Integrated Comprehensive Systems for Equity (ICS) is a left-of-center consulting firm focused on providing diversity, equity, and inclusion (DEI) and critical race theory-inspired services to public school districts. The firm was founded by Colleen Capper and Elise Frattura, both former professors of education within the University of Wisconsin system. Much of the firm’s work has involved providing “equity audits” for public school districts, with many of the firm’s clients being located in the founders’ home state of Wisconsin. The firm also provides training, guidance, and hosts conferences for school system administrators and state education officials and has demonstrated particular influence within the Wisconsin state Department of Public Instruction. ^{1 2 3}

The firm has also drawn criticism from right-leaning groups including Parents Defending Education and the MacIver Institute for promoting left-of-center ideology within Wisconsin school systems. ^{4 5}

Background

Integrated Comprehensive Systems for Equity (ICS) was founded in 2015 according to Wisconsin state business records. The company remained dormant for several years thereafter until it was reinstated with the state as an active company in 2018. The firm was founded by Elise Frattura, a former professor at the University of Wisconsin-Milwaukee who was an associate dean and department chair in the college’s school of education, and Colleen Capper, a former professor at the University of Wisconsin-Madison within the department of educational leadership and policy analysis. Both women have a background in academic research related to social justice, racial equity, and education. ^{6 7 8}

ICS offers several training programs for school district administrators, teachers, and school board members, among others. The firm’s flagship ICS Institute training program calls for participants to implement the firm’s trademarked “Integrated Comprehensive Systems for Equity” framework and to engage in a “deep equity analysis” of the school district, region, or state as well as completing the “ICS Action Plan” for the school to “advance systems change for all.” Participants in such trainings include the school principal, a general education teacher from each grade level, special education teachers, gifted-and-talented program teachers, and English as a second language (ESL) teachers. ⁹

Criticism

Integrated Comprehensive Systems for Equity (ICS) has drawn criticism as one of many left-of-center diversity consultancies that promote critical race theory-inspired ideologies within public school systems. As its founders and many clients are Wisconsin-based, the firm has been investigated by the right-leaning Wisconsin-based MacIver Institute, which criticized the groups use of “equity audits” to guide school districts through its racial “equity framework and process.” The MacIver Institute reported that the firm’s “equity non-negotiables” have appeared in school districts throughout Wisconsin as principles that the school district cannot modify or compromise on. These non-negotiables direct the school towards critical race theory-inspired principles. Some of the firm’s 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.” ¹⁰

Parents Defending Education, a right-of-center educational advocacy organization, filed a federal civil rights complaint within the U.S. Department of Education’s Office of Civil Rights against the school system in Hudson, Wisconsin, alleging that the ICS’s equity audit for the school system should lead to an investigation due to the firm’s audit alleging that “systemic” racism exists within the school system. Parents Defending Education contended in its complaint that if such allegations of systemic racism are accurate, they constitute a civil rights violation worthy of federal investigation or intervention. ¹¹

1. Questionable Curriculum: Why You Should Be Concerned About ICS Equity Promoting CRT in Your Schools.” MacIver Institute. Accessed May 19, 2022. https://www.maciverinstitute.com/2021/09/questionable-curriculum-why-you-should-be-concerned-about-ics-promoting-crt-in-your-schools/
2. “OCR Complaint: Hudson School District.” Parents Defending Education. Accessed May 19, 2022. https://defendinged.org/complaints/ocr-complaint-hudson-school-district/
3. “About.” Integrated Comprehensive Systems for Equity. Accessed May 19, 2022. https://www.icsequity.org/about
4. “Parents Defending Education US Department of Education Office of Civil Rights Complaint.” May 16, 2022. Accessed May 19, 2022. https://defendinged.org/wp-content/uploads/2022/05/Hudson-School-District_v2.pdf
5. “Questionable Curriculum: Why You Should Be Concerned About ICS Equity Promoting CRT in Your Schools.” MacIver Institute. Accessed May 19, 2022. https://www.maciverinstitute.com/2021/09/questionable-curriculum-why-you-should-be-concerned-about-ics-promoting-crt-in-your-schools/
6. “Integrated Comprehensive Systems for Equity.” Wisconsin Corporate Records Search. Accessed May 19, 2022. https://www.wdfi.org/apps/corpsearch/Details.aspx?entityID=I030285&hash=1687504623&searchFunctionID=931e3745-219d-4f72-a985-eb4c252b90f5&type=Simple&q=integrated+comprehensive+systems
7. “Colleen A. Capper.” Integrated Comprehensive Systems for Equity. Accessed May 19, 2022. https://www.icsequity.org/people/colleen-a-capper
8. “Elise Frattura.” Integrated Comprehensive Systems for Equity. Accessed May 19, 2022. https://www.icsequity.org/people/elise-frattura
9. “ICS Institute Part 1.” Integrated Comprehensive Systems for Equity. Accessed May 19, 2022. https://www.icsequity.org/services/institute-part-1
10. “Questionable Curriculum: Why You Should Be Concerned About ICS Equity Promoting CRT in Your Schools.” MacIver Institute. Accessed May 19, 2022. https://www.maciverinstitute.com/2021/09/questionable-curriculum-why-you-should-be-concerned-about-ics-promoting-crt-in-your-schools/
11. “Parents Defending Education US Department of Education Office of Civil Rights Complaint.” May 16, 2022. Accessed May 19, 2022. https://defendinged.org/wp-content/uploads/2022/05/Hudson-School-District_v2.pdf