (page not numbered).
  6. Ibid (page not numbered).
  7. The School-to-Work Opportunities Act of 1997, Title I, Section 3(a) (C).
  8. Ibid, Section 3(a)(1)(A).
  9. Ibid, Section 102.
  10. Ibid, Section 103.
  11. Ibid, Section 104.
  12. Bridging the Gap, Implementing School-to-Work Transition in Austin, Texas, Policy Research Project 103, Lyndon B. Johnson School of Public Affairs, Austin, Texas, 1993, p. 3.
  13. A Human Resources Development Plan for the United States, National Center on Education and the Economy, Washington, 1992.
  14. Executive Summary, Report to Congress, Implementation of the School-to-Work Opportunities Act (page not numbered).
  15. Robert Holland, What's Wrong with School-to-Work? EDUCATION REPORTER, Eagle Forum Education & Legal Defense Fund, St. Louis, Mo., May 1997.
  16. Donna Hearne. Paychecks and Power, The Constitutional Coalition, St. Louis, MO, 1995, p. 1.
  17. Testimony of Diana M. Fessler to the Tennessee Senate Education Committee, www.http://www.fessler.com., May 21, 1997.
  18. Robert Holland, What's Wrong With School-to-Work? EDUCATION REPORTER, Eagle Forum Education & Legal Defense Fund, St. Louis, Mo., May 1997.
  19. Rep. Harold Voorhees. Focus: Michigan Model of School-to-Work, EDUCATION REPORTER, Eagle Forum Education & Legal Defense Fund, St. Louis, MO, July 1997.
  20. Aldo Bernardo, Goals 2000 and School-to-Work: Education Reform as Social Planning, Oklahoma Council of Public Affairs, Oklahoma City, OK, 1996.
  21. Ray Ryan and Susan Imel. School-to-Work Transition: Genuine Reform or the Latest Fad? THE ERIC REVIEW, Volume 4, Number 2, Spring 1996, p. 7.
  22. Ibid, p. 7.
  23. Colleges, EDUCATION WEEK, New York, N.Y., March 5, 1997.
  24. Reaching the Next Step, American Federation of Teachers, Publication No. 281, Washington, D.C., 1996, p. 4.
  25. Margaret Leary., Turning Students into Employees, The National Tech Prep Network Center for Occupational Research, Waco, TX, 1996, p. 2.
  26. Executive Committee Meeting Minutes, Texas Council on Workforce and Economic Competitiveness, March 13, 1997.
  27. An Educator's Guide to School-to-Work, Brochure produced by Ohio School-to-Work, Columbus, OH (not dated).
  28. Lynn Olson, School-to-Work Revolution, Addison-Wesley, Reading, MA, 1997, p. 23.
  29. Making Career Connections, West Virginia School to Work.
  30. Thomas Bailey and Donna Merritt. School-to-Work for the College-Bound, EDUCATION WEEK, October 19, 1997.
  31. Connecting Learning and Work: A Call to Action, Education Commission of the States, Denver, CO, 1996, p. 1.
  32. Lynn Olson, School-to-Work Revolution, Addison-Wesley, Reading, MA, 1997, p. 205.
  33. Ray Ryan and Susan Imel. School-to-Work Transition: Genuine Reform or the Latest Fad? THE ERIC REVIEW, Volume 4, Number 2, Spring 1996, p. 2.
  34. The School-to-Work Opportunities Act of 1994, Section 3 (a)(C).
  35. Executive Summary, Report to Congress, Implementation of the School-to-Work Opportunities Act (page not numbered)
  36. Educational Benchmarks, Southern Regional Education Board, Atlanta, GA, 1996, p. 1, 35-38.
  37. High Schools That Work Web Site, Southern Regional Education Board, http://www.sreb.org/programs/hstw/about/Brochure, 1998.
  38. What is the High Schools That Work Program, Texas Education Agency Web Site, http://www.tea.texas.gov.Cate/hstw, 1997.
  39. Cathleen Stasz. Designing Classrooms that Work, Conception and Pilot Study, MDS-946, National Center for Research in Vocational Education supported by the Office of Vocational and Adult Education, U.S. Department of Education, 1997, p. 4 and 7.
  40. The Schools We Need-Why We Don't Have Them, p. 1-15, 48-68 and 127-159.
  41. Shirley McCune. Speech given to the Governor's Summit on Education, Kansas, 1989.
  42. Executive Summary, Report to Congress, Implementation of the School-to-Work Opportunities Act (page not numbered).
  43. School-to-Work Opportunities Act of 1994, Section 3 (a)(B).
  44. William Spady. The Trashing and Survival of OBE, EDUCATION WEEK, March 6, 1996.
  45. Examples and Summaries of State Initiatives to Develop Goals, Standards and Outcomes, Education Commission of the States, Denver, CO., 1994, p. 1.
  46. Charles Sykes, Dumbing Down Our Kids, St. Martin's Griffin, New York, NY, 1995, p. 202-209.
  47. Peg Luksik and Pamela Hoffecker. Outcome-Based Education, Huntington House Publishers, Lafayette, LA, 1995, p. 137-168.
  48. Dumbing Down Our Kids, p. 99-100.
  49. Listen, Discuss & Act: Parents and Teachers Views on Education Reform, Education Commission of the States, Denver, CO, 1996.
  50. The Basics: Parents Talk about Reading, Writing, Arithmetic and the Schools, Public Agenda, New York, NY, 1996 and First Things First: What Americans Expect from the Public Schools, Public Agenda, New York, NY, 1994.
  51. Study of School-to-Work Initiatives, Cross-Site Analysis, National School-to-Work Learning and Information Center Web Site, http://www.ed.gov/pubs/SER/SchoolWork/study, June, 1995.
  52. Executive Summary, Report to Congress, Implementation of the School-to-Work Opportunities Act (page not numbered).
  53. Ron Sunseri, Outcome-Based Education: Understanding the Truth about Education Reform, Multnomah Books, Sisters, OR, 1994, p. 77.
  54. Bonnie Grossen, The Story Behind Project Follow Through, EFFECTIVE SCHOOL PRACTICES, Volume 15, number 1, Winter 1994, p. 4.
  55. Ibid, p. 4.
  56. Billy Tashman. Our Failure to Follow Through, New York Newsday, November 14, 1994 reprinted in EFFECTIVE SCHOOL PRACTICES, Volume 15, Number 1, Winter 1996, p. 67.
  57. Cathy L. Watkins, Project Follow Through, BEHAVIOR MONOGRAPHS, Cambridge Center for Behavioral Studies, Cambridge, MA, 1997, Abstract.
  58. Geoffrey Bock, Linda Stebbins with Elizabeth Proper. Excerpts from the Abt Reports: Descriptions of the Models and Summary of Results, EFFECTIVE SCHOOL PRACTICES, Volume 15, Number 1, Winter 1996, p.10-15.
  59. Cathy L. Watkins, Project Follow Through, BEHAVIOR MONOGRAPHS, Cambridge Center for Behavioral Studies, Cambridge, MA, 1997, p. 60.
  60. Ibid, p. 60.
  61. Ibid, p. 34.
  62. Ibid, p. 59.
  63. Ibid, p. 60.
  64. Ibid, p. 44.
  65. Wesley Becker and Siegfried Engelmann. Sponsor Findings from Project Follow Through, EFFECTIVE SCHOOL PRACTICES, Volume 15, Number 1, Winter 1996, p. 41.
  66. Project Follow Through, p. 60.
  67. Ibid, p. 79.
  68. Ibid, p. 35.
  69. The Schools We Need: Why We Don't Have Them, p. 127-175.
  70. Ibid.
  71. Camilla Benbow and Julian Stanley, Inequity in Equality, Psychology, Public Policy and Law, Volume 2, Number 2, p. 249-292.
  72. A Nation at Risk: The Imperative for Education Reform, National Commission on Excellence in Education, Government Printing Office, Washington, D.C., 1983.
  73. The Schools We Need-Why We Don't Have Them, p. 3.
  74. Dumbing Down our Kids, p. 238.
  75. Kathy Finnegan. Goals 2000: Restructuring Our Schools, Hearthstone Publishing, Oklahoma City, OK, 1996, p. 42.
  76. Overview, The Academy for Educational Development Web Site, http://www.aed.org/html and www.aed.org/publications/arep/arep/_3.html, January, 1998.
  77. Goals 2000: Restructuring Our Schools, p. 44.
  78. Ibid, p. 47.
  79. Ibid, p. 40.
  80. Maureen Bozell, History of School-to-Work, Letter to Bonnylinn@aol.com, Academy of Educational Development, December 5, 1997 (permission to release obtained from Bonnylinn), p. 2.
  81. Ibid, p. 2.
  82. Ibid, p. 2.
  83. Goals 2000: Restructuring Our Schools, p. 53.
  84. Ibid, p. 53.
  85. Ibid, p. 44 and 53.
  86. Letter to Hillary Clinton, The Governor's Mansion, 1800 Canter Street, Little Rock, AR from Marc Tucker, National Center on Education and the Economy, November 11, 1992, CRISIS MAGAZINE, April, 1996.
  87. Ibid.
  88. A Human Resources Development Plan for the United States, National Center on Education and the Economy, Washington, D.C., 1992.
  89. Goals 2000-Restructuring Our Schools, p. 59 and 60.
  90. Marc Tucker. A School-to-Work Transition System for the United States, National Center on Education and the Economy, Washington, D.C., 1994; and States Begin Developing the Certificate of Initial Mastery, National Center on Education and the Economy, D.C., 1994.
  91. School-to-Work Learning and Information Center, Academy for Education Development Web Site, http://www.aed.org/us/sch2work.
  92. Fact Sheet, School-To-Work Learning Center Faxed Sheet, National School-to-Work Learning and Information, Washington, D.C.
  93. Bettye Lewis, School-to-Work: A Lifelong Learning System, The Christian Conscience Web Site, http://www.nctins.net/showcase/conscience.
  94. Education Briefs, The Notebook Series, January 1998, Texas Family Research Center, San Antonio, Texas, January 1998.
  95. Michael Kirst. Who Should Control Our Schools, School Leader, American School Board Association, March 4, 1988 (reprinted from the NEA Today, Issues OE88, January 1988.
  96. Tennessee Slows Down School-to-Work, EDUCATION REPORTER, Eagle Forum & Legal Defense Fund, Number 138, July 1997.
  97. Michigan Model of School-to-Work, EDUCATION REPORTER, Eagle Forum & Legal Defense Fund, Number 138, July 1997.
  98. Certificates of Mastery vs. Diplomas, EDUCATION REPORTER, Eagle Forum & Legal Defense Fund, June 1997.
  99. Letter of Transmittal to members of the Ohio State Board of Education, and Dr. Goff from Diana Fessler, Third District, December 10, 1996, A Report on the Work Toward National Standards, Assessments and Certificates, http://www.fessler.com.
  100. Letter to J.. D. Hoye, Director of the National School-to-Work Office from George W. Bush, Governor of the State of Texas, August 28, 1996.
  101. Education Briefs, The Notebook Series.
  102. Letter to Senator Teel Bivens, Texas State Senate from Texas State Board of Education Representative Bob Offut, November 1997 (carbon copies mailed to all members of the Texas Legislature).
  103. Texas School-to-Work Application for an Implementation Grant, Submitted to the U.S. Department of Education, August 30, 1996 by the State of Texas, Office of the Governor, p. 13.
  104. Ibid, Memorandum of Understanding, Implementation of a Statewide School-to-Work Texas System, Appendix (page not numbered).
  105. Ibid, p. 16.
  106. Texas School-to-Work Application for an Implementation Grant, 3.
  107. Ibid, p. 3.
  108. Ibid, p. 17.
  109. Ibid, p. 17 and 18.
  110. Ibid, p. 19.
  111. Ibid, p. 3.
  112. Letter to Hillary, page 8.
  113. Telephone Conversation with Amy Praskac, Texas Workforce Commission and Anne Newman, Texas Family Research Center, January 28, 1998.
  114. United States Department of Education and Labor News Release, November 21, 1996.
  115. Texas School-to-Work State Application for an Implementation Grant.
  116. Ibid, p. 39.
  117. School-to-Work Opportunities System Guidelines and Application Materials, Program Year 1997-1998, The New York State Education Department, Office of Workforce Preparation and Continuing Education, January 1997, p. 7.
  118. Ibid, p. 3
  119. A Report on the Work Toward Nation Standards, Assessments and Certificates, p. 28.
  120. Working Together and Learning Together: Creating Washington's Comprehensive School-to-Work System, State of Washington, June 16, 1995, p. 2.
  121. Executive Summary, Report to Congress, Implementation of School-to-Work Opportunities Act (page not numbered).
  122. Michigan Model of School-to-Work.
  123. Implementation State Site Visit Protocol, National School-to-Work Office, Washington, D.C., p. 7.
  124. Texas Redefines the Three R's: The New Public School Curriculum, House Research Organization, Texas House of Representatives, Focus Report, October 7, 1997, p. 1.
  125. New Essential Knowledge and Skills to Be Adopted by the State Board of Education, Texas Essential Knowledge and Skills, Texas Education Agency, Austin, TX August 1996 (first page, not numbered).
  126. Texas Redefines the Three R's: The New Public School Curriculum, p. 6.
  127. Texas School-to-Work Application for an Implementation Grant, p. 4.
  128. Texas Essential Knowledge and Skills, Chapter 112.5 Science, Grade 3 (b)(3)(E), p. 9.
  129. Career Development Implementation Handbook, Texas Education Agency, Austin, TX, 1996.
  130. Connecting Schools to High Performance, Texas Workforce Commission, Austin, TX 1996.
  131. Recommended High School Programs of Study, Texas Education Agency, Austin, TX, 1997.
  132. Ibid, p. 1.
  133. Ibid, p. 6.
  134. Letter to Teel Bivens, Texas State Senate from the Texas State Board of Education Member Bob Offut.
  135. Career Pathways Toolbox, Texas Education Agency, Austin, TX, 1996, p. 5.
  136. Legislative Fact Sheet, HR 2884/S1361, School-to-Work Opportunities Act of 1994, The U.S. Department of Education and U.S. Department of Labor.
  137. Ibid.
  138. Ibid.
  139. Minutes, Texas Skill Standards Board Meeting, Austin, TX, March 4, 1997.
  140. Minutes, Texas Skill Standards Board Meeting, Austin, TX, August 23, 1996.
  141. Texas School-to-Work State Application for an Implementation Grant, p. 20 and 21.
  142. Ibid, p. 8.
  143. Ibid, p. 3.
  144. Strategic Plan 1997-2001, Texas Workforce Commission, Austin, TX, 1996, attachment 2, p. 2-16.
  145. Chart 5, Occupations having the largest numerical increase in employment, 1994-2005, U.S. Bureau of Labor Statistics, Washington, D.C., 1996. 146. (1) Texas Workforce Commission Report to the Texas State Board of Education Committee on Long Range Planning, Austin, TX, September 12, 1996 (15%); (2) Career Majors in Texas Public Education, Texas State Occupational Informational Coordinating Committee in collaboration, Austin, TX, 1996 (less than 20%); (3) School-to-Work Transition, Texas Department of Commerce, Workforce Development Division, Austin, TX 1993 (less than 30%); and, (4) Exploring Career Pathways - A Guide for Students and Their Families, Texas Education Agency, Austin, TX, 1996, (30%) with the Texas Education Agency and Texas Higher Education Coordinating Board.
  146. A Guideline for Program Development Pre-K Through 12th Grade, Texas Education Agency, Austin, TX.
  147. American Family Association Law Center and National Legal Foundation, Attorneys for the Plaintiffs in the United States District Court for the District of Oregon, Case No. 96-6232-TC, Complaint for Injunctive and Declaratory Relief, p. 1.
  148. Texas School-to-Work State Application for an Implementation Grant, Application Contents (page not numbered).
  149. School-to-Work Opportunities State Implementation Grant, Oregon Department of Education, April 1, 1994, p. iv.
  150. Ibid, p. v.
  151. Ibid, p. iv.
  152. Connecting Schools to High Performance (page not numbered); and Texas Skills Standards Board.
  153. School-to-Work Opportunities State Implementation Grant, Oregon Department of Education, p. 1.
  154. American Family Association Law Center and Nation Legal Foundation.
  155. Senate Bill 5890, State of Washington, 55th Legislature, State of Washington, 7 Regular Session by Senators Zarelli, Hochstatter, Stevens, Schow, Swecher, Benton and Oke., Read First Time on 2/18/97.
  156. Working and Learning Together: Creating Washington's Comprehensive School-to-Work Transition System, Stte of Washington (page not numbered).
  157. Ibid, p. 1,5, and 10.
  158. School-to-Work Opportunities System, Guidelines and Application Materials, Program Year 1997-98, The New York State Education Department, Office of Workforce Preparation and Continuing Education, January 1997, p. 5, Table of 1995-1996 Actual Activities.
  159. School-to-Work Overview of New York State's School-to-Work Initiative, The New York State School to Work Advisory Council, p. 1.
  160. Ibid, p. 1.
  161. Ibid, p. 3.
  162. Ibid, p. 3, 8 and 9.
  163. Ibid, p. 12.
  164. National Governors Association Stateline, State School-to-Work System Development-1996, Washington, D.C., December 4, 1996, p. 1.
  165. Ibid., p. 10.
  166. Ibid, p. 10.
  167. Ibid (pages of tables not numbered).

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