International Montessori
Accreditation Council (IMAC)

Written Comments
to US Department of Education

April 1, 2008

Ms. Robin Greathouse
Accreditation and State Liaison
U.S. Department of Education
1990 K Street N.W., Room 7126
Washington, DC 20006-8509

RE: Opposing MACTE Recognition Renewal

Dear Ms. Greathouse,

I am writing on behalf of the International Montessori Accreditation Council (IMAC) to oppose the renewed recognition of the Montessori Accreditation Council for Teacher Education (MACTE) by your Department. Such recognition interferes with the development and progress of quality in Montessori teacher education, particularly as it harms IMAC accreditation activities and other non-MACTE types of Montessori teaching. The relevant background issues are described in more detail in the accompanying documents.

We also believe that the MACTE agency fails to qualify for USDE recognition under the pertinent recognition criteria, Title 34 CFR Part 602, for the following reasons:

§602.1(a)(1) Not a Reliable Authority

MACTE is not a reliable authority in Montessori teacher education because it represents only a single limited type of Montessori teaching, which is essentially the model and philosophy of the American Montessori Society (AMS). See Types of Montessori Teaching. The few non-AMS institutions that participate in MACTE do so either because they subscribe to the same AMS philosophy or out of fear and threat that non-participation would preclude their graduates from qualifying for employment under restrictive licensing regulation of Montessori schools.

Without the counter-balancing influence of IMAC recognition, MACTE exerts a misleading, incomplete, and unrepresentative impression of Montessori teacher education to the general public. In fact, the MACTE-AMS type of Montessori teaching is fundamentally inconsistent with the original vision, purpose and function of Montessori teaching as a scientific approach to bring about the child’s true nature. This true natural type of Montessori teaching, as well as other prominent expressions in the field, are inconsistent with MACTE participation due to this agency’s restrictive structure and operation. For example, the well-known non-AMS organization, Association Montessori Internationale (AMI), has no effective participation in MACTE decision-making since it has no representation on the agency’s central Commission.

Whatever pretense to diversity the MACTE agency may have had when first recognized in 1995, has now completely disappeared in its current structure and operation. For example, the original nine (9) separate MACTE review committees are now replaced by a single controlling Commission that reviews and approves all institutions. This central Commission, however, is dominated by AMS personnel, and uses a repressive majority-rule decision-making format to stifle any significant dissenting expression.

In practice, MACTE works against quality in Montessori teacher education by limiting expression and diversity in the wider Montessori community. For example, MACTE is waging an aggressive campaign to eliminate alternative expression in the field by gaining exclusive control over the certification of teachers in each of the 50 states. The MACTE website states: “It is vitally important that each of the 50 states grant recognition of Montessori certification obtained from institutions and programs accredited by MACTE for Montessori classrooms.” If successful, this campaign would cripple effective competition and experimental innovation in Montessori teacher education, which is so vitally important for its quality operation and progress. The practices and operation of MACTE therefore clearly work against it serving as a reliable authority of quality in the field.

§602.1(b)(1) Accreditation is not a required element

The MACTE agency has not shown evidence of a genuine need for its accreditation as a required element to enable participation in HEA funding programs by interested students. The USDE has already made it crystal clear that it cannot recognize any agency unless it shows that its institutions need the agency’s own specific accreditation to participate in Federal programs. The IMAC agency was denied recognition on precisely these same grounds. See USDE letter to IMAC, dated June 14, 1996.

Now, after so many years of recognized status, MACTE institutions still largely avoid even applying to qualify for Title IV funding. The few that have, tend to either fail to draw down funds or become disqualified for lack of interest. Even now, the three currently qualified institutions are all affiliated with other recognized accrediting agencies, which can presumably meet any requirement for student participation in HEA funding programs. MACTE is therefore not a “required element” to enable participation in HEA funding by interested students.

Although the current MACTE renewal petition claims that many more institutions are now interested and pursuing HEA qualification, there is little evidence of this. In fact, the MACTE agency seems aware of this obvious lack of interest, as it has been seeking to actively assist its accredited institutions to qualify. Quite rightly, however, the USDE said this type of self-serving MACTE involvement in the qualifying process would be a conflict of interest. (MATCE Commission Report, November, 2007)

MACTE-accredited institutions have never had a real need or interest to obtain federal funding for students through this agency. Rather, MACTE only seeks to have institutions qualify for funding at all to maintain a pretense of need to justify USDE recognition. MACTE’s real purpose in recognized status is rather to leverage and control the preferential issuing of Montessori teacher certification. See Montessori Accreditation — Issues of Power, Control, and Fear in Teacher Certification. Now, after 12 years of MACTE recognition, it is time to recognize the false premise of its USDE recognition and that is does not meet the burden of proving its compliance with this provision of the pertinent criteria.

§602.3(a)(2)(iii); (b)(1) and (3); §602.21(b)(5)
MACTE’s decision-making is not separate and independent, violating fundamental protection against conflict of interest

All MACTE decision-making is concentrated in a single all-powerful Commission, which is dominated and controlled by representatives of the same institutions it seeks to review and accredit. Only two of the 10 members are representatives of the general public. Moreover, four of the remaining 8 Montessori members are AMS personnel, three of whom hold key leadership positions on the Commission.

The lack of independent and separate decision-making in accreditation is even more evident in the way MACTE has changed from the time of its initial recognition in 1995. Since then, the nine (9) original review committees have been replaced with a single Commission, which effectively stifles dissent and open discussion through majority voting procedures and other means. For example, it discourages dissent and wider accountability for its actions by requiring members of the Commission to sign a pledge that they must publicly support actions of MACTE regardless of their own personal disagreement.

In addition, new Commission members can only participate by meeting highly restrictive conditions, and even then, only if elected by the existing Commission members. In this context, any diverse or dissenting interests of the constituent institutions is effectively repressed and denied any meaningful expression and representation on the Commission. The MACTE agency, therefore, lacks a truly separate and independent decision-making process due to its self-serving nature and function of operation. In addition, it violates protection against conflict of interest since it has no effective accountability for harm against institutions that don’t conform to the narrow perspective and control of the entrenched members of the Commission.

Summary
In sum, the MACTE agency fails to demonstrate compliance with key criteria designed to assure it is functioning as a reliable authority in the field of Montessori teacher education. Its original recognition was given on the false premise of a need to meet eligibility for Federal programs, which now, after 12 years, MACTE has amply demonstrated it does not have. Based on the above comments, we urge the Department to find that the MACTE agency fails to meet the pertinent recognition criteria and, therefore, should not be renewed for such recognition.

Sincerely,

Lee Havis, Chairperson
Encl./ Types of Montessori Teaching
Montessori Accreditation — Issues of Power, Control and Fear in Teacher Certification