The Massachusetts Department of Elementary and Secondary Education (DESE) has circulated a draft Antisemitism and Societal Bias Prevention Curriculum and Professional Development Rubric [PDF] for public comment.

Guidance for Colleagues Completing the DESE Public Comment Survey

The Department of Elementary and Secondary Education (DESE) is collecting feedback on the Antisemitism and Societal Bias Prevention Curriculum and Professional Development Rubric through an online survey. The survey asks respondents to (1) rate each proposed criterion and (2) provide short written explanations and additional comments.

The example below reflects the analysis in this report and is offered as guidance for colleagues who wish to submit aligned feedback.

Survey link:
https://survey.alchemer.com/s3/8175442/Public-Comment-Antisemitism-and-Societal-Bias-Prevention-Curriculum-and-Professional-Development-Rubric

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Suggested ratings for the criteria table (Question 5)

When you reach the grid that asks you to choose “In support / Mixed support / In opposition / Neutral” for each criterion, you may wish to use the following pattern:

• Choose “Mixed support, with specific suggestions to change aspects of the language” for:
  • Materials align with the MA History and Social Science (HSS) Curriculum Framework
  • Materials address antisemitism within broader context of societal bias
  • Materials have students evaluate and analyze information and sources aligned with the expectations across the MA Curriculum Frameworks
  • Materials include helpful supports for educators
  • Professional development is aligned and meets the criteria for high quality
• Choose “In support of the proposed criteria” for:
  • Materials support students’ mental and emotional health and building healthy relationships in combatting antisemitism and societal bias
  • Materials include general elements of high‑quality curricula and are accessible for all students

Colleagues should, of course, adjust these if their own reading leads them to a different judgment.

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Example text for “Explain your rating(s)” (Question 6)

You can copy, shorten, or adapt language like this:

We support the overall intent of this rubric but have concerns about how several criteria are framed. The description of “societal bias” lists characteristics such as race, religion, disability, immigration status, sexual orientation, and gender identity, but omits national origin and ancestry, which are explicit protected classes under Massachusetts and federal civil‑rights law and are central to understanding antisemitism as discrimination based on shared ancestry and perceived national origin. Most school‑based antisemitism and anti‑Zionist hostility toward Jews and Israelis falls into those categories, not immigration status.

The rubric also defines antisemitism only as “general hatred towards Jewish individuals and communities” and does not reflect widely recognized frameworks, such as the IHRA working definition, that address contemporary manifestations including conspiracy theories, demonization, double standards, and certain forms of anti‑Zionism. In addition, the references to teaching about genocide and to analyzing “genocide and mass atrocities in the modern world” are extremely broad. Without guardrails, this risks legitimizing politicized accusations of “genocide” against Israel or Holocaust inversion in classroom materials, which are themselves forms of antisemitism.

Finally, while we agree that media literacy, educator supports, and professional development are important, the criteria do not require that materials and providers (1) adhere to a robust, contemporary definition of antisemitism, (2) treat Israel and Jewish peoplehood accurately, or (3) avoid BDS‑aligned and delegitimizing content. For these reasons, we selected “mixed support” for several criteria rather than full support.

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Example text for “Other comments” (Question 7)

For the final open‑response question, you might use something like:

We appreciate that the Department is taking antisemitism seriously and developing a rubric to guide curricula and professional development. To ensure that the rubric truly protects Jewish and Israeli‑heritage students, we encourage DESE to revise the draft so that it explicitly includes national origin and ancestry in its identity‑based categories; incorporates a more complete, contemporary definition of antisemitism (such as the IHRA framework); places clear limits on how the term “genocide” is used in relation to Israel and the Holocaust; and requires that curriculum materials, professional development providers, and listed resources treat Israel and Jewish peoplehood accurately and do not promote BDS or the delegitimization of Israel’s right to exist. With these changes, the rubric could become a strong tool for both Holocaust/genocide education and the prevention of antisemitism in Massachusetts schools.

These suggested survey responses are meant to give colleagues a clear and consistent way to participate in the public-comment process while reflecting the core concerns identified in this report. The survey itself is brief, but the issues raised by the draft rubric are not. What follows is a more detailed, structured analysis of the document—its omissions, its vulnerabilities, and the revisions we believe are essential. We encourage readers who plan to submit comments to review the full analysis below so their individual feedback can be informed by the broader policy implications we have identified.

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Full Analysis: Antisemitism and Societal Bias Prevention Curriculum and Professional Development Rubric

The document is presented as an implementation tool for a new state requirement to address antisemitism and “societal bias” in K–12 schools, and it is explicitly tied to Massachusetts curriculum frameworks in History and Social Science, Comprehensive Health and PE, Digital Literacy, and Safe and Supportive Schools.

At first glance, the rubric appears to support the kind of work we want to see: accurate teaching about antisemitism and genocide, better media literacy, and safer schools for students from minority communities. In the current climate, however—where antisemitism, anti‑Zionist agitation, and BDS activism are actively targeting educational spaces—several choices in this draft are not neutral. Taken together, they narrow the legal categories that protect Jewish and Israeli‑heritage students, blur or under‑define antisemitism, and leave space for hostile anti‑Israel narratives to be smuggled into curricula and professional development under a generic “anti‑bias” banner.

Our overall position is that the state is right to take antisemitism seriously and to create a rubric at all. But we cannot support the adoption of this draft in its present form. It should be amended so that its definitions match Massachusetts and federal civil‑rights law, its treatment of antisemitism matches contemporary realities and the IHRA framework, and its implementation channels are not handed to vendors and partners who have a record of delegitimizing Israel or marginalizing Jewish and Israeli‑heritage students.

Identity‑Based Bias, Immigration Status, and the Omission of National Origin and Ancestry

One of the most revealing sentences in the draft is the basic definition of “societal bias”:

Societal bias, or identity-based bias, includes antisemitism and relates to prejudice based on any person’s identity characteristics such as race, religion, disability, immigration status, sexual orientation, and gender identity.

This line claims to be describing bias “based on identity characteristics,” and the rubric elsewhere says it is informed by state and federal civil‑rights guidance. Yet the list it offers does not match Massachusetts law. The Commonwealth’s public accommodation law and anti‑discrimination statutes explicitly protect people from discrimination based on race, color, religious creed, national origin, gender identity, sexual orientation, disability, and ancestry, among other categories.

National origin and ancestry are missing from the rubric’s core description of identity‑based bias; “immigration status” is added instead. The document clearly knows the term national origin exists, since it appears later in a health‑education example about bullying. That makes its absence from the main definition more significant. In practice, antisemitism and anti‑Zionist hostility in schools are often directed at students because of their Jewish ancestry or their real or perceived Israeli or Middle Eastern national origin. Federal Title VI guidance explicitly treats discrimination based on race, color, or national origin as covering groups such as Jews when they are targeted for their shared ancestry or ethnic characteristics.

When a document that claims to be grounded in civil‑rights law talks about identity‑based bias but drops national origin and ancestry while introducing immigration status, it shifts the frame. It makes it easier to treat harassment of “Zionists,” “Israelis,” or “people like you” as merely political and not as bias based on protected characteristics. Any rubric addressing antisemitism and societal bias should explicitly name national origin and ancestry alongside race, religion, and the other categories protected under Massachusetts and federal law, and it should root its examples in that legal framework. Otherwise, the very categories that actually protect Jewish and Israeli‑heritage students are quietly down‑ranked at the definitional level.

The Use of “Genocide” in an Antisemitism Rubric

The draft tells school communities that, to counter antisemitism and societal bias, they should raise awareness of the origins, history, and effects of hate “including teaching about genocide,” and later requires students to “analyze the causes of genocide and mass atrocities in the modern world.”

There is an obvious, legitimate reason to link genocide to antisemitism: the Holocaust is the clearest historical example of what state‑sponsored antisemitism can produce, and our organization supports robust Holocaust and genocide education in every state. But in the present environment, the term “genocide” is also being weaponized against Israel. Activists routinely accuse Israel of genocide, and some educational spaces have normalized that claim without grounding it in international legal standards or serious historical scholarship. At the same time, IHRA‑aligned work and Jewish communal analyses identify “Holocaust inversion”—portraying Jews or Israel as Nazis or genocide perpetrators—as a contemporary form of antisemitism.

If genocide and “mass atrocities in the modern world” are raised inside an antisemitism rubric with no guardrails, it becomes easy for hostile PD providers or curriculum writers to smuggle in materials that equate Israel with Nazi Germany or place Israeli military actions alongside the worst genocides in history. That possibility is not theoretical; recent federal civil‑rights investigations into schools and universities have already been triggered by environments where Israel is portrayed as a uniquely evil or genocidal state and Jewish students are harassed in that context.

We want genocide and mass atrocities taught in this context, but we need the term used carefully. The rubric should specify that teaching about genocide must be grounded in recognized historical and legal definitions, not activist slogans, and it should explicitly identify Holocaust inversion and reckless “genocide” accusations against Israel as examples of antisemitism that schools must not endorse. Without this, the genocide language can be turned into another vehicle for anti‑Israel indoctrination under the cover of antisemitism education.

Definition of Antisemitism and the Omission of IHRA

The draft defines antisemitism as “commonly understood as general hatred towards Jewish individuals and communities.” This is a very thin definition. It describes an attitude but not behavior, and it says nothing about the specific forms antisemitism takes in the contemporary world: conspiracy theories, demonization, double standards, and attacks on the legitimacy of Jewish self‑determination in Israel.

The IHRA working definition of antisemitism has become the leading international standard, precisely because it couples a general definition with concrete, illustrative examples that include some forms of hostility to Israel when they cross over into treating Jews or the Jewish state with double standards, demonization, or collective blame. Our organization supports using IHRA or a substantively equivalent framework in educational policy because it allows schools to see clearly when anti‑Israel activity becomes antisemitic.

By avoiding any reference to IHRA and by defining antisemitism only as “general hatred,” the rubric gives administrators and vendors as much room as possible to treat even extreme anti‑Zionist rhetoric as “legitimate criticism of a country,” while still claiming to have addressed antisemitism. In a neutral setting, that might be just weak drafting; in this environment, it functions as a deliberate narrowing of the problem. DESE should either adopt IHRA explicitly or embed IHRA’s core elements, including examples that involve Israel, so that the definition of antisemitism actually matches the threats Jewish and Israeli‑heritage students are facing.

Antisemitism in a Generic Anti‑Bias Framework

Throughout the document, antisemitism is consistently folded into a broad “societal bias” and “anti‑bias” frame. The rubric emphasizes that it will be implemented through an anti‑bias lens, connecting antisemitism to racism, xenophobia, and other forms of identity‑based hate.

There is value in cross‑community work, but the way this is done matters. In many DEI and ethnic‑studies environments, Jews are racialized as “white” and privileged, while Israel is cast solely as a “settler‑colonial” project. Generic anti‑bias language is often used to marginalize antisemitism as less urgent than other forms of hate and to defend anti‑Israel activism as part of “liberation” work. By never distinguishing antisemitism as a distinct and uniquely persistent form of hatred, and by never naming anti‑Zionist and BDS‑related hostility as contemporary manifestations of antisemitism, the rubric allows implementers to treat antisemitism as an add‑on to existing DEI programming that remains structurally hostile to Israel and, by extension, to many Jewish students.

A stronger document would situate antisemitism within broader anti‑bias efforts but still recognize its unique patterns—historically and today. It would say plainly that, in the United States in 2024–25, antisemitism often appears in ostensibly “anti‑Zionist” or “anti‑Israel” forms, and that an antisemitism rubric must equip districts to recognize and address those forms, not just slurs and Holocaust denial.

Israel, Jewish Peoplehood, and Historical Framing

The rubric relies heavily on the Massachusetts History and Social Science Framework and highlights specific standards. Among them is a Grade 6 topic labelled “Ancient Israel, Palestine, c. 2000 BCE–70 CE,” and a high‑school standard calling on students to explain the background of Israel’s establishment in 1948 and subsequent military and political conflicts.

The combined effect of these references is concerning. Projecting the word “Palestine” back to 2000 BCE is anachronistic; the Roman renaming of the province came many centuries later. In today’s political context, this kind of phrasing aligns with efforts to blur or undermine Jewish indigeneity and present Jews as late‑arriving “settlers” in their own ancestral homeland. The 1948 and “subsequent conflicts” standard is, in itself, a reasonable topic, but the rubric places no constraints on how those events should be framed. There is no requirement that materials affirm Israel’s right to exist as the nation‑state of the Jewish people, no insistence on balanced presentation of facts, and no prohibition on using BDS‑aligned or “from the river to the sea” materials in the name of “decolonizing” the curriculum.

Combined with a silence about Jewish peoplehood and indigenous connection to the land of Israel, this creates room for districts and PD vendors to teach about Israel primarily through narratives that depict Zionism as inherently racist or colonial. Our organization should argue that a rubric on antisemitism must treat Jewish peoplehood and Israel accurately, that it should correct or at least contextualize anachronistic labels, and that it should require materials on Israel and its conflicts to be fact‑based, balanced, and explicitly non‑delegitimizing.

DEI Infrastructure, Media Literacy, and PD Vendors

The draft repeatedly instructs districts to implement the rubric through existing DEI‑aligned structures: Multi‑Tiered Systems of Support, Safe and Supportive Schools, WIDA English‑language standards, Comprehensive Health and PE, and DESE’s Culturally and Linguistically Sustaining Practices resources. It also calls for professional development that builds “sociocultural consciousness,” equips educators to “contextualize historical frames,” and encourages partnerships with community advocates and curriculum vendors.

In many systems, these are exactly the pipelines through which anti‑Israel and “decolonization” agendas enter K–12. The rubric does not require that PD providers avoid BDS advocacy, does not insist on adherence to IHRA, and does not set criteria for community partners beyond generic expertise. At the same time, the media‑literacy sections tell students to evaluate bias and credibility in sources and to analyze how media can misrepresent information, but never explicitly mention antisemitic propaganda, Holocaust denial, or anti‑Israel disinformation as priority content to recognize and reject.

In this configuration, the rubric functions more as a conduit than a guardrail. It channels implementation into a DEI and PD ecosystem that is already contested terrain, without any filters to keep out organizations and materials that portray Israel as illegitimate or cast Jewish identity as a problem. A safer approach would require that any provider or resource used to meet the rubric’s expectations be consistent with IHRA, refrain from BDS or similar campaigns, and demonstrate specific expertise in antisemitism and Holocaust education. It would also name antisemitic and anti‑Israel digital content as a distinct threat that media‑literacy instruction must tackle head‑on, rather than leaving that to inference.

Student Safety and Enforcement

Finally, the rubric acknowledges that schools have legal obligations to prevent and address hate and bias incidents, but it does not explain what those obligations are, how they intersect with Title VI and state anti‑discrimination law, or what Jewish and Israeli‑heritage students should expect when they report antisemitic harassment.

In an era when the U.S. Department of Education is opening Title VI investigations into school systems that fail to protect Jewish students, this silence is notable. A rubric that allows districts to claim they have antisemitism curricula and PD in place, but that never spells out how students can seek redress when the environment becomes hostile, risks becoming a shield rather than a tool.

Conclusion

The draft Antisemitism and Societal Bias Prevention Curriculum and Professional Development Rubric arrives at a time when Jewish and Israeli‑heritage students in Massachusetts and across the country are facing a surge of hostility that blends old antisemitic tropes with new anti‑Zionist campaigns. In that setting, we cannot treat definitional choices and omissions as neutral. A rubric that downplays national origin and ancestry, defines antisemitism only as “general hatred,” invokes genocide without safeguards, and channels implementation through unfiltered DEI and PD pipelines is structurally vulnerable to being turned against the very students it claims to protect.

While ICAN welcomes the state’s willingness to address antisemitism in schools, we oppose the adoption of this draft unless it is substantially revised. At minimum, the document should align its identity‑based categories with Massachusetts and federal law, adopt or closely track IHRA in defining antisemitism, constrain the way “genocide” and Holocaust analogies can be used in relation to Israel, protect Israel‑related content from ideological capture, and set real criteria for PD providers, community partners, and resources so that antisemitism is not reintroduced through a back door.