President Reagan's comments on education are a perfect example of the failure of America's schools. He commits logical fallacies, makes assertions without supporting facts and cites examples that do not support his point. Were his teachers still at their blackboards today, they would be ineligible for merit pay.

At his press conference and his graduation speech at Seton Hall University last month, the president posited this syllogism: Federal funds for education have increased. Test scores have declined. Ergo, the one must have caused the other. Twenty-five points off for this logical fallacy.

The declining test scores Reagan cites are those on the Scholastic Aptitude Test, the exam taken by college applicants. He conveniently ignores the rising scores of elementary students, notably black students, as measured by the National Assessment of Educational Progress. During the 1970s, black fourth-graders made substantial gains in reading and math, while their white classmates registered lower gains in reading and a decline in math scores. Black eighth-graders also showed a greater rate of improvement in reading and math than did their white counterparts. Overall, these achievement gains by black students had the positive effect of closing the gap between black students' scores and the national average scores.

Many observers credit these results to the $3 billion annual federal investment in compensatory education (formerly Title I, now Chapter I), to the Right-to-Read effort and to state compensatory education programs. But we should not commit the same error of logic as the president, coming to the opposite conclusion: that large federal expenditures have increased test scores. There is no solid, empirical evidence directly linking cause and effect. However, there is some strongly suggestive evidence.

* The strongest gains in achievement during the 1970s were in the lowest performance quartile, precisely the students for whom Title I funds are designated.

* The National Assessment shows the greatest improvements in reading, rather than math and science, a reflection perhaps of the fact that most compensatory money has gone into remedial reading.

* Rising test results have been reported by inner-city schools, the very ones to which Title I funds are targeted.

* Evaluations showing Title I students out- performing non-Title I students independently corroborate findings of the National Assessment.

President Reagan is most critical of high schools. He then asserts that the old solution-- money--has been tried but "it failed." Twenty- five points off for an unsupported assertion.

In fact, the greatest bulk of federal education funds goes to elementary and higher education. According to the Congressional Budget Office, 34 percent of federal education expenditures in fiscal year 1979 was directed to elementary students, 12 percent to secondary students and 54 percent to post-secondary students. If high schools are the weakest link in the education system, federal money is not to blame.

The president's solutions for the deficiencies of our educational system are more local control and greater parental responsibility. As an example of the first, he cited an Austin, Texas, high school that had been reformed by its principal, with assistance from a desegregation order and an infusion of federal Emergency School Aid Act money, a program that the administration and Congress eliminated two years ago. Minus 10 points for an example that contradicts the main argument.

As for parental responsibility, federal education law has done more than local policy to give some parents genuine control over their children's education. Title I legally sanctioned parent councils to advise school officials on the educational program for disadvantaged children. The Education for All Handicapped Children Act gives parents of disabled students the right to participate in, and contest if necessary, educational decisions made about their own children. For these parents, local responsibility has been a code word for no say at all.

Reagan's response to the rising clamor for educational excellence is prayer in public schools and tax subsidies for private schools. He has yet to explain how these federal policies will assist educators, parents and businessmen in reconstructing America's public schools to meet the current challenge. We do need a national debate about how to improve education and what role the federal government might play. But let that debate be based on facts, not myths and distortions.