Which One of the Following Statements Concerning a Needs Assessment

Which one of the following statements concerning a needs assessment is NOT true?

A) The needs and/or program assessment is a useful tool for gathering data and support for program implementation.
B) The needs and/or program assessment often must be a creative tool developed in-house to meet the program's specific needs.
C) Given that the needs assessment may be developed in-house without the benefit of external validity, generalizing the results may be difficult.
D) Program planning is an essential step before needs assessment can be performed.