Summary

Developed during a different industrial era, today’s education system was never designed to meet modern learners’ needs. This incongruity has heaped systemic problems upon individual educators, blunted the effectiveness of reforms, and shortchanged the nation’s most vulnerable young people — outcomes exposed and exacerbated by COVID-19. Building back better in a post-pandemic United States will require federal investments not only in schools, but in “learning ecosystems” that leverage and connect the assets of entire communities. Tasked with studying, seeding, and scaling these ecosystems in communities across the country, a White House Initiative on Community Learning Ecosystems would signal a shift toward a new education model, positioning the United States as a global leader in learning.

The surge in education technology use in response to COVID-19 represents a massive natural experiment: an opportunity to learn what works at scale, for which students, and under which conditions. However, without the right data standards in place we risk incomplete or inaccurate inferences from this experiment.

The COVID-19 pandemic has dramatically increased use of educational technologies. There is evidence that this “emergency onlining” will lead to learning loss, especially among underserved communities. To understand and address the extent of learning loss—as well as to explore and support potential future uses of educational technologies—the U.S. Department of Education (ED) must systematically implement established open-data standards that allow us to understand how students engage with learning technologies. Widescale implementation of these standards will make it possible to combine and analyze validated data sets generated by multiple technologies. This in turn will provide unprecedented, on-demand reporting and research capabilities that can be used to precisely identify gaps and create targeted interventions. Specifically, we recommend that ED mandate the use of the open Experience API (xAPI) standard for educational technology purchased with federal funds. We further recommend that ED invest time, talent, and resources to further develop this standard and pilot efforts to leverage educational-technology data for insights through the Institute for Education Sciences (IES) and other agencies.

Challenge and Opportunity

The COVID-19 pandemic rapidly forced schools across the country to close physical campuses and convert all instruction to an “emergency online” modality for much of 2020. The situation will likely persist well into 2021. The emergency shift to online teaching meant that many teachers had insufficient preparation to successfully adapt classroom-teaching methods for digital formats. Moreover, many students—especially those from low-income families or from historically underserved racial and ethnic groups—lack access to high-speed broadband and technology assets needed to fully participate in online learning. These factors are combining to create learning losses that exacerbate our existing digital divides that may persist for years.

Robust educational research and development is needed to fully understand the extent and distribution of learning loss, as well as to develop interventions for addressing it. Educational technologies—which record all student interactions, from logins to mouse-clicks to assignment submissions—could provide a wealth of data on how online education is succeeding and/or falling short. Unfortunately, these data are frequently recorded in a way that is unique to each application. This lack of consistency makes it difficult to integrate educational data or make comparisons between institutions

The time is ripe to introduce new requirements for learning technology designed to ensure that parents, educators, administrators, and stakeholders at every level can assess where students are at, what they know, and what will best help them to advance. These insights could also significantly reduce the day-to-day demands on teachers’ time and attention, enabling them to focus on deeper student questions. The technology needed to implement such requirements are already available in the open-source xAPI standard, which is currently in the final stages of approval as an IEEE standard. Further, there are xAPI “profiles” that define specific data requirements for processes common to educational technologies, such as playing a video. While the concept of a learning-data standard was recommended by ED as early as 2015, adoption has been uneven in practice. This situation must change for us to immediately address COVID19 learning loss as quickly and accurately as possible.

Plan of Action

To address the challenges outlined above, we recommend including xAPI as a federal procurement requirement to encourage adoption among educational software and service providers. Widespread adoption will mean that most—if not ultimately all—providers consistently and automatically generate only the educational data that conforms to standards established by ED. Establishing consistent standards for educational data will make it easier for all parties to contribute meaningfully to key datasets, and for researchers to develop tools to track and exchange meaningful data. These outcomes together will deliver deeper understandings of how our nation’s students are doing, inform efforts to close achievement gaps, and facilitate tracking of changes over time. We also recommend investing ED time, talent, and resources into further developing the xAPI standard and participating in pilot projects that demonstrate its utility. Each of these recommendations is detailed further below.

Recommendation 1. Mandate use of the xAPI standard for ED-funded procurement.

We recommend that ED mandate use of xAPI for all educational technology purchased through ED directly as well as through federal grants. ED should also establish a process for ensuring compliance, including conducting conformance tests on educational software and services from different providers.

The IEEE is in the final stages of publishing the open-source xAPI standard. Mandating its adoption would demonstrate cutting-edge ED leadership. Widespread adoption of the standard will provide a common approach to collecting evidence about how students, parents, and teachers interact with education platforms, paving the way for much more rigorous, consistent, and reliable educational research.

Recommendation 2. Develop xAPI profiles to facilitate data integration and improve data quality for the educational sector.

IEEE is standardizing documents that help automate the data governance needs for a type of educational solution (“application profiles”). Standards developers are rarely familiar with learning sciences and educational research. As a result, xAPI profiles will tend to be general in nature unless domain-specific experts get involved. For instance, medical experts have worked to develop the MedBiquitious xAPI Profiles for Medical Education. Human-resources experts have developed the Human Resources Open Standards (HROS) xAPI Profile and, and work is ongoing for an Assessment xAPI Profile that supports the U.S. Chamber of Commerce T3 initiative.

ED should invest time, talent, and funding to develop xAPI profiles that are aligned with current research and national priorities. An xAPI Profile effort could help to normalize data collection from a spate of popular 5th grade mobile math applications, that properly identify the relevant ED standards, competencies or objectives are challenged by a student, which could provide such app developers with the automation that would simplify generating better, aligned data. Works like this could change online classrooms into opportunities to embed better pedagogy into practice at scale.

Recommendation 3. Invest in applied research and development.

ED should partner with schools and educational technology companies to invest in applied research that demonstrates insights from standardized educational data. ED should also work with partners to invest in public repositories of code to make it easier for all stakeholders to leverage insights. Such investments should focus both on the short term (e.g., providing immediate insights about use of educational technology and learning loss during the COVID-19 pandemic) and long term (e.g., providing examples of potential applications that could be scaled and replicated in the future). Such investments would not only advance our understanding of education, but would also help to develop a market for further development of data-based educational products. IES and ED’s Office of Educational Technology should partner to identify topics and approaches to conduct this cutting-edge research.

There are multiple examples of research using educational-process data that these investments could build on. IES recently issued a request for proposals (RFP) to use National Assessment of Educational Progress (NAEP) process data to identify students with disabilities, to understand how those student use available accommodations, and to determine which are most successful. Predictive models of student dropout risk, course design analytics to identify areas for improvement, and course-taking patterns are all being conducting using this data at relatively small scale through academic societies, such as the Society for Learning Analytics Research (SoLAR) and the International Educational Data Mining Society. All stand to benefit and leverage this data to dramatically improve research.

SoLAR recently published a position paper describing current challenges with these data.4 Larger educational-research societies such as the American Educational Research Association (AERA) and the National Council on Measurement in Education (NCME) have launched specialized groups focused on working with educational-process data.

By investing in this area, ED could help to nurture this area of research and make a difference in the lives of students, parents, teachers and schools across the country. This approach would help to motivate better data quality and enable technologists to build more robust learning applications, thereby helping us to stem the COVID-19 learning loss as quickly as possible using contemporary science and technology.

The Biden-Harris Administration is committed to providing the best possible education to all students. Research has established that students of color experience benefits to social and emotional development and learning outcomes when taught by educators of color. Diverse educators and administrators are particularly important for schools with many students of color. Accordingly, schools across the country should prioritize hiring highly-effective teachers of color. This policy proposal identifies opportunities to recruit—and retain—highly effective K-12 educators of color.

As a first step, the Biden-Harris Administration should create an Under Secretary of Diversity at the Department of Education (ED), charged with organizing a White House Summit to establish the value of a diverse teacher workforce and convene leaders to identify best practices and a strategy for Federal Government support of state, local, and private programs. Following the summit, ED, led by the Under Secretary of Diversity, should revisit current programs that identify high need areas, such as math, science and special education to include the pressing need for diverse educators. Simultaneously, the administration must work with Congress to reauthorize the Higher Education Act, incorporating the previously introduced College Transparency Act to ensure robust data reporting and evaluate the effectiveness of financial incentives.

Challenge and Opportunity

A sense of belonging is widely accepted to be a basic human desire. Academic success can be heavily impacted by a sense of belonging in one’s academic environment. For students who do not feel that they belong, it can affect their mental and physical health, and future criminal activity. Schools have at least four racialized areas potentially affected by teacher composition: content, teaching methods, feedback type, and disciplinary practices. Teachers of color are one piece of the solution. Recognizing similarities between shared attributes and/or social identities of themselves and their teachers, connecting with people they can trust and be open with can help support a sense of belonging, which is critical to academic success.

Even as the demographics of the United States continue to shift, the teacher workforce remains overwhelmingly white, leading to a demand for teachers of color that far outweighs the supply. While certain states have had some success recruiting more teachers of color, individuals pursuing teaching careers face significant obstacles, causing many to leave the profession earlier than their white colleagues. For many first-generation students and students of color, the path to a profession in teaching can be perilous, with unsustainable wages and work conditions. Some federal programs designed to help teachers manage student debt and continue teaching have failed the very people who our students need to stay in the profession. The COVID-19 pandemic has only exacerbated current inequalities in educational outcomes, presenting additional challenges to all teachers, and particularly teachers of color.

Anecdotal evidence suggests that college students are very interested in teaching but lack supported pathways and incentives to pursue a career in the field. Many passionate and talented state, local, and private leaders are working to support highly effective teachers of color, and a strong evidence base shows the potential for successful small-scale programs. However, programs and successes are inconsistent and piecemeal across the country. The Biden-Harris Administration should build on these opportunities to create a strong federal infrastructure that establishes teaching career pathways and supports teachers of color in the classroom.

The success of our country in meeting the needs of the future STEM workforce and productive labor market will depend on our ability to effectively educate a diverse population. Technology is the future—and the present. In STEM and other core workforce areas, the United States is trailing behind other industrialized nations. As the workforce of the future continues to evolve, we need to prepare our students. In our memo, we involve the National Science Foundation (NSF) and the National Institutes of Health (NIH), as they, along with the Department of Education (ED), will want to prioritize the workforce of the future—ensuring that the United States is once again leading the world in breakthroughs in science and technology.

Plan of Action

On Day One, the incoming Secretary of Education should: 

Appoint an Under Secretary of Diversity, ED

On Day One, the Biden-Harris Administration should create a new leadership position at ED, an Under Secretary of Diversity. This individual will serve the role of a Chief Diversity Officer, tasked with examining the role of race at the agency, in curricula, teacher preparation and development, and in school and district leadership nationwide, and with ensuring that national education initiatives are inclusive and actively anti-racist. Once in place, the Under Secretary will launch a White House summit, revisit existing programs and practices at ED to increase support for highly effective teachers of color, and support passage of critical legislation.

Launch a White House Summit on how to recruit and retain a highly effective, diverse teacher workforce.

The Biden-Harris Administration should develop an interagency working group to coordinate efforts between ED, NSF, NIH, and the National Science and Technology Council (NSTC), as well as education funders and business leaders who have named teacher diversity as a clear priority, to convene leaders who have been successful in finding, developing, and retaining educators of color. This effort would be led by the Under Secretary of Diversity at ED and the Assistant Director for the Education and Human Resources Directorate at NSF.

A White House convening would establish that delivering the best education to students of color is a national priority. The broad goal would be to quickly generate new ideas and learn from best practices toward the goal of establishing a teacher workforce that mirrors the diversity of the American student population. The more specific goals would be:

• Identify early pathways for students of color to consider careers in education, beginning in high school.
• Increase the inclusion of minority teachers in federal task forces, advisory committees, and policy settings.
• Support effective, innovative traditional and alternative-certification models that ensure recruitment and retention of candidates of color.

The Department of Education should prioritize supporting highly effective teachers of color.

ED should revisit current programs to include diverse educators in the requirements for high-need areas. The department currently provides incentives for states and school districts to hire and for individuals to pursue teaching. A comprehensive plan to substantially increase the diversity of educators must also consider retention and the professional experience after training. ED should promote retention by providing incentives for school districts to hire cohorts of diverse educators in order to reduce isolation and provide support. A “best-practices” grant program to ensure deep investment in programming also warrants renewed attention.

ED should:

• Rebuild the Office of Civil Rights (OCR). Under the leadership of Betsy DeVos, without opportunity for public comment, OCR altered procedures, allowing the office to dismiss hundreds of civil rights complaints, disregarding ‘burdensome’ cases. These procedural changes should be reversed. Additionally, the office should ensure all data collection returns to 2016 levels of collection and rigor, including restoring special reports—such as the discipline report and the education equity report—to regular reporting levels.
• Issue a “Dear Colleague” letter to establish that supporting the recruitment and retention of diverse, highly qualified teachers is an agency priority. The agency should promote all federal programs available to aspiring and new teachers and amplify potential uses of Title I, II, and IV. Additionally, it should increase support to districts, including providing technical assistance and webinars.
• Immediately restore federal loan forgiveness for teachers. ED should expand the definition of Nationwide Teacher Shortage areas: districts should be enabled to consider the demand for culturally-competent educators in highly diverse schools, enabling teachers meeting these high-need categories to benefit from cancellation of up to 100 percent of Federal Perkins Loans, and other benefits.12 It should also simplify recertification requirements and reduce penalties for the Teacher Education Assistance for College and Higher Education (TEACH) Grant Program.
• Enhance the Support Effective Educator Development and Teacher Quality Partnership Program. The Office of Elementary and Secondary Education should launch a grant competition designed to retain high quality teachers of color, including proposals to hire cohorts of teachers of color. The Department should double the current budget of these programs, given growing concerns about increased teacher shortages following the pandemic.
• Increase diversity within education research, including among its leadership. The Institute of Education Sciences (IES) should increase diversity of researchers, peer reviewers, and programs supporting researcher development and early career scholars of color. Relatedly, the President should appoint diverse members of the Board of Education Sciences. Increase rigor of review and add accountability to states education plans. This should include efforts to effectively support students of color and provide technical assistance to support state success. ED should update federal guidance for the use of Title Funding to support a diverse, highly-effective teacher pipeline. This should include residency programs and support for colleges and universities graduating effective teachers to high-need districts supported with Title I funding.
• Ensure that federal funding for “grow-your-own” programs is widely distributed. This initiative should particularly encourage partnerships with programs that have a track record of recruiting and retaining (beyond 5 teaching years) successful, diverse, and effective teachers. A growing body of scholarship is establishing the value of recruiting people from local communities that could successfully transition as teachers.

Urge Congress to Reauthorize the Higher Education Act (HEA), incorporating the previously proposed College Transparency Act (CTA).

Sustained federal investment in achieving diversity of K-12 educators that align with the diversity of our students will lead to improved social and emotional development and learning outcomes of our diverse population. CTA legislation is needed to enable the National Center for Education Statistics (NCES) to develop and maintain a secure, privacy-protected postsecondary student-level data system in order to accurately evaluate student enrollment patterns, progression, completion, and post collegiate outcomes, as well as higher education costs and financial aid. The Higher Education Act should be reauthorized to expand access, improve affordability, and promote completion for all students, including prospective teachers of color. Reauthorization should include critical protections for the Public Service Loan Forgiveness program.

Summary

Never before have so many children in America used so much educational technology, and never before has it been so important to ensure that these technologies are secure. Currently, however, school administrators are overburdened with complex security considerations that make it challenging for them to keep student data secure. The educational technologies now common in America’s physical and virtual classrooms should meet security standards designed to protect its students. As a civil rights agency, the Department of Education has a responsibility to lead a coordinated approach to ensuring a baseline of security for all students in the American education system.

This policy initiative will support America’s students and schools at a time when educational experiences—and student information—are increasingly online and vulnerable to exploitation. The plan of action outlined below includes a new Department of Education educational technology security rule, training support for schools, a voluntary technology self-certification system, an online registry of certified technologies to help grow a secure educational technology market, and processes for industry support and collaboration in this work. Combined, these efforts will create a safer digital learning environment for the nation’s students and a more robust educational technology marketplace.

Summary

The Biden-Harris Administration should create a plan for a public, online platform to connect teachers with college students and recent graduates to serve as tutors for K-12 students. One-on-one tutoring is a proven intervention that improves children’s educational competencies and increases students’ self-confidence. Along with supporting students, this platform could provide needed employment for young adults and enable teachers and students together to produce improved educational outcomes. The COVID-19 pandemic has led to the closure of more than 124,000 schools with the majority of students now learning online. Meanwhile, millions of college students have lost part-time work or are graduating into a historically difficult job market that does not have positions for them to fill. Just as the New Deal created work programs that both created employment and improved our national landscape, our country requires creative solutions that can meet the urgent needs of our time, can be quickly scaled up using modern technology and can adjust to the changing needs dictated by the cycles of the coronavirus.

Summary

Addressing inequality, closing achievement gaps, and tackling opportunity gaps in schools requires a highly effective educator in every classroom, a diversified teacher workforce, and an implementation of culturally responsive policies and practices. The 2015 Every Student Succeeds Act (ESSA) requires State Education Agencies (SEA) to identify and close gaps in equitable access to effective teachers but does not offer specific definitions about what constitutes teacher effectiveness. There is an opportunity to build on state equity plans and collaboratively work with districts, schools, educator preparation programs, and other stakeholders to close the gap in access to effective educators, diversify the workforce, and ensure that the training of educators includes a focus on culturally proficient practices.

The homework gap—which refers to the divide between students who have home access to the technology tools necessary for education versus those without—has existed for decades.

The next administration should maximize the use of all available policy tools to close the homework gap and keep it closed. First, the Federal Communications Commission (FCC) should update the existing E-rate program to allow schools to ensure home access to broadband for every student and teacher (Pre-K to Grade 12). Second, the FCC, in coordination with the Department of Education, should launch a one-to-one device program for students and teachers (Pre-K to Grade 12). Third, the FCC should incentivize the deployment of “future-proof” networks that are capable of at least 100/100 mbps to meet the needs of distance learning. Fourth and finally, the FCC should provide schools and states clear guidance on the key data needed to assess their homework gap and include this data in a public facing dashboard for broader stakeholder analysis.

Challenge and Opportunity

The homework gap—which refers to the divide between students who have home access to the technology tools necessary for education versus those without—has existed for decades.

At the start of the pandemic, 55 million students were sent home due to school closures and school districts initiated large-scale distance learning efforts. However, an estimated 16 million students and 400,000 teachers lacked access to an adequate home broadband connection or device needed to effectively engage in distance learning. Recent reports find that the homework gap disproportionately impacts lower-income and minority students. For these students in the homework gap, some schools—striving to continue any form of education—began to offer paper packets. Others opted to close early for the year, understanding that if they proceeded with a distance learning program without addressing the homework gap, they would further exacerbate existing inequities in education. The pandemic has forced our nation to see the consequences of the homework gap in real time. Educational and economic experts connect the disruption in access to education to learning loss, which negatively impacts childrens’ long-term economic well-being and the U.S. economy as a whole. Of course, it is worth underlining the fact that a pandemic is not the only reason schools have been closed in recent years as the effects of climate change, including extreme heat, wildfires, flooding, hurricanes, and tornadoes, have all caused extended disruptions to in-school instruction, and will continue to in the future. It is incumbent on policymakers to support school efforts to nimbly shift to distance learning when needed.

While policymakers have made progress on this issue by focusing on connecting and resourcing anchor institutions, such as schools, libraries and other community-based organizations, efforts to date have largely focused on providing students in the homework gap with an alternative public resource outside of the home. While some of these outside supports have their own benefits (e.g. trained staff, access to printers) they force students in need of access to remain outside of the home after school hours. For a family with limited time and resources, shuttling to and from various public computing centers (e.g. libraries, community-based organizations) cuts into work hours and requires additional funds for transportation. Even when these public resources are known to be available, teachers avoid assigning homework that may require heavy use of the internet because of the lack of home access to broadband for students. With years of institutional connectivity investments in place, anchor institutions are well positioned to help close the homework gap at home for teachers and students alike, once and for all.

In Congress, several bills (See HEROES Act and Emergency Educational Connections Act) have been introduced to fund the homework gap and to be administered through the FCC’s E-rate program, indicating that significant support exists to bolster the FCC’s current commitment to ensure connectivity for schools also extends to students with both funding and necessary updates to relevant statutes.

Prioritizing the resilient delivery of education and supporting equitable access to education by closing the homework gap helps to shelter our nation’s students in times of crisis and helps to ensure that all students have an opportunity to thrive when times are calm.

Plan of Action

E-rate

The FCC should update the existing E-rate program to clarify that the program will support schools to ensure home access to broadband for every student and teacher (Pre-K to Grade 12). The E-rate program is well known to schools, libraries and community-based organizations who are already working to address the homework gap. Since the start of the pandemic, states and schools have quickly built programs to try to cover the homework gap for as many students as possible. Without reliable funding these initiatives are at risk of ending, pushing students back into the homework gap. Ensuring reliable funding depends both on Congress doing its part to legislate and commit necessary funds, as well as the FCC to modernize the E-rate program to better serve the educational needs of students and robustly support home broadband access.

Because the FCC has E-Rate as an existing program that schools already work with on connectivity, expanding E-rate to also coordinate funding for student devices is efficient, schoolfriendly, and common-sense policy. Separating the device component of the homework gap to a new program would slow down delivery of support and require schools to navigate additional and a potentially new administrative process. The FCC should collaborate with Department of Education (ED) and Bureau of Indian Education (BIE) to ensure that both the device and connectivity components of a support program meet the needs of students and educators.

Connectivity

The FCC should

• Allow schools to use E-rate funded networks to support innovative programs to deliver home broadband access to students.
• Allow E-rate funds to pay for home broadband subscriptions for students.
• Allow for consortia and bulk purchasing.
• Extend rules around pricing transparency to funds used for home broadband subscription for students and publish pricing information on the FCC website.

Devices

The FCC, in coordination with ED and BIE, should launch a one-to-one device program to

• Ensure access to developmentally appropriate devices for students and teachers (Pre-K to Grade 12), as well as supplying the kind of equipment necessary for high quality STEM learning opportunities and equitable STEM education broadly.
• Develop a joint taskforce with Department of Commerce, ED, and BIE to address supply chain constraints for devices, ensure that the educational market is prioritized, require transparency in pricing and publish pricing information on the FCC website

Infrastructure Upgrades and Deployment

The FCC should incentivize deployment of “future-proof” networks—capable of at least 100/100 mbps— that can meet the needs of distance learning. Distance learning efforts since March have revealed that even if the cost of a monthly broadband subscription could be addressed, many students still lack access to a broadband service capable of delivering a synchronous distance learning program (at least 200/10 mbps). The FCC should

• Ensure that supported networks are able to deliver synchronous distance learning programs where the FCC provides funding for broadband infrastructure deployment.
• Prioritize infrastructure upgrades and deployment in areas that have broadband service of 25/25 mbps or less. Review rules, regulations and guidance from the FCC to encourage community broadband projects and other forms of public/private partnerships to apply for infrastructure funding.
• Encourage open access of funded infrastructure.

Supporting School-level Assessments

To ensure these programs continue to serve schools and students effectively, the FCC should provide schools and states clear guidance on the key data needed to assess the current state of the “Homework Gap” and include this data in a public facing dashboard for broader stakeholder analysis. Schools across the country have already begun to assess the homework gap in their own districts down to the address level and plan to continue these assessments periodically. The Administration should also encourage these efforts by launching a national homework gap mapping project to assess gaps. The FCC should encourage data collection on

• Broadband service availability
• Broadband service speeds
• Quality of broadband service
• Service providers available
• Needs for IT support (for both students/caregivers and teachers)
• Needs for digital literacy support (for both students/caregivers and teachers)
• Location information (while remaining FERPA compliant)
• Demographic information
• Language(s) primarily spoken

Conclusion

The FCC should modernize and expand its approach to closing the homework gap. Students, parents, and teachers need the federal government to step up and commit to a historic effort to ensure poor Internet access is no longer a systemic barrier in our society. Programs must be expanded or developed to ensure that all students and teachers have continuing support for home access to broadband and devices that meet the current and future demands of distance learning. Federal funds used for the expansion of broadband infrastructure must prioritize communities that lack the ability to adequately support distance learning (25/25 mbps or less) and require that any new deployment not only meet today’s demand for distance learning but also be able to evolve to meet future educational requirements. The FCC has an opportunity to work in partnership with schools, cities, and states to develop a recurring, granular, robust, assessment of the homework gap that would provide current, actionable data to support and encourage efforts to keep the gap closed.

Summary

Tens of thousands of students experience violence in schools in the form of corporal punishment. Nineteen states continue to allow for corporal punishment as a means of disciplining students in public schools. And public schools in nine states use corporal punishment as a disciplinary strategy for preschool-aged children. There is no federal law or regulation governing the practice, however the federal government should be clear that it does not condone it.

By strengthening state and local capacity to use data analytics, evaluation, and evidence in formula grant programs, the Department of Education (ED) could significantly increase the impact of its major investments in pre-K, K-12, and community college systems. Important changes could be made through coordinated regulatory and administrative actions that do not require congressional action, laying the groundwork for future congressional action to fill critical gaps.

Challenge and Opportunity

The Department of Education’s main initiatives to strengthen the use of data, evaluation, and evidence have focused on a small number of competitive grant programs (e.g., Education Innovation and Research, State Longitudinal Data Systems) with funding totaling less than $500 million annually. The vast majority of ED’s annual funding to state and local governments is allocated by formula to programs supporting pre-K, K-12, and community college systems (totaling over $39 billion). With the possible exception of a few recent ESSA provisions requiring states and localities to use evidence, ED lacks meaningful policies to strengthen state and local use of data, evidence and evaluation to improve the impact of formula grants. States and localities face multiple impediments to using data and evidence to make decisions, including impediments that stem from ED policies and practices:

• Lack of strong financial incentives for states and localities to use formula funding for data, analytics, evaluation, and adoption of evidence-based approaches.
• Lack of clarity about ways that existing program funds may be used to build data, analytics and evaluation capacity.
• Confusion about how to share and analyze data while meeting FERPA privacy requirements.
• An overemphasis on reporting compliance measures rather than outcomes and evaluation findings that would help programs improve. Many of these impediments could be addressed through ED regulatory and administrative reforms that do not require legislation. These reforms would help address systemic weaknesses and equity issues in state and local education systems that have been amplified by the COVID19 pandemic.

Plan of Action

The Secretary should designate a senior ED policy official and an attorney to lead a task force to devise regulatory and administrative reforms that can strengthen state and local data, analytics, and evaluation capacity. To be developed through extensive consultation with state and local officials, these reforms would include:

Regulatory reforms. ED should revise EDGAR provisions to:

• Require, as a condition of funding, that grantees use data and analytics to answer key questions that can improve program effectiveness. This common-sense change to both formula and competitive grants is long overdue, since no organization or program can function effectively without using data to guide decisions.
• Clarify that grantees with formula and competitive grants may use program funds (beyond those included in indirect costs) to strengthen their data, analytics, and evaluation capacity. This would include capacity to integrate and analyze education and non-education data to improve cross-program coordination that could lead to better student outcomes. This is consistent with GAO’s “necessary expense rule”, which clarifies that statutes need not specify all allowable uses of funds.
• Modify the “Strategy to Scale” selection criteria for competitive grants to award extra points to projects designed to scale up evidence-based interventions that will leverage formula grant funding (e.g., Title I, CTE), or state and local funding, above the minimum required by statute (e.g., 10 percent for EIR). This change would (1) increase adoption of effective interventions that cannot reach scale using competitive grant funds alone; and (2) increase the share of ED formula funding that supports evidence-based strategies. (There is precedent for this model, which was previously used in HHS’ 2008 home visiting initiative.)

Streamlining data collections. ED should continue to work with state and local grantees: (1) to eliminate unnecessary reporting that does not help grantees improve programs; and (2) to standardize data to improve its utility to users at all levels.

Technical assistance. ED, in collaboration with non-federal partners, should provide proactive technical assistance to help state and local governments make effective use of increased investments in data, analytics, and evaluation, including:

• additional guidance and examples on how individual level data can be shared and integrated with non-education data while meeting FERPA requirements;
• case studies on how to answer key questions with data analytics and evaluation;
• open-source technology solutions that can be deployed at the state and local level, including data-linkage platforms to link data across programs;
• ways to build staff data and technology skills;
• cost-allocation tools, vetted with auditors, for building shared data and analytics capacity with multiple funding streams; and
• strategies to reduce bias and promote equity in data analytics.

Innovative Personnel Exchanges and Public Private Partnerships. ED should employ the use IPAs, public-private partnerships, and other partnerships with relevant community organizations to engage state and local perspectives and non-government talent in implementing the action plan.

Assessment of state and local capacity. With state and local partners, ED should conduct a thorough assessment of state and local capacity gaps that cannot be adequately addressed through the regulatory and administrative actions above. This assessment would inform potential legislative and appropriations proposals to Congress.

While the focus of this initiative would be on federally funded programs, the potential benefits would extend to activities funded at the state and local level. This ED initiative could be part of a White House-led strategy to strengthen state and local data and analytics capacity across a broad range of federally funded programs, particularly those serving vulnerable populations.