Questionable Curriculum: Why You Should Be Concerned About ICS Equity Promoting CRT In Your Schools

As we have been investigating CRT in schools, Integrated Comprehensive Systems for Equity, or ICS Equity, is a name that has come up repeatedly as a key player of the CRT development in districts across the state.


What is ICS Equity? What does it instruct teachers to take back to their classrooms?

Does it really impact your child’s education?

The MacIver Institute has an insider look at the CRT training teachers in Wisconsin undergo through ICS Equity.


September 8, 2021


What is ICS Equity?

As the MacIver Institute has been investigating Critical Race Theory (or CRT, Culturally Responsive Teaching, equity, dismantling structural racism, etc) in our schools, we have repeatedly come across an outlet called Integrated Comprehensive Systems for Equity (ICS Equity). ICS Equity appears to be a key proponent of CRT development and training in school districts across the state.

According to its website, ICS Equity was founded by Dr. Elise Frattura and Dr. Colleen Capper to help clients in the world of education “move beyond piecemeal approaches to equity and achieve equity systems change.”

At its core, ICS Equity seeks to overthrow our supposedly oppressive and inequitable system of education. Their website states that:

In spite of decades of educational reform and federal mandates, inequities among students not only persist but are growing. To eliminate these inequities, leaders must understand how their current piecemeal approaches are not only ineffective, but are exacerbating these inequities. Further, most equity work addresses only one aspect of inequities, such as culturally relevant pedagogy or developing culturally competent staff. Instead, leaders must learn how to transform the entire education system via Integrated Comprehensive Systems for Equity (ICS Equity). ICS Equity is the only equity-focused work that takes a systems approach to eliminate inequities.

The ICS Equity program contains four “cornerstones” that guide their work: “Focus on Equity, Align Staff and Students, Transform Teaching and Learning, and Leverage Funding and Policy.” The ICS Equity training program typically begins after a school district has undergone an ICS “equity audit” to discover the problems and inequities found in the schools. While it is unclear what officially triggers an equity audit, in many districts, this occurs after an incident of alleged racism or complaints are brought forward from a student or alumni.


ICS Equity in Practice – Perspective of an Educator who Participated in the Training

The MacIver Institute obtained a copy of the ICS training material from an anonymous source who sat through the entire program. ICS Equity’s comprehensive coaching walks a district that has “failed” their equity audit through a multi-step “equity framework and process.” There are thirteen modules that teachers and staff must complete, including “Know the History of Educational Marginalization,” “Realign Staff and Students,” “Design Identity Relevant Teaching and Learning,” and “Create Multi-Year Equity Action Plans.”

The ICS Equity program is not just an hour-long seminar that a few teachers and school administrators sit through once. The program is a multi-day session conducted over multiple years, including “​​meeting with the ICS Equity Coach, 75 minutes, 4 times per year for 3 years.” The session our source participated in had over 100 educators in attendance.

The training begins by saying, “What we know is that oppression and marginalization are historical, structural, cultural, and systemic. As a result of that fact, any equity changes we are trying to make must address the entire educational system, or requires what we term equity systems change.” This isn’t a discussion about the latest best practices or new tips on how to be a more effective teacher. This is about a complete and radical overhaul of how we teach our children and what we teach our children.

“Further, most equity work addresses only one aspect of inequities, such as culturally relevant pedagogy or developing culturally competent staff. Instead, leaders must learn how to transform the entire education system via Integrated Comprehensive Systems for Equity” (ICS Equity).

During the training, participants are taught how to create Equity Non-Negotiables based on the results of the equity audit conducted by ICS. As the MacIver Institute has previously reported, these Non-Negotiables have been appearing in school districts across the state. Equity Non-Negotiables or Equity Principles are guidelines for school districts to abide by, not open to interpretation or modification, that seem to commit the school district to focus on equity, Critical Race Theory (CRT), culturally responsive teaching, or one of the many euphemisms for CRT.

The ICS Equity framework for building Equity Non-Negotiables compares the current model with proposed improvements in the form of these Non-Negotiables. Some of the suggested Non-Negotiables include “the system is responsible for student failure” and “all staff are aligned to Co-Plan to Co-Serve to Co-Learn Teams (C3) to support cohesive instruction.” These Non-Negotiables are emphasized throughout the thirteen-module program.

Our source described the ICS Equity seminars as lacking open discussion or interaction. The “training” isn’t an honest and free-flowing conversation among education professionals about how they can improve education or share ideas on how to better reach children. The ICS Equity training makes these educators feel as though the way they have been teaching for all these years is wrong. The “system” they’ve taught within is the problem and it must be restructured in order to eliminate the inequities that exist. Those individuals that dared question the narrative being pushed were either ignored or called out. Our source even went so far as to call the training exhausting because of the length of the sessions, the repetition in each session, and the continual bashing of the system.

Maybe the biggest problem with the ICS Equity training is that many teachers do want real help, not CRT or indoctrination, to become better teachers. Teachers trust their administrators and DPI to supply them with the training they need to do their jobs effectively but now they are not receiving this help. And when DPI, school districts, and entities like ICS push dangerous and extremely biased information on staff, it is only natural that this trickles down into the classroom.


ICS in the Classroom

Many advocates for CRT — like ICS Equity and similar groups — claim that their work is only “teacher training” and that it is not actually leading to any substantial changes in the classroom. However, this is patently untrue. In many districts that have used ICS or similar consulting groups, significant changes have had a direct impact on student curriculum and outcomes.

Equity versus Equality

The driving goal behind the implementation of the ICS Equity program is equity — not equality — for all students. Equity is the opposite of equality. Americans have long enshrined the idea of equality and equal opportunity, believing that all people are created equal, with unalienable rights given to us by our creator. Equity, on the other hand, means everyone has the same outcomes, an idea rooted in communism, which is currently manifesting itself in America as Critical Race Theory.

To achieve equal outcomes, some districts — such as Middleton-Cross Plains or Madison Metropolitan Schools — have begun the process of eliminating grades. The Madison School District has made numerous changes to learning in the district, all in the name of CRT and equity. In their high schools, the lowest score you will receive on an assignment is a 50, even if you have earned a lower score than 50 or if you fail to turn in the assignment altogether. Most recently, a Madison high school student that fails will no longer receive an F, but instead will receive a “No Pass” which will not count towards their cumulative Grade Point Average (GPA). The District is also currently debating the elimination of honors classes, because of the “disparities in the demographics of standalone honors” classes.

In other districts, the implementation process looks different. Many districts across the state and country are moving to eliminate standardized tests. At the Wisconsin Public Education Network’s Summer Summit on August 2, 2021, the Sun Prairie School Board President, Dr. Steve Schroeder, shared that “Our school board a few months ago unanimously passed a resolution stating that we will move away from the almost exclusive use of standardized testing to assess student learning.” These are the kind of outcomes that CRT proponents are striving to create. 

Finally, the ICS Equity program itself has a direct impact on classroom curriculum. At Elmbrook Schools, one district linked with ICS Equity, in a Freshman Honors Biology class, students were given a presentation discussing race and identity. This presentation supposedly accompanies the students’ assigned reading of the book The Immortal Life of Henrietta Lacks. While the book itself does address biology and human cells, it is clear the focus of the accompanying presentation is on equity and race issues, rather than the science behind it.

Honors Biology Presentation in Elmbrook Schools

During the presentation, students are told to “Be aware of your language including microaggressions” because “the audience may include Persons of Color.” The teacher makes it clear “This is not about ‘being right’ but about shared understanding.”


Diving Deeper – Department of Public Instruction Parrots ICS

As many parents have discovered, Integrated Comprehensive Systems For Equity is not just a consulting firm that has been hired by a few dozen school districts across the state; their ideas are radical, infiltrating not just our public schools, but the Department of Public Instruction (DPI) as well.

As of September 2020, DPI has instituted a “Co-Teaching Practice Profile,” that contains “the essential attributes of an equitable cotaught learning environment, which is inclusive of each and every learner.” In this document, the Department of Public Instruction uses a definition straight from the ICS Equity guidebook and credits ICS Equity for the definition (see screenshot below).

Excerpt from WI Co-Teaching Practice Profile

That being said, ICS Equity principles are not just appearing in high-level DPI curriculum. One of ICS Equity’s co-founders, Dr. Elise Frattura, is a “Professor Emeritus” and a former Dean at the School of Education for UW Milwaukee. She has been an advisor for many Doctoral dissertations of educators across the state, using her role to influence even more educators in training.

One example of her reach appears in the dissertation “Difference Makers: A Multi-Case Study of the Conditions Under Which Superintendents Build Equitable Learning Environments to Support Black Students” by Nicole Jones, who now serves as the Director of Employment Services at New Berlin Schools. In this dissertation, on which Dr. Frattura was a committee member, Jones states that superintendent development programs should “focus on how superintendents might manage their board rather than being managed by their board in order to improve their ability to implement changes that are in the best interest of the student population.”

Jones’ dissertation also includes a definition for perseverance as “Willingness to continue their work to build equity in the face of community (parent, school board, teacher) pushback.” This should be alarming to parents: an educator is actually advocating that superintendents should try to work around or manage their duly elected boards.

Readers of MacIver will also recognize the name Dr. Decoteau Irby in Dr. Jones’ dissertation acknowledgments. Back in 2018, Irby spoke at the 34th Annual State Superintendent’s Conference on Special Education & Pupil Services with a presentation innocuously and academically titled, “Stuck Improving: Understanding Organizational Capacity for Equity-focused Improvement.”

Excerpt from Dr. Jones’ Dissertation


This is not the only example of a school administrator taking radical guidance from people like Frattura and Irby. The Mequon-Thiensville School District has recently attracted attention as four school board members are fighting against a potential recall. Their superintendent, Matthew Joynt, is a close acquaintance of ICS founder, Dr. Elise Frattura. Joynt’s dissertation, also written through UW Milwaukee, is titled “Motivation of School Board Members to Support Equity and Social Justice in Public Education.” Dr. Frattura was on this dissertation committee as well.

Joynt’s research looked at “the underlying motivations of school board members to support equity and social justice policy and initiatives.” Similar to Jones’ work, one of the takeaways from Joynt’s work is the importance of including the district superintendent in the School Board’s work. Joynt wrote that “the Board-Superintendent relationship is critical to the success of a school district, making it essential that the Board’s leadership team include the superintendent.”

While decisions made about a district should clearly involve that district’s superintendent, there is an important distinction between collaboration and a superintendent acting alone. As we have seen in districts across the state, there have been instances where the superintendent actually makes critical decisions for the district without even consulting the elected school board.


Questionable Curriculum: Critical Race Theory (Et Al) In Wisconsin – A Continuing Series

If you have additional tips or examples of CRT in the classroom that warrant investigation, please contact us at: