Congress should approve a new allowable use of Title I spending that specifically enables and encourages school districts to use funds for activities that support and drive equity-focused innovation. The persistent equity gap between wealthy and poor students in our country, and the continuing challenges caused by the pandemic, demand new, more effective strategies to help the students who are most underserved by our public education system.

Efforts focused on the distribution of all education funding, and Title I in particular, have focused on ensuring that funds flow to students and districts with the highest need. Given the persistence of achievement and opportunity gaps across race, class, and socioeconomic status, there is still work to be done on this front. Further, rapidly developing technologies such as artificial intelligence and immersive technologies are opening up new possibilities for students and teachers. However, these solutions are not enough. Realizing the full potential of funding streams and emerging technologies to transform student outcomes requires new solutions designed alongside the communities they are intended to serve. 

To finally close the equity gap, districts must invest in developing, evaluating, and implementing new solutions to meet the needs of students and families today and in a rapidly changing future. Using Title I funding to create a continuous, improvement-oriented research and development (R&D) infrastructure supporting innovations at scale will generate the systemic changes needed to reach the students in highest need of new, creative, and more effective solutions to support their learning. 

Challenge and Opportunity

Billions of dollars of federal funding have been distributed to school districts since the authorization of Title I federal funding under the Elementary and Secondary Education Act (ESEA), introduced in 1965 (later reauthorized under the Every Student Succeeds Act [ESSA]). In 2023 alone, Congress approved $18.4 billion in Title I funding. This funding is designed to provide targeted resources to school districts to ensure that students from low-income families can meet rigorous academic standards and have access to post-secondary opportunities. ESEA was authorized during the height of the Civil Rights Movement with the intent of addressing the two primary goals of (1) ensuring traditionally disadvantaged students were better served in an effort to create more equitable public education, and (2) addressing the funding disparities created by differences in local property taxes, the predominant source of education funding in most districts. These dual purposes were ultimately aimed at ensuring that a student’s zip code did not define their destiny.

The passing of ESEA was a watershed moment. Prior to its authorization, education policy was left mostly up to states and localities. In authorizing ESEA, the federal government launched ongoing involvement in public education and initiated a focus on principles of equity in education.

Further, research shows that school spending matters: Increased funding has been found to be associated with higher levels of student achievement. However, despite the increased spending for students from low-income families via Title I, the literature on outcomes of Title 1 funding is mixed. The limited impact of Title I funds on outcomes may be a result of municipalities using Title I funding to supplant or fill gaps in their overall funding and programs, instead of being used as an additive funding stream meant to equalize funding between poorer and richer districts. Additionally, while a taxonomy of options is provided to bring rigor and research to how districts use Title funding, the narrow set of options has not yielded the intended outcomes at scale. For instance, studies have repeatedly shown that school turnaround efforts have proven particularly stubborn and not shown the hoped-for outcomes.

The equity gap that ESEA was created to address has not been erased. There is still a persistent achievement gap between high- and low-income students in the nation. The emergence of COVID in 2020 uprooted the public education system, and its impact on student learning, as measured by test scores, is profound. Students lost ground across all focus areas and grades. Now, in the post-pandemic era, students have continued to lose ground. The “COVID Generation” of students are behind where they should be, and many are disengaged or questioning the value of their public education. Chronic absenteeism is increasing across all grades, races, and incomes. These challenges create an imperative for schools and districts to deepen their understanding of the interests and needs of students and families. The quick technological advancements in the education market are changing what is possible and available to students, while also raising important questions around ethics, student agency, and equitable access to technology. It is a moment of immense potential in public education. 

Title I funds are a key mechanism to addressing the array of challenges in education ranging from equity to fast-paced advancements in technology transforming the field. In its current form, Title I allocation occurs via four distribution criteria. The majority of funding is allocated via basic grants that are determined entirely on individual student income eligibility. The other three criteria allocate funding based on the concentration of student financial need within a district. Those looking to rethink allocation often argue for considering impact per dollar allocated, beyond solely need as a qualifying indicator for funding, essentially taking into account cost of living and services in an area to understand how far additional funding will stretch in order to more accurately equalize funding. It is essential that Title I is redesigned beyond redoing the distribution formula. The money allocated must be spent differently—more creatively, innovatively, and wisely—in order to ensure that the needs of the most vulnerable students are finally met.

Plan of Action

Title I needs a new allowable spending category approved that specifically enables and encourages districts to use funds for activities that drive equity-focused innovation. Making room for innovation grounded in equity is particularly important in this present moment. Equity has always been important, but there are now tools to better understand and implement systems to address it. As school districts continue to recover from the pandemic-related disruptions, explore new edtech learning options, and prepare for an increasingly diverse population of students for the future, they must be encouraged to drive the creation of better solutions for students via adding a spending category that indicates the value the federal government sees in innovating for equity. Some of the spending options highlighted below are feasible under the current Title I language. By encouraging these options tethered specifically to innovation, district leadership will feel more flexibility to spend on programs that can foster equity-driven innovation and create space for the new solutions that are needed to improve outcomes for students.

Innovation, in this context, is any systemic change that brings new services, tools, or ways of working into school districts that improve the learning opportunities and experience for students. Equity-focused innovation refers to innovation efforts that are specifically focused on improving equity within school systems. It is a solution-finding process to meet the needs of students and families. Innovation can be new, technology-driven tools for students, teachers, or others who support student learning. But innovation is not limited to technology. Allowing Title I funding to be used for activities that support and foster equity-driven innovation could also include:

• Improving data systems and usage: Ensure that school districts have agile data systems equipped to identify student weaknesses and determine the effectiveness of solutions. As more solutions come to market and are developed internally, both AI and otherwise, school systems will be able to better serve students qualifying for Title I funding if they can meaningfully assess what is and is not working and use that information to guide strategy and decision-making.
• Leadership development: Support the research and development, futurist, and equitable design skills of systems to enable leaders to guide innovation from within districts alongside students and families.
• Testing new solutions: Title I funding currently can be spent primarily on evidence-based programs; enabling the use of funding for innovative pilots that have community support would provide space to discover more effective solutions. 
• Incentivizing systemic district innovation: School districts could use funding to support the creation of innovation offices within their administration structure that are tasked with developing an innovation agenda rooted in district and student needs and spearheading solutions. 
• Building networks for change: District leaders charged with creating and sustaining new learning models, school models, and programs often do so in isolation. Allowing districts to fund the creation of new programs and support existing organizations that bring together school system innovators and researchers to capture and share best practices, promising new solutions, and lessons learned from testing can lead to better adoption and scale of promising new models. There are already networks that exist, for instance, the Regional Education Laboratory Program. Funding could be used to support these existing networks or to develop new networks specifically tailored to meet the needs of leaders driving these innovations.

Expanding Title I funding to make room for innovative ideas and solutions within school systems has the potential to unlock new, more effective solutions that will help close equity gaps, but spending available education funds on unproven ideas can be risky. It is essential that the Department of Education issues carefully constructed guardrails to allow ample space for new solutions to emerge and scale, while also protecting students and ensuring their educational needs are still met. These guardrails and design principles would ensure that funds are spent in impactful ways that support innovation and building an evidence base. Examples of guardrails for a school system spending Title I funding on innovation could include:

• Innovation agenda: There should be a clearly articulated, publicly available innovation agenda that lays out how needs are being identified using quantitative and qualitative data and research, the methods of how innovations are being developed and selected, the goals of the innovation and how the work will grow (or not) based on clearly defined metrics of success.
• Clear research & development process: New ideas, tools, and ways of working must come into the district with a clear R&D process that begins with student and community needs and then regularly interrogates what is and is not working, tries to understand the why behind what is working, and expands promising practices.
• Pilot size limits: Unproven and innovative ideas should begin as pilots in order to ensure they are tested, evaluated, and proven before being used more broadly.
• Timeline requirements for results: New innovation funded via Title I funding should have a limited timeline during which the system needs to show improvement and evidence of impact.
• Clear outcomes that the innovation is aiming for: Innovation is not about something new for the sake of something new. Innovation funding via Title I funding must be linked to specific outcomes that will help achieve the overarching programmatic goal of increasing educational equity in our country. 

While creating an authorized funding category for equity-focused innovation through Title I would have the most widespread impact, other ways to drive equitable innovation should also be pursued in the short term, such as through the new Comprehensive Center (CC), set to open in fall 2024, that will focus on equitable funding. It should prioritize developing the skills in district leaders to enable and drive equity-driven innovation. 

Conclusion

Investment in innovation through Title I funding can feel high risk compared to the more comfortable route of spending only on proven solutions. However, many ways of traditional spending are not currently working at scale. Investing in innovation creates the space to find solutions that actually work for students—especially those that are farthest from opportunity and whom Title I funding is intended to support. Despite the perceived risk, investing in innovation is not a high-risk path when coupled with a clear sense of the community need, guardrails to promote responsible R&D and piloting processes, predetermined outcome goals, and the data systems to support transparency on progress. Large-scale, federal investment in creating space for innovation through Title I funding in—an already well-known mode of district funding not currently realizing its desired impact—will create solutions within public education that give students the opportunities they need and deserve.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

This memo was developed in partnership with the Alliance for Learning Innovation, a coalition dedicated to advocating for building a better research and development infrastructure in education for the benefit of all students. Read more education R&D memos developed in partnership with ALI here.

Newborn screening is performed on millions of babies in the U.S. every year to test for rare genetic diseases and, when necessary, allow for early treatment. While newborn screening is mandated by the federal government, each state runs its own screening program. Importantly, individual states manage how newborn screening data is stored and, potentially, accessed and used in the future. While such data is often used for quality assurance testing and clinical research, there have been  instances of law enforcement subpoenaing newborn screening data for use in criminal investigations. For example, New Jersey used newborn screening data to investigate a decades-old sexual assault This raises major concerns about overall transparency of data use and  privacy in the newborn screening process. 

The incoming administration should encourage states to develop data handling standards for newborn screening data. Specifically these standards should include how long data is stored and who can access it. This can be accomplished by directing the Health and Human Services’ (HHS) Federal Advisory Committee on Heritable Disorders in Newborns and Children (ACHDNC) to provide recommendations that clearly communicate data use and privacy measures to state health departments. In addition, the incoming administration should also encourage development of increased educational materials for parents to explain these privacy concerns, and create funding opportunities to incentivize both of these measures.

Challenge and Opportunity

Newborn screening is a universal practice across the United States. Blood samples are taken from infants only a few days old to test for a variety of genetic diseases such as phenylketonuria, which can cause intellectual disability that can be prevented through changes in diet—if it is caught early enough. These blood samples can be used for both metabolic and genetic tests, depending on which disease is being tested for and how it is detected.  Phenylketonuria, for example, is detected by high levels of a molecule called phenylalanine in the blood, while spinal muscular atrophy (SMA) is detected by changes in the genetic sequence of the gene associated with SMA. Newborn screening is an essential practice that identifies a wide range of severe diseases before symptoms occur, and three babies out of every 1,000 are identified with a genetic condition. 

While newborn screening is required by the federal government, each state can determine which panel of diseases are tested. The Department of Health and Human Services established an Advisory Committee on Heritable Disorders in Newborns and Children (ACHDNC), which regularly updates a Recommended Uniform Screening Panel (RUSP) with conditions. For example, SMA was approved to the RUSP in 2018, and all 50 states have now added SMA to their screening panels.  Much of the effort to both nominate conditions to the federal RUSP and to encourage individual states to adapt spinal muscular atrophy testing was led by patient advocacy groups such as CureSMA, and these sorts of groups play a significant role in the addition of future conditions. Similar efforts are underway for Krabbe disease, which was added to the RUSP in 2024  and is currently screened for in only twelve states, a number that may increase in the coming years as more states consider adding it to their panels.   State advisory boards will review new disease nominations and, along with their status on the RUSP, will often consider how prevalent a disease is, if there are treatments available for the disease, and cost-effectiveness of screening for this condition.  Regardless of which tests are performed, every state participates in newborn screening. Importantly, newborn screening does not require affirmative consent from parents—some states offer opt-out options, generally for religious reasons, but 98% of infants are screened. 

Mandatory newborn screening programs have led health departments across the country to obtain genetic data from nearly every child in the country for decades. With recent developments in genetic sequencing technologies, this means that, theoretically, this newborn screening data could be repurposed for other functions. In 2022, the New Jersey Office of the Public Defender filed a lawsuit against the New Jersey Department of Health for complying with a subpoena to provide newborn screening data to the police as part of a sexual assault investigation. Specifically, law enforcement subpoenaed the blood sample of a suspect’s child, which they used to perform new DNA analysis to match DNA crime scene evidence. The lawsuit reveals that the New Jersey Department of Health has retained newborn screening blood spots for over twenty years; that the data obtained from the subpoena was used to bring criminal charges for a crime committed in 1996; and that the Office of the Public Defender were not provided information about how many similar subpoenas have been complied with in the past. 

This case highlights the bigger issue of newborn screening data as the United States’ “hidden national DNA database.” Law enforcement has potential access to decades of samples that can be used for genetic analysis that were not intended for law enforcement use. Police in other states like California have also sought access to newborn screening databases for investigational purposes. In California, the state health department keeps samples indefinitely, and not only is this information not disclosed to parents, it no longer provides parents with an opt-out option. As law enforcement agencies across states begin to understand the magnitude of data that can be found in these databases, it is becoming clear that health department policies for regulating access to these data are lacking. 

Using genetic data in law enforcement has become increasingly common. The practice of “investigative genetic genealogy,” or IGG, has made national headlines in recent years, in which law enforcement can access genetic data from publicly available databases to use in criminal investigations. These databases are full of genetic data that consumers who participate in direct-to-consumer genetic testing, such as 23andMe, can use to voluntarily upload and share their data with more people. IGG presents its own privacy concerns, but it is important to recognize the voluntary nature of both (a) participating in direct-to-consumer testing and (b) uploading it to a third-party website. Newborn screening, on the other hand, is not an optional practice.  

Proponents of IGG argue that using genetic data is very effective at not only catching killers—and doing so quicker than without DNA data—but also exonerating innocents.  However, this fact does not outweigh the major issues of privacy, transparency, and the fact that this approach potentially violates the fourth amendment’s protections against unreasonable search and seizures—especially when it comes to incorporating newborn screening data into these approaches. A previous court case found a hospital in violation of the fourth amendment for providing law enforcement with warrantless drug screening results from pregnant women, even though the women were under the impression they were receiving diagnostic tests. The Supreme Court argued that the hospital’s actions break down public trust in the health system, as patients have a “reasonable expectation of privacy” regarding their test results. While cases of subpoenaing newborn screening data may not currently violate any legal procedure, allowing law enforcement access to these data for use in future investigations, particularly without informing the individuals or parents involved, may also erode trust in the health system. This may lead to parents—when given the option—to opting out of newborn screening programs more often, leading to an increase in genetic and metabolic disorders going undiagnosed in newborns and causing major health problems in the future. In addition, with many scientists advocating for adopting whole-genome sequencing of newborns—instead of simply sequencing a panel of genes that are commonly identified as disease-causing in newborns—the amount of potential available genetic data could be staggering.  As a result, the incoming administration needs to take action to address the lack of transparent policies regarding newborn screening data in order to maintain its success as a public health measure.

Plan of Action

Current genetic privacy legislation

The landscape of genetic privacy legislation is, currently, somewhat patchwork. At the federal level, the most relevant legislation includes (1) the Genetic Information Nondiscrimination Act (GINA), (2) the Affordable Care Act (ACA), and (3) the Health Insurance Portability and Accountability Act (HIPAA). GINA specifically prohibits genetic discrimination in health insurance and in the workplace. This means that health insurers cannot deny coverage based on genetic data, and employers cannot make hiring, firing, or promotion decisions based on genetic data. The ACA strengthens GINA’s stipulation against genetic discrimination in health insurance by mandating that any health insurance issuer must provide coverage to whomever applies, as well as including genetic information on the list of factors that cannot be considered when determining overage or premium costs. HIPAA additionally regulates genetic data gathered in a healthcare setting, which includes newborn screening data, but HIPAA-protected information can be shared at the request of a court order or subpoena. The FBI developed an interim policy regarding all types of forensic genetic genealogy—often used with direct-to-consumer genetic tests but could also be applicable to newborn screening—which states the criteria required for investigators to use this approach. Criteria includes the requirement that a case must be an unsolved violent crime. In addition, the interim policy states that investigative agencies must identify themselves as law enforcement—a previous case was solved by accessing genetic databases without disclosing this information to the database—and that any collected data must be destroyed upon conclusion of the case.

Additionally, many states have additional laws that strengthen genetic privacy regulation on top of federal regulations. Maryland  passed a bill that regulates the use of genetic data in criminal investigations—specifically, it requires that law enforcement obtains informed consent from non-suspects before using their DNA in investigations. Other recent state regulations that address law enforcement access to genetic data in one way or another include Montana, which requires government agencies to obtain a warrant to access genetic data, and Tennessee, which explicitly allows law enforcement to access genetic data as long as they obtain a warrant or subpoena. Importantly, many of these laws are geared more towards addressing genetic data from direct-to-consumer testing and do not directly apply to newborn screening. Like federal legislation, state genetic privacy legislation is largely lacking in policies to address the use of newborn screening by law enforcement. 

On top of legislation regarding genetic privacy, states all have their own respective policies regarding newborn screening that vary dramatically. For example, a court in Minnesota found that nonconsensual storage of newborn screening data for use outside of genetic screening purposes violates the state genetic privacy law stating that genetic information can only be distributed with an individual’s written consent, leading to Minnesota destroying its newborn screening samples. Other states have no legislation at all. Additionally, states can have laws addressing other, non-law enforcement uses of newborn screening data; another major use of newborn screening data is research. 

Policy Recommendations

The incoming administration should address the lack of transparency in newborn screening data management by implementing the following recommendations:

Direct the ACHDNC to develop national recommendations detailing standards for newborn genetic screening sample and data handling.

These standards should include:

Standards for what the data can be used for outside of newborn screening, and by whom. Newborn screening data is used in additional ways outside of law enforcement; it can also be used for quality assurance to help ensure tests are working properly, to help develop new tests, and in clinical trials. There are compelling arguments for these uses; for clinical research, for example, this data can contribute towards research studying the disease the child may have been diagnosed with. However, for the sake of transparency, policy should state specifically what newborn genetic data can and cannot be used for, and who is allowed access to the data under these circumstances. For instance, Michigan has a program called the Michigan BioTrust, which takes the leftover, de-identified newborn screening samples for use in research towards understanding disease. Parents can choose to opt in or out at the time of screening, and parents—as well as children, upon turning 18—can change their mind and have their data removed later if they so choose. Regardless of state decisions on whether law enforcement should be able to access their newborn screening data, clearly stating what the data can be used for overall is paramount for parents to understand what happens to their children’s samples.

The length of time that blood samples and genetic data can be stored in state databases, and when, if ever, the data will be destroyed. As detailed by the lawsuit, New Jersey had been storing samples for over twenty years, although parents were not actually aware of this fact until the lawsuit was filed; potentially in response to this lawsuit, starting in November 2024, New Jersey will be destroying blood spots older than 2 years. Similarly, Delaware stores blood spot samples for three years before destroying them. While there is no definitive answer to what the best timeline for saving samples is, establishing a transparent timeline for how long samples can be stored in each state will improve data handling transparency.

What say, if any, do parents have in what is done with their child’s samples and data. In Texas, after a lawsuit determining that storing newborn screening samples without consent was against the law, parents have the right to request their child’s samples be destroyed if they so choose. Developing policies that allow parents—or children themselves, once they become adults—to have a say in what happens to the samples after screening is completed would provide individuals control of their data without disincentivizing testing. 

Partner with state advisory boards to develop educational materials for parents detailing ACHDNC recommendations and state-specific policy.

While newborn screening is mandated, there is variable information available to parents regarding what is done with the data. For example, Michigan has an extensive Q&A page on their Department of Health website addressing many major newborn screening-related questions, including a section addressing what is done with samples after screening is complete. In contrast, West Virginia’s Q&A page does not address what happens to the samples after testing.  Not only would developing standard policies for data handling be beneficial, but improving the dissemination of such information to parents would increase overall transparency and improve trust in the system. The incoming administration should work closely with state advisory boards to improve the communication of newly-developed data handling standards to parents and other relevant parties.

Incentivize development of plans by providing grant opportunities to state health departments to support newborn screening programs.

Currently, newborn screening programs receive no direct federal funding; however, costs include operating costs, testing equipment, and personnel on top of the tests themselves. In general, newborn screening is paid for through a fee for the tests, which are often covered by the parents’ health insurance, or the State Children’s Health Insurance Program or Medicaid. However, grants such as the NBS Co-Propel have been awarded to states in the past for creating improvements in their newborn screening programs such as support for long-term follow up on patients that have positive test results returned to them. The Co-Propel grant was administered through the Maternal & Child Health Bureau (MCHB) of Health and Human Services; the incoming administration could recommend that MCHB initiates a new funding opportunity for states to either develop data storage standards and/or educational materials for families to encourage the adaptation of these standards.

Conclusion

Newborn genetic screening is an essential public health measure that saves thousands of lives each year by identifying diseases in newborns that can either be prevented early or treated immediately rather than waiting until severe symptom onset. However, with the advent of new genetic technologies and the burgeoning use of newborn genetic screening data in law enforcement investigations, major privacy and transparency issues are becoming known to parents, potentially putting trust in the newborn screening process at risk. This could reduce desire to participate in these programs, leading to an inability to quickly diagnose many preventable or treatable conditions. The incoming administration should work towards encouraging state health departments to develop clear and well-communicated data storage standards for newborn screening samples in order to combat these concerns moving forward.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

This memo proposes the modernization of the Enhancing Education Through Technology (E2T2) Program as part of the overdue Elementary and Secondary Education Act’s (ESEA) reauthorization. With the expiration of several programs that support technology-enabled teaching and learning—such as the Elementary and Secondary School Emergency Relief (ESSER) fund, Emergency Connectivity Fund (ECF), and the Affordable Connectivity Program (ACP)—and the increasing prevalence of digital tools in educational settings, there is a pressing need for dedicated aid to states and districts. A reimagined E2T2 can address the digital use, design, and access divides identified in the 2024 National Educational Technology Plan (NETP).

Challenge and Opportunity 

The 2024 NETP, the U.S. Department of Education’s (ED) flagship educational technology (edtech) policy document, envisions a future where all students use digital tools actively to learn, all educators have support to design those classroom experiences, and all communities can readily access foundational connectivity, devices, and digital content. The original $1 billion E2T2, established under the No Child Left Behind Act, played a critical role in developing and implementing state and local plans that reflected this vision. For example, SETDA’s 2010 report examining all states’ investments found that the top E2T2 priorities were: 

1. Professional development (top priority in 34 states)
2. Increasing achievement and digital literacy (top priority in 6 states)
3. Increase access to technology (top priority in 4 states)

However, the program lost funding in 2011 and was excluded from the 2015 Every Student Succeeds Act (ESSA). Since then, edtech has been subsumed under broader block grants, such as the Student Support and Academic Enrichment Program (Title IV-A) and Supporting Effective Instruction Program (Title II-A), resulting in a dilution of focus and resources. Furthermore, the end of the current Administration coincides with several challenges: 

• Federal Program Expirations: ED’s ESSER fund, which supported technology-enabled teaching and learning, was fully obligated by September 2024. The Federal Communications Commission’s (FCC) ECF, which provided $7.1 billion to purchase equipment, sunsetted in June 2024. Finally, the FCC’s ACP connected 23 million households to broadband at a discounted rate. Although many ACP recipients used the program to access schoolwork, the FCC exhausted its $14 billion in May 2024. A new program is necessary to sustain the significant gains made through these programs. 
• Unprepared for Emerging Technologies: As innovative tools like generative artificial intelligence (AI) make their way into educational environments, there is an increasing need to support states and districts by offering guidance and professional learning. While half of students aged 14-22 report using generative AI, including for schoolwork, 70% of educators have not yet received training on how to use AI effectively and responsibly. 
• Urgency for Digital Citizenship: Recent actions by the Surgeon General to recommend warning labels on social media, as well as bans on cell phones in schools approved by several states and local school boards, calls for additional capacity at the state and local levels to support digital citizenship education. 
• Educator Attrition: Due to increased pressures faced during the pandemic, educator attrition rates have increased. Although many policy solutions can help counter this issue, research suggests that educators who do not feel supported in their roles are more likely to leave the profession. With the average district now accessing nearly 3,000 different technology tools in a given school year, educators are more likely to feel lost in selecting and deploying the most appropriate options. States and districts require additional capacity to help educators navigate vast quantities of digital tools, thereby bolstering a feeling of professional support. 

Plan of Action

ESSA will be nine years old in December 2024, and the legislation included authorization levels for many programs only up until fiscal year 2020. The 119th Congress has an opportunity to examine the legislation and authorize new programs that respond to current challenges. 

A reimagined E2T2, authorized at a minimum of $1.8 billion, can be provided to states and districts through the ED’s Office of Elementary and Secondary Education (OESE), which has experience in administering large national programs. A 1.5% national activities set-aside, reserved by OESE and the Office of Planning, Evaluation, and Policy Development (OPEPD), can offer means for evaluating the impact of the program, as well as providing technical assistance through convenings and federal guidance on impactful investment strategies.

Similar to the original E2T2, state education agencies should receive their share of funds via Title I formula upon submission of a long-range statewide edtech plan informed through adequate community input (e.g., see the U.S. Department of Commerce’s guidance on soliciting public comments and engaging community organizations). States should be permitted to reserve a maximum of 5% of funds received to carry out various coordination activities, including the establishment of a dedicated edtech office that reports to the chief state school officer and is responsible for governing program implementation. The remainder of the funds should be subgranted through a mix of formula and competitive grants to local educational agencies and consortia of eligible entities (e.g., districts, nonprofits, higher education institutions, community anchor institutions). 

Allowable uses should include activities to close the three digital divides articulated in the 2024 NETP. For example, the reimagined E2T2 can support the current national AI strategy by allowing funds to be invested toward closing the “digital use divide,” providing opportunities for students to build AI literacy skills and use AI tools to examine and solve community problems. Funds could also be used to close the “digital design divide” by providing educators with ongoing professional development and reinforcing their abilities to align instruction with the Universal Design for Learning principles. Finally, funds could be used to close the “digital access divide” by allowing schools to procure accessible technology solutions, support students’ universal broadband access, or establish a state or local cabinet-level edtech director position. 

In 2025, federal policymakers have an opportunity to begin critical discussions around the E2T2 modernization by taking specific action steps:

• The Senate Health, Education, Labor, and Pensions Committee and the House Education and Workforce Committee can introduce steps to reauthorize ESEA, as well as seek input from educators and education leaders on new program considerations. 

• The White House Domestic Policy Council and Office of Management and Budget can advocate for the reimagined E2T2 in the president’s annual budget request.
• The Secretary of Education, alongside ED’s Assistant Secretary for Policy, Evaluation, and Policy Development and Assistant Secretary for Legislation and Congressional Affairs, can engage the public and legislators to build support for the reimagined E2T2.

Conclusion

The reimagined E2T2 represents a critical opportunity to address many pressing challenges in K-12 education while preparing students for the future. As we approach the reauthorization of ESEA, as well as consider policy solutions to fully harness the promises of emerging technologies like AI, providing systems with dedicated support for closing the three digital divides can significantly enhance the quality and equity of education across the United States. 

This memo was developed in partnership with the Alliance for Learning Innovation, a coalition dedicated to advocating for building a better research and development infrastructure in education for the benefit of all students. Read more education R&D memos developed in partnership with ALI here.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

Competent and innovative technologists are crucial to the future of U.S. national security. The National Security Commission on Artificial Intelligence (NSCAI) warns that a digital talent deficit at the Department of Defense (DOD) represents the greatest impediment to the U.S. military’s effective embrace of emerging technologies (such as artificial intelligence). 

A new Digital Military Talent Initiative could help address the military’s digital-talent gap by providing an expedited path to U.S. citizenship through military service for noncitizen technologists aligned to NSCAI archetypes. Modernization of an already-existing DOD program and military enlistment policy updates could infuse digital talent by providing vetted noncitizens a pathway to accelerated naturalization through military service.

Challenge and Opportunity

A paucity of technical talent threatens the U.S. military’s current and future capability goals, as evidenced by the military’s ongoing inability to staff cyber units or achieve objectives set by the Pentagon’s Chief Data Officer. Global competition for technical talent requires the United States to get more creative with recruitment. The former Director of the DOD’s Defense Innovation Unit noted that the Pentagon’s efforts to add science and technology talent to its workforce are “insufficient” given competitors’ gains in these arenas. 

If current efforts are insufficient to meet technical talent needs, future efforts may be worse. Projections suggest the U.S. population is aging, such that fewer working-age persons will be available relative to the broader population in years to come. This trend may have an outsize negative impact on the military’s available talent pool, as the military fills its ranks predominantly with younger workers. Only 12% of the nation’s young adults are qualified and available to enlist, further exacerbating the larger recruiting shortage. Compounding the problem is the fact that military-eligible tech talent is often lost to the higher-paying private sector. Last, lack of lifestyle flexibility may make the military a hard sell, especially for innovative and free-thinking talent.

Even the newest models for bringing private-sector talent into the military, such as the U.S. Digital Corps and cyber direct-hire authorities, only harness talent from existing U.S. citizens. Proposals for training more government technologists (e.g., by creating a federal digital service academy) are limited by the number of citizens who may be willing and able to participate. 

There is a blueprint that may help overcome these challenges. During the Global War on Terror, the U.S. military enlisted over 10,000 noncitizen volunteers through the Military Accessions Vital to the National Interest (MAVNI) program. Under this program, a select group of pre-screened recruits was offered the chance to remain in the U.S. and obtain citizenship in exchange for military service. Notwithstanding an untimely termination that gave rise to a series of lawsuits, MAVNI was widely recognized as a success. It should be noted that over 14,000 individuals expressed interest in the first year that the U.S. Army sought to enlist recruits in the Global War on Terror pursuant to 10 U.S.C. § 504(b)(2)). However, the program was limited in scope. Although many MAVNI participants held advanced degrees, the skillsets the program sought (due to DOD’s self-imposed restrictions) were limited to certain foreign languages and medical specialties. Modernizing and expanding MAVNI with statutory authority commensurate with the realities of modern conflict could help mitigate technology talent shortages in the military.

Modernizing and expanding MAVNI would also align with the NSCAI’s recommendation for a “comprehensive” legislative strategy to enable “highly skilled immigrants to encourage more AI talent to study, work, and remain in the United States.” Our nation’s inadequate strategies for recruiting foreign technical and STEM talent have caused leading companies like Google to appeal for Congressional assistance, even as peer nations like Canada have developed novel, effective policies to support digital immigration. During the Trump administration, Toronto became the fastest-growing location for tech-sector jobs in North America. The upshot is clear: the U.S. military—and the United States generally—faces a widening tech talent gap that requires out-of-the-box thinking to address.

Plan of Action

We propose a two-part plan of action for launching a national Digital Military Talent Initiative. Part One entails minor modifications to existing law governing U.S. military eligibility. Part Two involves modernizing the existing MAVNI program by expanding the definition of skills deemed “vital to the national interest” and evolving recruitment and technology practices to incorporate this new talent. More detail on each of these components is provided below.

Part 1. Amend existing law governing U.S. military eligibility. 

Two paragraphs of 10 U.S.C. § 504(b) should be modified to enable the Department of Defense to access noncitizen technologists. First, 10 U.S.C. § 504(b)(2)—which governs military enlistment of individuals who are neither U.S. citizens, permanent residents, nor citizens of Micronesia, the Marshall Islands, or Palau— should be modified to read:

“Notwithstanding paragraph (1), and subject to paragraph (3), the Secretary concerned may authorize enlistment of a person not described in paragraph (1) if the Secretary determines that such person possesses a critical skill or expertise that is vital to the national interest.”

In other words, 10 U.S.C. § 504(b)(2) should be modified by removing provision (B), which currently requires that an enlistee use their referenced “critical skill or expertise” in their “primary daily duties.” This requirement unnecessarily inhibits military commanders at all levels, since critical skills and expertise often include skills and expertise deployed only in moments of the utmost exigency.

Second, 10 U.S.C. § 504(b)(3) should be modified to read: 

“A Secretary concerned may not authorize more than 10,000 enlistments under paragraph (2) per military department in a calendar year until after the Secretary of Defense submits to Congress written notice of the intent of that Secretary concerned to authorize more than 10,000 such enlistments in a calendar year.” 

This language increases the enlistment number at which the Secretary of Defense is statutorily obligated to notify Congress and does away with the 30-day waiting period that the Secretary must wait between notifying Congress and proceeding with the enlistment authorization.

These modifications are needed to accommodate anticipated recruitment under an expanded MAVNI and help the Secretary to move quickly on leveraging such a talent pool. Congressional changes can be slow and difficult to change; however, without these changes, the MAVNI program will continue to be constrained when bringing noncitizen tech talent into the military.

Part 2. Modernize the DOD’s existing MAVNI program by authorizing enlistment for certain vetted noncitizens with critical digital competencies.

The MAVNI program authorizes certain noncitizens to enlist if they possess critical skills limited to certain foreign languages and medical specialties. As the demands of modern conflict have adjusted at the speed of technological advancement, so too should the way the U.S. staffs its military. The DOD should expand the MAVNI program to include skills aligned to the NSCAI’s digital-talent archetypes, the 2021 Executive Order 14028 on improving the nation’s cybersecurity, FY2022 National Defense Authorization Act, and the 2023 Executive Order 14110 on the development and use of artificial intelligence. The DOD should also consider the following recommendations to modernize the existing MAVNI program. 

MAVNI Program Setup:

• Determine talent needs of military service-software factories, as well as tactical-level units and enterprise programs pursuing technology transformations.
• Source and prioritize needs related to specific problem statements and technology applications that can be developed with minimal risk and have potential for significant impact. 
• Educate internal stakeholders on leveraging noncitizen technologists capable of developing and shipping code in zero trust environments.
• Evolve and scale MAVNI program infrastructure in alignment with DOD zero trust principles and architecture requirements.
• Develop professional-development and career pathways that incentivize recruited technical talent to remain engaged in their military careers. 
• Gather and implement feedback from program alumni and participants on topics including recruitment, retention, training, incentives, and community-building.

Recruitment Process:

• Define enlistment pathways for recruited technical talent. For instance, a recruit might first enter into a non-classified military occupational specialty—whether a unique specialty for uncleared technical talent or a traditional specialty. After receiving a clearance naturalization, the recruit could a) shift to an existing enlisted role in information technology/networking, cyber, and electronic warfare, b) enter a potentially new technology-specialty role, or c) commission as a warrant or officer. 
• Understand military recruiter pain points and concerns specific to MAVNI and technical talent identification to ensure appropriate talent screening, talking points, and incentivization for both the recruiter and potential service member.
• MAVNI participants enlisting in the military are encouraged to join any of the Regular or Reserve components.
• Naturalization should occur prior to MAVNI participants reporting to initial active duty training to avoid creating any U.S. visa complications.

Conclusion

The DOD’s current technology talent deficiencies may evolve into an existential vulnerability without significant course correction, while our competitors increase investments in both R&D and STEM education. The DOD can begin addressing these deficiencies through an integrated Technical Military Talent Initiative. Such an initiative should comprise two parts: (1) amending existing law governing enlistment eligibility and (2) modernizing the existing MAVNI program to recruit talent for the military in alignment with STEM skills “vital to the national interest.”  Together, these actions will dramatically grow the U.S. military’s eligible technology talent pool, thus enabling it to better compete in future sub-threshold and armed conflict.

This idea was originally published on February 9, 2022; we’ve re-published this updated version on November 13, 2024. The views expressed are those of the authors. The analysis presented stems from the authors’ academic research of publicly available sources, not from protected operational information. All errors and omissions are those of the authors.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

The United States should continue to pursue its commitment to reduce greenhouse gas emissions by 50–52% from 2005 levels by 2030 and achieve net-zero emissions by 2050. To reach these goals, the United States must rapidly increase renewable-energy production while simultaneously building the transmission capacity needed to carry power generated from new renewable sources. Such an investment requires transforming the American electricity grid at a never-before-seen speed and scale. For example, the 2024 DOE National Transmission Planning study estimates that the American transmission system will need to grow between 2.4 – 3.5 times its 2020 size by 2050 to achieve a 90% greenhouse gas emissions reduction from a 2005 baseline by 2035 and net-zero emissions in 2050. A promising way to achieve this ambitious transmission target is to create a national High Voltage Direct Current (HVDC) transmission network overlaid atop the existing alternating current (AC) grid. In addition to advancing America’s climate goals, such an effort would spur economic development in rural areas, improve the grid’s energy efficiency, and bolster grid stability and security. This memo proposes several policy options the Department of Energy (DOE) and Congress can pursue to incentivize private-sector efforts to construct a national HVDC transmission network while avoiding permitting issues that have doomed some previous HVDC projects.

Challenge and Opportunity

The current American electricity grid resembles the roadway system before the Eisenhower interstate system. Just as roads extended to most communities by the early 1950s, few areas are unelectrified today. However, the AC power lines that cross the United States today are tangled, congested, and ill-suited to quickly move large amounts of renewable power from energy-producing regions with lower demand (such as the Midwest and Southwest) directly to large population centers with high demand. Since HVDC transmission lines lose less power than AC lines at distances > 300 miles, HVDC technology is the best option to directly connect the renewable generation needed to achieve net-zero emissions by 2050 with consumers. 

There are few HVDC lines in the United States today. Those that do exist are scattered across the country and were not designed to facilitate renewable development. As a result, the United States is a long way from the integrated nationwide HVDC network needed to achieve net-zero emissions. Many recent attempts by the private sector to begin building long-distance HVDC transmission lines between renewable producing regions and consumers—such as Clean Line Energy’s proposal for an aboveground line that would have linked much of the Great Plains to the Southeast—have been unsuccessful due to a host of challenges. These challenges included negotiating leases with thousands of landowners with understandable concerns about how the project could alter their properties, negotiating with many local and state jurisdictions to secure project approval, and maintaining investor confidence throughout the complex and time-consuming permitting and leasing process. 
However, a new generation of private developers has proposed an innovative solution that bypasses these challenges: the construction of an underground nationwide HVDC network alongside existing rail corridors. Unlike aboveground transmission built through a mosaic of property owners’ holdings, this solution requires negotiation with only the seven major American rail companies. This approach also takes advantage of the proximity of these already-disturbed corridors to many areas with high renewable-energy potential (Figure 1), does not add visual pollution to the aboveground landscape, and would weatherproof grid infrastructure against natural disasters.

Figure 1

Areas with high potential for wind and solar generation in the Great Plains and Southwest overlap with existing rail routes. Clockwise from left to right, routes of all seven class 1 railways (Source: Federal Railway Administration), heat map of average annual wind speed 80 meters aboveground (an indicator of the potential for wind energy generation; Source: National Renewable Energy

Importantly, these benefits apply to co-location next to highways or existing transmission lines as well. While this memo focuses on rail co-location, co-location next to other infrastructure should be simultaneously pursued by first removing regulatory barriers as was recently enacted in Minnesota and promoting the efficiencies gained from all forms of infrastructure co-location to relevant stakeholders. 

In addition to the political considerations discussed above, several recent advances in HVDC technology have driven costs low enough to make HVDC installation cost-competitive with installing high voltage alternating current (HVAC) lines (see FAQ for more details). As a result, incentivizing HVDC makes sense from perspectives beyond addressing climate change. The U.S. electric grid must be modernized to address pressing challenges beyond climate, such as the need for improved grid reliability and stability. Because HVDC transmission, unlike AC transmission, can maintain consistent power, voltage, and frequency, constructing a HVDC transmission network is a promising way to support the large-scale incorporation of renewable sources into our nation’s energy mix while simultaneously bolstering grid stability and efficiency, and spurring economic growth in rural areas. 

A nationwide HVDC network would also increase grid stability by connecting the four large interconnections that make up the shared American and Canadian power grid (Figure 2). Currently, the two largest of these interconnections—the Eastern and Western interconnections—manage 700 and 250 GW of electricity respectively. Yet, these interconnections are connected by transfer stations with a capacity of only about 1 GW. A recent study led by NREL modeled the economics of building a nationwide HVDC macrogrid that would tie the Eastern and Western interconnections together. The study concluded that such an investment would have a net benefit-to-cost ratio of 1.36 due to the possible ability for a nationwide HVDC grid to (i) shuttle renewable energy across the country as different power sources begin and end generation capabilities each day, and (ii) respond more nimbly to power outages in regions affected by natural disasters.

Figure 2

The four interconnections comprising the American and Canadian electricity grid: the Western, Eastern, ERCOT (Texas), and Quebec interconnections. Colors within the Eastern interconnection represent the territories of non-profit entities established to promote and enhance grid reliability within the territories shown on the map. These grid-reliability non-profits should not be confused with independent system operators (ISOs). (Source: National Electricity Reliability Council (NERC)).

Many private companies are already starting to realize an upgraded U.S. grid via new co-located HVDC transmission lines. For example, Minneapolis-based Direct Connect, with financial backing from American and international investors, has begun the permitting process for SOO Green, a buried HVDC line along a low-use railway that will link the Iowa countryside to the Chicago area. Direct Connect estimates that the SOO Green HVDC link will spur $1.5 billion of new renewable-energy development, create $2.2 billion of economic output in Iowa and Illinois, and create thousands of construction, operation, and maintenance jobs. Although geographically short, the line is also significant because it will join the Midwest (MISO) and PJM Independent System Operators (ISOs), two of the seven regional bodies that manage much of the United States’ grid. The combined territory of the MISO and PJM ISOs stretches from the wind-rich Great Plains to demand centers like Chicago and the Northeast corridor. Facilitating HVDC transmission in this project will allow renewable power to be efficiently funneled from regions that produce lots of energy to the regions that need it. 

The Champlain Hudson Power Express joining NY-ISO and the Quebec interconnection is another example demonstrating the promise of buried, co-located HVDC transmission. The project is projected to save New York homes and businesses $17.3 billion over 30 years through wholesale electricity costs by supplying Quebec hydropower to New York City. The line is currently permitted and under construction and when finished will stretch 339 miles underneath Lake Champlain & the Hudson River and underground through New York State to a converter in Astoria, New York City. The terrestrial portions will be built alongside existing railroad and highway right of ways. 

While these two projects and the handful of other buried and  co-located HVDC lines currently in permitting, permitted, or under construction are important projects, far more transmission needs to be built to meet the U.S.’ climate goals.  As a result, scaling underground co-located HVDC rapidly enough to achieve the transmission required for net-zero emissions in 2050 requires federal action to make these types of lines a more attractive proposition. The policy options outlined below would encourage other privately backed HVDC projects with the potential to boost rural economies while advancing climate action.

Plan of Action

The following policy recommendations would accelerate the development of a national HVDC network by stimulating privately funded construction of underground HVDC transmission lines located alongside existing rail corridors. Recommendations one and two are easily actionable rule changes that can be enacted by the Federal Energy Regulatory Commission (FERC) under existing authority. Recommendation three proposes that the DOE Grid Deployment Office should consider rail co-location in its NIETC designation process. Recommendation four is a more ambitious proposal for federal tax credits which would require Congressional action.

Recommendation 1. FERC should issue a new order that requires ISOs to review new renewable generation and new transmission projects on separate tracks to decrease permitting time delays.

New merchant transmission projects (transmission lines developed by private companies and not by rate-regulated utilities) such as SOO Green and the Champlain Hudson Power Express are often reviewed by ISOs in the same interconnection queue as new generation projects. Due to the high volume backlog of new, often speculative, renewable generation project proposals, transmission projects can wait for years before they are reviewed. This then creates a vicious cycle holding back the clean-energy sector: a delayed review of the transmission capabilities required by new renewable-generation projects ultimately chills the market for generation projects as well.

FERC recently reformed its regulations for interconnection requests (FERC Order 2023). FERC’s  expectation is that switching to a first-ready, first-served system, clustering projects together in groups to be approved en masse, and increasing both submission deposits and withdrawal penalties should prevent speculative submissions and reduce approval times. Order 2023’s removal of the reasonable effects standard (i.e. hardening deadlines for transmission providers to complete impact and interconnection studies) as well as allowing multiple generation projects to share interconnections should also reduce wait times. 

FERC Order 2023 is a laudable first step to address interconnection backlogs; however there is a chance that reality may not match FERC’s expectations. Therefore, FERC should continue to improve the regulatory regime in this area by issuing a new order that requires ISOs to review new renewable generation and new transmission projects on separate tracks. Such a rule would greatly decrease the permitting time for co-located HVDC transmission projects. 

Recommendation 2. FERC should encourage ISOs to re-examine older transmission interconnection rules that are appropriate for AC transmission regulation but do not take into account the benefits of HVDC. External capacity rules, which govern the ability to trade power across ISO boundaries, are a specific area in need of action because they can create barriers to building HVDC transmission across ISO boundaries. 

One granular example is described in SOO Green’s complaint to FERC about the PJM ISO (FERC Docket EL21-103).  Under current rules set by the PJM ISO, energy generated outside of the PJM service area can participate in PJM’s energy marketplace only if grid operators can directly dispatch that energy. This rule was established because grid operators cannot otherwise control the free flow of power through cross-ISO AC transmission, but it results in the exclusion of external, non-dispatchable renewable energy resources from PJM’s market.  However, HVDC lines offer the capacity to schedule current flow at pre-agreed upon times, allowing PJM to directly control transmission and negating the need to control energy dispatch. PJM should look for solutions to this issue from ISO New England and NYISO’s external capacity rules, which have enabled them to import external capacity through HVDC lines into their territories. 

FERC should encourage PJM ISO to revise its external capacity rules to enable less burdensome pathways to market participation for external resources connecting through HVDC transmission. PJM can look to ISO New England and NYISO as examples.

Recommendation 3. As the DOE proposes possible National Interest Electric Transmission Corridors (NIETCs), it should pursue co-location with rail, highways, and existing transmission whenever possible.

Previous attempts by Congress to establish greater federal power over transmission siting and permitting have revolved around the DOE’s authority to designate areas as NIETCs. NIETCs are regions that the DOE identifies as particularly prone to grid congestion or transmission-capacity constraints. Creation of NIETCs was authorized by the Federal Power Act (Sec. 216), which also grants FERC the authority to supersede states’ permitting and siting decisions if the rejected transmission project is in a NIETC and meets certain conditions (including benefits to consumers (even those in other states), enhancement of energy independence, or if the project is “consistent with the public interest”). This “backstop” authority was created by the Energy Policy Act of 2005, was recently reformed in 2021’s Infrastructure Investment and Jobs Act, and was further clarified by FERC Order 1977 through the creation of a landowner bill of rights. 

While a laudable attempt to spur transmission investment and respect landowners, the revised authority in its current form is unlikely to lead to the sudden acceleration of transmission siting and permitting necessary to achieve the United States’ climate goals. This is because NIETC designation, as well as any FERC action under Section 216, (i) trigger the development of environmental impact statements under the National Environmental Policy Act (NEPA), and (ii) may still engender strong political opposition by states and landowners whose properties would be part of proposed routes but would not receive any benefits from transmission investments.

The DOE recently released a list of proposed NIETCs, which if designated would be the first corridors in the country.  Some of the NIETCs were designed with co-location in mind, for example the NY – NE ISO link is located alongside roadways and mid-Atlantic routes are co-located with already existing transmission. However, rail co-location was not mentioned, yet the DOE’s proposed NIETCs overlap with the nation’s class 1 railways in many locations, especially in the Southwest and Midwest. In order to speed up the NEPA review process and reduce NIETC opposition, the DOE should i) consider discussing rail co-location in addition to highway and transmission infrastructure during the upcoming public engagement process, and ii) promote the possibility of co-location to transmission developers in all relevant NIETCs after they are officially designated.

Recommendation 4. Create federal tax credits to stimulate domestic manufacturing and construction of HVDC transmission, including HVDC lines along rail corridors.

Congress should create two federal investment tax credits (ITCs) to stimulate a market for American HVDC lines. One tax credit should be directed to American manufacturers of cross-linked polyethylene (XLPE) which serves as the material for the liner in HVDC cables. Since most producers are based in Asia, such an incentive would help ensure a reliable domestic supply of this essential material. The second tax credit should be directed to HVDC line developers who propose new regionally significant transmission projects that join ISOs or the three interconnections together. Since the United States’ grid grew in an ad-hoc, decentralized way, a Congressional tax credit of this type would further build on FERC’s recent order 1920, which requires transmission providers to think more big picture, long-term and strategically by developing a long-term regional transmission plan that covers at least the next 20 years. 

Such a tax credit was recently introduced into Congress. In 2023, Sen. Martin Heinrich (D-NM) proposed a 30% ITC for “regionally significant” transmission projects which was also introduced in a companion bill by Rep. Steven Horsford, (D-Nev). Their Grid Resiliency Tax Credit Act would provide a 10-year credit for projects that begin building before 2033. The bill is currently under discussion by the Senate Finance committee and should be amended to also include a tax credit for XLPE manufacturers. The expiration of parts of the Tax Cuts and Jobs Act in 2025 will focus attention on tax legislation in the next Congress and offer a legislative window for transmission construction and component manufacturing tax credits. In the potentially acrimonious debate about the future of tax policy, transmission tax credits could be a rare point of agreement and an opportunity for both parties to invest in American manufacturing and infrastructure growth.

Conclusion

A significant increase in transmission capacity is needed to meet the United States’ efforts to achieve net-zero emissions by 2050. Creating a nationwide HVDC transmission network would not only greatly aid the United States’ efforts to address climate change, it would also improve grid stability and provide sustained economic development in rural areas. Direct Connect’s SOO Green project and the Champlain Hudson Power Express are examples of innovative solutions to legitimate stakeholder concerns over environmental impacts and individual property rights – concerns that have plagued previous failed efforts to construct long-distance HVDC transmission. The federal government can stimulate private development of HVDC  infrastructure via rule changes to the transmission interconnection process by FERC, promoting rail co-location in the NIETC design and designation process, and by passing new HVDC transmission-specific tax credits.

This idea was originally published on May 5, 2022; we’ve re-published this updated version on November 12, 2024.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

Current hiring processes for political appointees are opaque and problematic; job openings are essentially closed off except to those in the right networks. To democratize hiring, the next administration should develop a public jobs board for non-Senate-confirmed political appointments, which includes a list of open roles and job descriptions. By serving as a one-stop shop for those interested in serving in an administration, an open jobs board would bring more skilled candidates into the administration, diversify the appointee workforce, expedite the hiring process, and improve government transparency.

Challenge and Opportunity

Hiring for federal political appointee positions is a broken process. Even though political appointees steer some of the federal government’s most essential functions, the way these individuals are hired lacks the rigor and transparency expected in most other fields.

Political appointment hiring processes are opaque, favoring privileged candidates already in policy networks. There is currently no standardized hiring mechanism for filling political appointee roles, even though new administrations must fill thousands of lower-level appointee positions. Openings are often shared only through word-of-mouth or internal networks, meaning that many strong candidates with relevant domain expertise may never be aware of available opportunities to work in an administration. Though the Plum Book (an annually updated list of political appointees) exists, it does not list vacancies, meaning outside candidates must still have insider information on who is hiring.

These closed hiring processes are deeply problematic because they lead to a non-diverse pool of applicants. For example, current networking-based processes benefit graduates of elite universities, and similar networking-based employment processes such as employee referral programs tend to benefit White men more than any other demographic group. We have experienced this opaque process firsthand at the Aspen Tech Policy Hub; though we have trained hundreds of science and technology fellows who are interested in serving as appointees, we are unaware of any that obtained political appointment roles by means other than networking.

Appointee positions often do not include formal job descriptions, making it difficult for outside candidates to identify roles that are a good fit. Most political appointee jobs do not include a written, formalized job description—a standard best practice across every other sector. A lack of job descriptions makes it almost impossible for outside candidates utilizing the Plum Book to understand what a position entails or whether it would be a good fit. Candidates that are being recruited typically learn more about position responsibilities through direct conversations with hiring managers, which again favors candidates who have direct connections to the hiring team.

Hiring processes are inefficient for hiring staff. The current approach is not only problematic for candidates; it is also inefficient for hiring staff. Through the current process, PPO or other hiring staff must sift through tens of thousands of resumes submitted through online resume bank submissions (e.g. the Biden administration’s “Join Us” form) that are not tailored to specific jobs. They may also end up directly reaching out to candidates that may not actually be interested in specific positions, or who lack required specialized skills.

Given these challenges, there is significant opportunity to reform the political appointment hiring process to benefit both applications and hiring officials.

Plan of Action

The next administration’s Presidential Personnel Office (PPO) should pilot a public jobs board for Schedule C and non-career Senior Executive Service political appointment positions and expand the job board to all non-Senate-confirmed appointments if the pilot is successful. This public jobs board should eventually provide a list of currently open vacancies, a brief description for each currently open vacancy that includes a job description and job requirements, and a process for applying to that position.

Having a more transparent and open jobs board with job descriptions would have multiple benefits. It would:

• Bring in more diverse applicants and strengthen the appointee workforce by broadening hiring pools; 
• Require hiring managers to write out job descriptions in advance, allowing outside candidates to better understand job opportunities and hiring managers to pinpoint qualifications they are looking for; 
• Expedite the hiring process since hiring managers will now have a list of qualified applicants for each position; and 
• Improve government transparency and accessibility into critical public sector positions.

Additionally, an open jobs board will allow administration officials to collect key data on applicant background and use these data to improve recruitment going forward. For example, an open application process would allow administration officials to collect aggregate data on education credentials, demographics, and work experience, and modify processes to improve diversity as needed. Having an updated, open list of positions will also allow PPO to refer strong candidates to other open roles that may be a fit, as current processes make it difficult for administration officials or hiring managers to know what other open positions exist.

Implementing this jobs board will require two phases: (1) an initial phase where the transition team and PPO modify their current “Join Us” form to list 50-100 key initial hires the administration will need to make; and (2) a secondary phase where it builds a more fulsome jobs board, launched in late 2025, that includes all open roles going forward. 

Phase 1. By early 2025, the transition team (or General Services Administration, in its transition support capacity) should identify 50-100 key Schedule C or non-career Senior Executive service hires they think the PPO will need to fill early in the administration, and launch a revised resume bank to collect applicants for these positions. The transition team should prioritize roles that a) are urgent needs for the new administration, b) require specialized skills not commonly found among campaign and transition staff (for instance technical or scientific knowledge), and c) have no clear candidate already identified. The transition team should then revise the current administration’s “Join Us” form to include this list of 50-100 soon-to-be vacant job roles, as well as provide a 2-3 sentence description of the job responsibilities, and allow outside candidates to explicitly note interest in these positions. This should be a relatively light lift, given the current “Join Us” form is fairly easy to build.

Phase 2. Early in the administration, PPO should build a larger, more comprehensive jobs board that should aim to go live in late 2025 and includes all open Schedule C or non-Senior Executive Service (SES) positions. Upon launch, this jobs board should include open jobs for whom no candidate has been identified, and any new Schedule C and non-SES appointments that are open going forward. As described in further detail in the FAQ section, every job listed should include a brief description of the position responsibilities and qualifications, and additional questions on political affiliation and demographics.

During this second phase, the PPO and the Office of Personnel Management (OPM) should identify and track key metrics to determine whether it should be expanded to cover all non-Senate confirmed appointments. For example, PPO and OPM could compare the diversity of applicants, diversity of hires, number of qualified candidates who applied for a position, time-to-hire, and number of vacant positions pre- and post-implementation of the jobs board. 

If the jobs board improves key metrics, PPO and OPM should expand the jobs board to all non-Senate confirmed appointments. This would include non-Senate confirmed Senior Executive Service appointee positions.

Conclusion

An open jobs board for political appointee positions is necessary to building a stronger and more diverse appointee workforce, and for improving government transparency. An open jobs board will strengthen and diversify the appointee workforce, require hiring managers to specifically write down job responsibilities and qualifications, reduce hiring time, and ultimately result in more successful hires.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

The Inflation Reduction Act and the Infrastructure Innovation and Jobs Act are set to drive $300 billion in energy infrastructure investment by 2030. Without permitting reform, lengthy review processes threaten to make these federal investments one-third less effective at reducing greenhouse gas emissions. That’s why Congress has been grappling with reforming the National Environmental Policy Act (NEPA) for almost two years. Yet, despite the urgency to reform the law, there is a striking lack of available data on how NEPA actually works. Under these conditions, evidence-based policy making is simply impossible. With access to the right data and with thoughtful teaming, the next administration has a golden opportunity to create a roadmap for permitting software that maximizes the impact of federal investments.

Challenge and Opportunity

NEPA is a cornerstone of U.S. environmental law, requiring nearly all federally funded projects—like bridges, wildfire risk-reduction treatments, and wind farms—to undergo an environmental review. Despite its widespread impact, NEPA’s costs and benefits remain poorly understood. Although academics and the Council on Environmental Quality (CEQ) have conducted piecemeal studies using limited data, even the most basic data points, like the average duration of a NEPA analysis, remain elusive. Even the Government Accountability Office (GAO), when tasked with evaluating NEPA’s effectiveness in 2014, was unable to determine how many NEPA reviews are conducted annually, resulting in a report aptly titled “National Environmental Policy Act: Little Information Exists on NEPA Analyses.”

The lack of comprehensive data is not due to a lack of effort or awareness. In 2021, researchers at the University of Arizona launched NEPAccess, an AI-driven program aimed at aggregating publicly available NEPA data. While successful at scraping what data was accessible, the program could not create a comprehensive database because many NEPA documents are either not publicly available or too hard to access, namely Environmental Assessments (EAs) and Categorical Exclusions (CEs). The Pacific Northwest National Laboratory (PNNL) also built a language model to analyze NEPA documents but contained their analysis to the least common but most complex category of environmental reviews, Environmental Impact Statements (EISs).

Fortunately, much of the data needed to populate a more comprehensive NEPA database does exist. Unfortunately, it’s stored in a complex network of incompatible software systems, limiting both public access and interagency collaboration. Each agency responsible for conducting NEPA reviews operates its own unique NEPA software. Even the most advanced NEPA software, SOPA used by the Forest Service and ePlanning used by the Bureau of Land Management, do not automatically publish performance data.

Analyzing NEPA outcomes isn’t just an academic exercise; it’s an essential foundation for reform. Efforts to improve NEPA software have garnered bipartisan support from Congress. CEQ recently published a roadmap outlining important next steps to this end. In the report, CEQ explains that organized data would not only help guide development of better software but also foster broad efficiency in the NEPA process. In fact, CEQ even outlines the project components that would be most helpful to track (including unique ID numbers, level of review, document type, and project type).

Put simply, meshing this complex web of existing softwares into a tracking database would be nearly impossible (not to mention expensive). Luckily, advances in large language models, like the ones used by NEPAccess and PNNL, offer a simpler and more effective solution. With properly formatted files of all NEPA documents in one place, a small team of software engineers could harness PolicyAI’s existing program to build a comprehensive analysis dashboard.

Plan of Action

The greatest obstacles to building an AI-powered tracking dashboard are accessing the NEPA documents themselves and organizing their contents to enable meaningful analysis. Although the administration could address the availability of these documents by compelling agencies to release them, inconsistencies in how they’re written and stored would still pose a challenge. That means building a tracking board will require open, ongoing collaboration between technologists and agencies.

• Assemble a strike team: The administration should form a cross-disciplinary team to facilitate collaboration. This team should include CEQ; the Permitting Council; the agencies responsible for conducting the greatest number of NEPA reviews, including the Forest Service, Bureau of Land Management, and the U.S. Army Corps of Engineers; technologists from 18F; and those behind the PolicyAI tool developed by PNNL. It should also decide where the software development team will be housed, likely either at CEQ or the Permitting Council.
• Establish submission guidelines: When handling exorbitant amounts of data, uniform formatting ensures quick analysis. The strike team should assess how each agency receives and processes NEPA documents and create standardized submission guidelines, including file format and where they should be sent. 
• Mandate data submission: The administration should require all agencies to submit relevant NEPA data annually, adhering to the submission guidelines set by the strike team. This process should be streamlined to minimize the burden on agencies while maximizing the quality and completeness of the data; if possible, the software development team should pull data directly from the agency. Future modernization efforts should include building APIs to automate this process.
• Build the system: Using PolicyAI’s existing framework, the development team should create a language model to feed a publicly available, searchable database and dashboard that tracks vital metadata, including:
  • The project components suggested in CEQ’s E-NEPA report, including unique ID numbers, level of review, document type, and project type
  • Days spent producing an environmental review (if available; this information may need to be pulled from agency case management materials instead)
  • Page count of each environmental review
  • Lead and supporting agencies
  • Project location (latitude/longitude and acres impacted, or GIS information if possible) 
  • Other laws enmeshed in the review, including the Endangered Species Act, the National Historic Preservation Act, and the National Forest Management Act
  • When clearly stated in a NEPA document, cost of producing the review
  • When clearly stated in a NEPA document, staff hours used to produce the review
  • When clearly stated in a NEPA document, jobs and revenue created by the project
  • When clearly stated in a NEPA document, carbon emissions mitigated by the project

Conclusion

The stakes are high. With billions of dollars in federal climate and infrastructure investments on the line, a sluggish and opaque permitting process threatens to undermine national efforts to cut emissions. By embracing cutting-edge technology and prioritizing transparency, the next administration can not only reshape our understanding of the NEPA process but bolster its efficiency too.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

Without market-shaping interventions, federal and state subsidies for energy-efficient products like heat pumps often lead to higher prices, leaving the overall market worse off when rebates end. This is a key challenge that must be addressed as the Department of Energy (DOE) and states implement the Inflation Reduction Act’s Home Electrification and Appliance Rebates (HEAR) program. 

DOE should prioritize the development of evidence-based market-transformation strategies that states can implement with their HEAR funding. The DOE should use its existing allocation of administrative funds to create a central capability to (1) develop market-shaping toolkits and an evidence base on how state programs can improve value for money and achieve market transformation and (2) provide market-shaping program implementation assistance to states.

There are proven market-transformation strategies that can reduce costs and save consumers billions of dollars. DOE can look to the global public health sector for an example of what market-shaping interventions could do for heat pumps and other energy-efficient technologies. In that arena, the Clinton Health Access Initiative (CHAI) has shown how public funding can support market-based transformation, leading to sustainably lower drug and vaccine prices, new types of “all-inclusive” contracts, and improved product quality. Agreements negotiated by CHAI and the Bill and Melinda Gates Foundation have generated over $4 billion in savings for publicly financed health systems and improved healthcare for hundreds of millions of people. 

Similar impact can be achieved in the market for heat pumps if DOE and states can supply information to empower consumers to purchase the most cost-effective products, offer higher rebates for those cost-effective products, and seek supplier discounts for heat pumps eligible for rebates. 

Challenge and Opportunity 

HEAR received $4.5 billion in appropriations from the Inflation Reduction Act and provides consumers with rebates to purchase and install high-efficiency electric appliances. Heat pumps, the primary eligible appliance, present a huge opportunity for lowering overall greenhouse gas emissions from heating and cooling, which makes up over 10% of global emissions. In the continental United States, studies have shown that heat pumps can reduce carbon emissions up to 93% compared to gas furnaces across their lifetime. 

However, direct-to-consumer rebate programs have been shown to enable suppliers to increase prices unless these subsidies are used to reward innovation and reduce cost. If subsidies are dispersed and the program design is not aligned with a market-transformation strategy, the result will be a short-term boost in demand followed by a fall-off in consumer interest as prices increase and the rebates are no longer available. This is a problem because program funding for heat pump rebates will support only ~500,000 projects over the life of the program—but more than 50 million households will need to convert to heat pumps in order to decarbonize the sector.

HEAR aims to address this through Market Transformation Plans, which states are required to submit to DOE within a year after receiving the award. States will then need to obtain DOE approval before implementing them. We see several challenges with the current implementation of HEAR: 

• Need for evidence: There is a lack of evidence and policy agreement on the best approaches for market transformation. The DOE provides a potpourri of areas for action, but no evidence of cost-effectiveness. Thus, there is no rational basis for states to allocate funding across the 10 recommended areas for action. There are no measurable goals for market transformation.  

• Redundancy: It is wasteful and redundant to have every state program allocate administrative expenses to design market-transformation strategies incorporating some or all of the 10 recommended areas for action. There is nothing unique to Georgia, Iowa, or Vermont in creating a tool to better estimate energy savings. A best-in-class software tool developed by DOE or one of the states could be adapted for use in each state. Similarly, if a state develops insights into lower-cost ways to install heat pumps, these insights will be valuable in many other state programs. The best tools should be a public good made known to every state program. 

Despite these challenges, DOE has a clear opportunity to increase the impact of HEAR rebates by providing program design support to states for market-transformation goals. To ensure a competitive market and better value for money, state programs need guidance on how to overcome barriers created by information asymmetry – meaning that HVAC contractors have a much better understanding of the technical and cost/benefit aspects of heat pumps than consumers do. Consumers cannot work with contractors to select a heat pump solution that represents the best value for money if they do not understand the technical performance of products and how operating costs are affected by Seasonal Energy Efficiency Rating, coefficient of performance, and utility rates. If consumers are not well-informed, market outcomes will not be efficient. Currently, consumers do not have easy access to critical information such as the tradeoff in costs between increased Seasonal Energy Efficiency Rating and savings on monthly utility bills. 

Overcoming information asymmetry will also help lower soft costs, which is critical to lowering the cost of heat pumps. Based on studies conducted by New York State, Solar Energy Industries Association and DOE, soft costs run over 60% of project costs in some cases and have increased over the past 10 years.

There is still time to act, as thus far only a few states have received approval to begin issuing rebates and state market-transformation plans are still in the early stages of development.

Plan of Action 

Recommendation 1. Establish a central market transformation team to provide resources and technical assistance to states.

To limit cost and complexity at the state level for designing and staffing market-transformation initiatives, the DOE should set up central resources and capabilities. This could either be done by a dedicated team within the Office of State and Community Energy Programs or through a national lab. Funding would come from the 3% of program funds that DOE is allowed to use for administration and technical assistance. 

This team would:

• Collect, centralize, and publish heat pump equipment and installation cost data to increase transparency and consumer awareness of available options.
• Develop practical toolkits and an evidence base on how to achieve market transformation most cost-effectively.
• Provide market-shaping program design assistance to states to create and implement market transformation programs.

Data collection, analysis, and consistent reporting are at the heart of what this central team could provide states. The DOE data and tools requirements guide already asks states to provide information on the invoice, equipment and materials, and installation costs for each rebate transaction. It is critical that the DOE and state programs coordinate on how to collect and structure this data in order to benefit consumers across all state programs.

A central team could provide resources and technical assistance to State Energy Offices (SEOs) on how to implement market-shaping strategies in a phased approach.

Phase 1. Create greater price transparency and set benchmarks for pricing on the most common products supported by rebates.

The central market-transformation team should provide technical support to states on how to develop benchmarking data on prices available to consumers for the most common product offerings. Consumers should be able to evaluate pricing for heat pumps like they do for major purchases such as cars, travel, or higher education. State programs could facilitate these comparisons by having rebate-eligible contractors and suppliers provide illustrative bids for a set of 5–10 common heat pump installation scenarios, for example, installing a ductless mini-split in a three-bedroom home.

States should also require contractors to provide hourly rates for different types of labor, since installation costs are often ~70% of total project costs. Contractors should only be designated as recommended or preferred service providers (with access to HEAR rebates) if they are willing to share cost data.

In addition, the central market-transformation team could facilitate information-sharing and data aggregation across states to limit confusion and duplication of data. This will increase price transparency and limit the work required at the state level to find price information and integrate with product technical performance data.

Phase 2. Encourage price and service-level competition among suppliers by providing consumers with information on how to judge value for money.

A second area to improve market outcomes is by promoting competition. Price transparency supports this goal, but to achieve market transformation programs need to go further to help consumers understand what products, specific to their circumstances, offer best value for money. 

In the case of a heat pump installation, this means taking account of fuel source, energy prices, house condition, and other factors that drive the overall value-for-money equation when achieving improved energy efficiency. Again, information asymmetry is at play. Many energy-efficiency consultants and HVAC contractors offer to advise on these topics but have an inherent bias to promoting their products and services. There are no easily available public sources of reliable benchmark price/performance data for ducted and ductless heat pumps for homes ranging from 1500 to 2700 square feet, which would cover 75% of the single-family homes in the United States. 

In contrast, the commercial building sector benefits from very detailed cost information published on virtually every type of building material and specialty trade procedure. Data from sources such as RSMeans provides pricing and unit cost information for ductwork, electrical wiring, and mean hourly wage rates for HVAC technicians by region. Builders of newly constructed single-family homes use similar systems to estimate and manage the costs of every aspect of the new construction process. But a homeowner seeking to retrofit a heat pump into an existing structure has none of this information. Since virtually all rebates are likely to be retrofit installations, states and the DOE have a unique interest in making this market more competitive by developing and publishing cost/performance benchmarking data. 

State programs have considerable leverage that can be used to obtain the information needed from suppliers and installers. The central market-transformation team should use that information to create a tool that provides states and consumers with estimates of potential bill savings from installation of heat pumps in different regions and under different utility rates. This information would be very valuable to low- and middle-income (LMI) households, who are to receive most of the funding under HEAR.

Phase 3. Use the rebate program to lower costs and promote best-value products by negotiating product and service-level agreements with suppliers and contractors and awarding a higher level of rebate to installations that represent best value for money.

By subsidizing and consolidating demand, SEOs will have significant bargaining power to achieve fair prices for consumers.

First, by leveraging relationships with public and private sector stakeholders, SEOs can negotiate agreements with best-value contractors, offering guaranteed minimum volumes in return for discounted pricing and/or longer warranty periods for participating consumers. This is especially important for LMI households, who have limited home improvement budgets and experience disproportionately higher energy burdens, which is why there has been limited uptake of heat pumps by LMI households. In return, contractors gain access to a guaranteed number of additional projects that can offset the seasonal nature of the business.

Second, as states design the formulas used to distribute rebates, they should be encouraged to create systems that allocate a higher proportion of rebates to projects quoted at or below the benchmark costs and a smaller proportion or completely eliminate the rebates to projects higher than the benchmark. This will incentivize contractors to offer better value for money, as most projects will not proceed unless they receive a substantial rebate. States should also adopt a similar process as New York and Wisconsin in creating a list of approved contractors that adhere to “reasonable price” thresholds.

Recommendation 2. For future energy rebate programs, Congress and DOE can make market transformation more central to program design. 

In future clean energy legislation, Congress should direct DOE to include the principles recommended above into the design of energy rebate programs, whether implemented by DOE or states. Ideally, that would come with either greater funding for administration and technical assistance or dedicated funding for market-transformation activities in addition to the rebate program funding. 

For future rebate programs, DOE could take market transformation a step further by establishing benchmarking data for “fair and reasonable” prices from the beginning and requiring that, as part of their applications, states must have service-level agreements in place to ensure that only contractors that are at or below ceiling prices are awarded rebates. Establishing this at the federal level will ensure consistency and adoption at the state level.

Conclusion

The DOE should prioritize funding evidence-based market transformation strategies to increase the return on investment for rebate programs. Learning from U.S.-funded programs for global public health, a similar approach can be applied to the markets for energy-efficient appliances that are supported under the HEAR program. Market shaping can tip the balance towards more cost-effective and better-value products and prevent rebates from driving up prices. Successful market shaping will lead to sustained uptake of energy-efficient appliances by households across the country.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

The Technology Modernization Fund (TMF) currently funds multiyear technology projects to help agencies improve their service delivery. However, many agencies abdicate responsibility for project outcomes to vendors, lacking the internal leadership and project development teams necessary to apply a product model approach focused on user needs, starting small, learning what works, and making adjustments as needed. 

To promote better outcomes, TMF could make three key changes to help agencies shift from simply purchasing static software to acquiring ongoing capabilities that can meet their long-term mission needs: (1) provide education and training to help agencies adopt the product model; (2) evaluate investments based on their use of effective product management and development practices; and (3) fund the staff necessary to deliver true modernization capacity. 

Challenge and Opportunity

Technology modernization is a continual process of addressing unmet needs, not a one-time effort with a defined start and end. Too often, when agencies attempt to modernize, they purchase “static” software, treating it like any other commodity, such as computers or cars. But software is fundamentally different. It must continuously evolve to keep up with changing policies, security demands, and customer needs. 

Presently, agencies tend to rely on available procurement, contracting, and project management staff to lead technology projects. However, it is not enough to focus on the art of getting things done (project management); it is also critically important to understand the art of deciding what to do (product management). A product manager is empowered to make real-time decisions on priorities and features, including deciding what not to do, to ensure the final product effectively meets user needs. Without this role, development teams typically march through a vast, undifferentiated, unprioritized list of requirements, which is how information technology (IT) projects result in unwieldy failures. 

By contrast, the product model fosters a continuous cycle of improvement, essential for effective technology modernization. It empowers a small initial team with the right skills to conduct discovery sprints, engage users from the outset and throughout the process, and continuously develop, improve, and deliver value. This approach is ultimately more cost effective, results in continuously updated and effective software, and better meets user needs.

However, transitioning to the product model is challenging. Agencies need more than just infrastructure and tools to support seamless deployment and continuous software updates – they also need the right people and training. A lean team of product managers, user researchers, and service designers who will shape the effort from the outset can have an enormous impact on reducing costs and improving the effectiveness of eventual vendor contracts. Program and agency leaders, who truly understand the policy and operational context, may also require training to serve effectively as “product owners.” In this role, they work closely with experienced product managers to craft and bring to life a compelling product vision. 

These internal capacity investments are not expensive relative to the cost of traditional IT projects in government, but they are currently hard to make. Placing greater emphasis on building internal product management capacity will enable the government to more effectively tackle the root causes that lead to legacy systems becoming problematic in the first place. By developing this capacity, agencies can avoid future costly and ineffective “modernization” efforts.

Plan of Action

The General Services Administration’s Technology Modernization Fund plays a crucial role in helping government agencies transition from outdated legacy systems to modern, secure, and efficient technologies, strengthening the government’s ability to serve the public. However, changes to TMF’s strategy, policy, and practice could incentivize the broader adoption of product model approaches and make its investments more impactful.

The TMF should shift from investments in high-cost, static technologies that will not evolve to meet future needs towards supporting the development of product model capabilities within agencies. This requires a combination of skilled personnel, technology, and user-centered approaches. Success should be measured not just by direct savings in technology but by broader efficiencies, such as improvements in operational effectiveness, reductions in administrative burdens, and enhanced service delivery to users.

While successful investments may result in lower costs, the primary goal should be to deliver greater value by helping agencies better fulfill their missions. Ultimately, these changes will strengthen agency resilience, enabling them to adapt, scale, and respond more effectively to new challenges and conditions.

Recommendation 1. The Technology Modernization Board, responsible for evaluating proposals, should: 

1. Assess future investments based on the applicant’s demonstrated competencies and capacities in product ownership and management, as well as their commitment to developing these capabilities. This includes assessing proposed staffing models to ensure the right teams are in place.
2. Expand assessment criteria for active and completed projects beyond cost savings, to include measurements of improved mission delivery, operational efficiencies, resilience, and adaptability. 

Recommendation 2. The TMF Program Management Office, responsible for stewarding investments from start to finish, should: 

1. Educate and train agencies applying for funds on how to adopt and sustain the product model. 
2. Work with the General Services Administration’s 18F to incorporate TMF project successes and lessons learned into a continuously updated product model playbook for government agencies that includes guidance on the key roles and responsibilities needed to successfully own and manage products in government.
3. Collaborate with the Office of Personnel Management (OPM) to ensure that agencies have efficient and expedited pathways for acquiring the necessary talent, utilizing appropriate assessments to identify and onboard skilled individuals. 

Recommendation 3. Congress should: 

1. Encourage agencies to set up their own working capital funds under the authorities outlined in the TMF legislation. 
2. Explore the barriers to product model funding in the current budgeting and appropriations processes for the federal government as a whole and develop proposals for fitting them to purpose. 
3. Direct OPM to reduce procedural barriers that hinder swift and effective hiring. 

Conclusion 

The TMF should leverage its mandate to shift agencies towards a capabilities-first mindset. Changing how the program educates, funds, and assesses agencies will build internal capacity and deliver continuous improvement. This approach will lead to better outcomes, both in the near and long terms, by empowering agencies to adapt and evolve their capabilities to meet future challenges effectively.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

The United States currently observes a voluntary moratorium on explosive nuclear weapons testing. At the same time, the National Nuclear Security Administration (NNSA) is required by law to maintain the capability to conduct an underground nuclear explosive test at the Nevada National Security Site, if directed to do so by the U.S. president. 

Restarting U.S. nuclear weapons testing could have very negative security implications for the United States unless it was determined to be an absolute technical or security necessity. A restart of U.S. nuclear testing for any reason could open the door for China, Russia, Pakistan, and India to do the same, and make it even harder to condemn North Korea for its testing program. This would have significant security consequences for the United States and global environmental impacts.

The United States conducted over 1,000 nuclear weapons tests before the 1991 testing moratorium took effect. It was able to do so with the world’s most advanced diagnostic and data detection equipment, which enabled the US to conduct advanced computer simulations after the end of testing. Neither Russia or China conducted as many tests, and many fewer of those were able to collect advanced metrics, hampering these countries’ ability to match American simulation capabilities. Enabling Russia and China to resume testing could narrow the technical advantage the United States has held in testing data since the testing moratorium went into effect in 1992. 

Aside from the security loss, nuclear testing would also have long-lasting radiological effects at the test site itself, including radiation contamination in the soil and groundwater, and the chance of venting into the atmosphere. Despite these downsides, a future president has the legal authority—for political or other reasons—to order a resumption of nuclear testing. Ensuring any such decision is more democratic and subject to a broader system of political accountability could be achieved by creating a more integrated approval process, based on scientific or security needs. To this end, Congress should pass legislation requiring the NNSA administrator to certify that an explosive nuclear test is technically necessary to rectify an existing problem or doubt in U.S. nuclear surety before a test can be conducted.

Challenges and Opportunities

The United States is party to the 1963 Limited Test Ban Treaty, which prohibits atmospheric tests, and the Threshold Ban Treaty of 1974, limiting underground tests of more than 150 kilotons of explosive yield. In 1992, the United States also established a legal moratorium on nuclear testing through the Hatfield-Exon-Mitchell Amendment, passed during the George H.W. Bush Administration. After extending this moratorium in 1993, the United States, Russia, and China also signed the Comprehensive Nuclear Test Ban Treaty (CTBT) in 1996, which prohibits nuclear explosions. However, none of the Annex 2 (nuclear armed) states have ratified the CTBT, which prevents it from entering into force. 

Since halting nuclear explosive tests in 1992, the United States has benefited from a comparative advantage over other nuclear-armed states, given its advanced simulation and computing technologies, coupled with extensive data collected from conducting over 1,000 explosive nuclear tests over nearly five decades. The NNSA’s Stockpile Stewardship Program uses computer simulations to combine new scientific research with data from past nuclear explosive tests to assess the reliability, safety, and security of the U.S. stockpile without returning to nuclear explosive testing. Congress has mandated that the NNSA must provide a yearly report to the Nuclear Weapons Council, which reports to the president on the reliability of the nuclear weapons stockpile. The NNSA also maintains the capability to test nuclear weapons at the Nevada Test Site as directed by President Clinton in Presidential Decision Directive 15 (PDD-15). National Security Memorandum 7 requires the NNSA to have the capability to conduct an underground explosive test with limited diagnostics within 36 months, but the NNSA has asserted in their Stockpile Stewardship and Management plan that domestic and international laws and regulations could slow down this timeline. A 2011 report to Congress from the Department of Energy stated that a small test for political reasons could take only 6–10 months.

For the past 27 years, the NNSA administrator and the three directors of the national laboratories have annually certified—following a lengthy assessment process—that “there is no technical reason to conduct nuclear explosive testing.” Now, some figures, including former President Trump’s National Security Advisor, have called for a resumption of U.S. nuclear testing for political reasons. Specifically, testing advocates suggest—despite a lack of technical justification—that a return to testing is necessary in order to maintain the reliability of the U.S. nuclear stockpile and to intimidate China and other adversaries at the bargaining table. 

A 2003 study by Sandia National Laboratories found that conducting an underground nuclear test would cost between $76 million and $84 million in then-year dollars, approximately $132 million to $146 million today. In addition to financial cost, explosive nuclear testing could also be costly to both humans and the environment even if conducted underground. For example, at least 32 underground tests performed at the Nevada Test Site were found to have released considerable quantities of radionuclides into the atmosphere through venting. Underground testing can also lead to contamination of land and groundwater. One of the most significant impacts of nuclear testing in the United States is the disproportionately high rate of thyroid cancer in Nevada and surrounding states due to radioactive contamination of the environment.

In addition to health and environmental concerns, the resumption of nuclear tests in the United States would likely trigger nuclear testing by other states—all of which would have comparatively more to gain and learn from testing. When the CTBT was signed, the United States had already conducted far more nuclear tests than China or Russia with better technology to collect data, including fiber optic cables and supercomputers. A return to nuclear testing would also weaken international norms on nonproliferation and, rather than coerce adversaries into a preferred course of action, likely instigate more aggressive behavior and heightened tensions in response.

Plan of Action

In order to ensure that, if resumed, explosive nuclear testing is done for technical rather than political reasons, Congress should amend existing legislation to implement checks and balances on the president’s ability to order such a resumption. Per section 2530 of title 50 of the United States Code, “No underground test of nuclear weapons may be conducted by the United States after September 30, 1996, unless a foreign state conducts a nuclear test after this date, at which time the prohibition on United States nuclear testing is lifted.” Congress should amend this legislation to stipulate that, prior to any nuclear test being conducted, the NNSA administrator must first certify that the objectives of the test cannot be achieved through simulation and are important enough to warrant an end to the moratorium. A new certification should be required for every individual test, and the amendment should require that the certification be provided in the form of a publicly available, unclassified report to Congress, in addition to a classified report. In the absence of such an amendment, the president should make a Presidential Decision Directive to call for a certification by the NNSA administrator and a public hearing under oath to certify the same results cannot be achieved through scientific simulation in order for a nuclear test to be conducted.

Conclusion

The United States should continue its voluntary moratorium on all types of explosive nuclear weapons tests and implement further checks on the president’s ability to call for a resumption of nuclear testing.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

To help protect U.S. critical infrastructure workers from future pandemics and other biological threats, the next presidential administration should use the federal government’s grantmaking power to ensure ample supplies of high-quality respiratory personal protective equipment (PPE). The administration can take five concrete actions:

1. The Office of Pandemic Preparedness and Response Policy (OPPR) can coordinate requirements for federal agencies and recipients of federal emergency/disaster preparedness funding to maintain access to at least one reusable respirator per critical employee.
2. The Department of Labor’s Occupational Safety and Health Administration (OSHA) can initiate an occupational safety rule on reusable respirator resilience caches.
3. The Department of Health and Human Services’ Administration for Strategic Preparedness and Response (ASPR) can require PPE manufacturers receiving federal funding to demonstrate their robustness to extreme pandemics.
4. ASPR’s Strategic National Stockpile can start stockpiling reusable respirators.
5. The Federal Emergency Management Agency (FEMA) can leverage its public outreach experience to increase “peacetime” adoption of reusable respirators.

These actions would complete the Biden Administration’s existing portfolio of efforts to reduce the likelihood of dangerous PPE shortages in the future, reaffirming executive commitment to protecting vulnerable workers, building a resilient national supply chain, and encouraging innovation.

Challenge and Opportunity

The next pandemic could strike at any time, and our PPE supply chain is not ready. Experts predict that the chance of a severe natural epidemic could perhaps triple in the next few decades, and advances in synthetic biology are increasing the risk of deliberate biological threats. As the world witnessed in 2020, disposable PPE can quickly become scarce in a crisis. Inadequate stockpiles left millions of workers with insufficient access to respiratory protection and often higher death rates than the general public—especially the critical infrastructure workers who operate the supply chains for our food, healthcare, public safety, and other essential goods and services. In future pandemics, which could have a 4% to 11%+ chance of occurring in the next 20 years based on historical extrapolations, PPE shortages could cause unnecessary infections, deaths, and burnout among critical infrastructure workers.

Figure 1. Notional figure from Blueprint Biosecurity’s Next-Gen PPE Blueprint demonstrating the need for stockpiling PPE in advance of future pandemics.

Recognizing the vulnerability of our PPE supply chain to future pandemics, Section 3.3 of the National Biodefense Strategy and Implementation Plan directs the federal government to:

Establish resilient and scalable supply and manufacturing capabilities for PPE in the United States that can: (a) enable a containment response for; and (b) meet U.S. peak projected demand for healthcare and other essential critical infrastructure workers during a nationally or internationally significant biological incident.

At a high level, securing the supply of PPE during crises is already understood as a national priority. However, despite the federal government’s past efforts to invest in domestic PPE manufacturing, production capacity will still take time to ramp up in future scenarios. Our current stockpiles aren’t large enough to bridge that gap. Some illustrative math: there are approximately 50 million essential workers in the United States, but as of 2022 our Strategic National Stockpile only had about 540 million disposable N95 respirators. This is barely enough to last 10 days, assuming each worker only uses one per day. (One per day is even a stretch: extended use and reuse of disposable N95s often leads to air leakage around wearers’ faces.) State- and local-level stockpiles may help, but many states have already started jettisoning their PPE stocks as purchases from 2020 expire and the prudence of paying for storage becomes less visible. PPE shortages may happen again.

Fortunately, there is existing technology that can reduce the likelihood of shortages while also protecting workers better and reducing costs: reusable respirators, like elastomeric half-mask respirators (EHMRs). 

A single EHMR typically costs between $20 and $40. While the up-front cost of an EHMR is higher than the ~$1 cost of a disposable N95, a single EHMR can reliably last a worker for thousands of shifts over the entirety of a pandemic. Compared to disposable N95s, EHMRs are also better at protecting workers from infection, and workers prefer them to disposable N95s in risky environments. EHMR facepieces often have a 10-year shelf life, and filter cartridges typically have the same five-year shelf life of a typical disposable N95. A supply of EHMRs also takes up an estimated 1.5% of the warehouse space of the equivalent supply of disposable N95s.

Figure 2. The relative size of equivalent PPE stockpiles. Source: Blueprint Biosecurity’s Next-Gen PPE Blueprint.

Some previous drawbacks of EHMRs were their lack of filtration for exhaled air and the unclear efficacy of disinfecting them between uses. Both of those problems are on their way to being solved. The newest generation of EHMRs on the market (products like the Dentec Comfort-Air Nx and the ElastoMaskPro) provide filtration on both inhalation and exhalation, and initial results from ongoing studies presented by the National Institute for Occupational Safety and Health (NIOSH) have demonstrated that they can be safely disinfected. (Product links are for illustrative purposes, not endorsement.)

Establishing stable demand for the newest generation of EHMRs could drive additional innovation in product design or material use. This innovation could further reduce worker infection rates by eliminating the need for respirator fit testing, improving comfort and communication, and enabling self-disinfection. It could also increase the number of critical infrastructure workers coverable with a fixed stockpile budget by increasing shelf lives and reducing cost per unit. Making reusable respirators more protective, ergonomic, and storable would improve the number of lives they are able to save in future pandemics while lowering costs. For further information on EHMRs, the National Academies has published studies that explore the benefits of reusable respirators.

The next administration, led by the new OPPR can require critical infrastructure operators that receive federal emergency/disaster preparedness funding to maintain resilience caches of at least one reusable respirator per critical infrastructure worker in their workplaces—enough to protect those workers during future pandemics.

These resilience caches would have two key benefits:

1. Because many U.S. critical infrastructure operators, from healthcare to electricity providers, receive federal emergency preparedness funds, these requirements would bolster our nation’s mission-critical functions against pandemics or other inhalation hazards like wildfire smoke. At the same time, the requirements would be tied to a source of funding that could be used to meet them. 
2. By creating large, sustainable private-sector demand for domestic respirators, these requirements would help substantially grow the domestic industrial base for PPE manufacturing, without relying on future warm-basing payments like those that Congress recently rescinded.

By taking action, the next administration has an opportunity to reduce the future burden on taxpayers and the federal government, help keep workers safe, and increase the robustness of domestic critical infrastructure.

Plan of Action

Recommendation 1. Require federal agencies and recipients of federal emergency/disaster preparedness funding to maintain access to at least one reusable respirator per critical employee.

OPPR can coordinate a process to define the minimum target product profile of reusable respirators that employers must procure. To incentivize continual respirator innovation, OPPR’s process can regularly raise the minimum performance standards of PPE in these resilience caches. These standards could be published alongside regular PPE demand forecasts. As products expire every 5 or 10 years, employers would be required to procure the new, higher standard. 

OPPR can also convene representatives from each agency that administers emergency/disaster preparedness funding programs to critical infrastructure sectors and can align those agencies on language for:

• Requiring funding recipients to maintain access to resilience caches of enough PPE.
• Explicitly including “maintaining access to PPE resilience caches” as an acceptable and encouraged use of funding.

The Cybersecurity and Infrastructure Security Agency (CISA) within the Department of Homeland Security (DHS) can update its definition of essential workers and set guidelines for which employees would need a reusable respirator.

FEMA’s Office of National Continuity Programs can recommend reusable respirator stocks for critical staff at federal departments and agencies, and the Centers for Medicare and Medicaid Services (CMS) can also set a requirement for healthcare facilities as a condition of participation for receiving Medicare reimbursement.

Recommendation 2. Initiate an occupational safety rule on reusable respirator resilience caches.

To cover any critical infrastructure workplaces that are not affected by the requirements in Recommendation 1, OSHA can also require employers to maintain these resilience caches. This provision could be incorporated into a broader rule on pandemic preparedness, as a former OSHA director has suggested.

OSHA should also develop preemptive guidance on the scenarios in which it would likely relax its other rules. In normal times, employers are usually required to implement a full, costly Respiratory Protection Program (RPP) whenever they hand an employee an EHMR. An RPP typically includes complex, time-consuming steps like medical evaluations that may impede PPE access in crises. OSHA already has experience relaxing RPP rules in pandemics, and preemptive guidance on when those rules might be relaxed in the future would help employers better understand possible regulations around using their resilience caches.

Recommendation 3. Require PPE manufacturers receiving federal funding to demonstrate their robustness to extreme pandemics.

The DHS pandemic response plan notes that workplace absenteeism rates during extreme pandemics are projected to be to 40%. 

U.S. PPE manufacturers supported by federal industrial base expansion programs, such as the investments managed by ASPR, should be required to demonstrate that they can remain operational in extreme conditions in order to continue receiving funding. 

To demonstrate their pandemic preparedness, these manufacturers should have:

• An on-site stockpile of enough reusable respirators for the maximum number of workers they might hire during a manufacturing surge.
• A comprehensive pandemic response plan that addresses workplace transmission protection.
• Regular exercises and independent evaluations of their pandemic response plans.

Recommendation 4. Start stockpiling reusable respirators in the Strategic National Stockpile.

Inside ASPR, the Strategic National Stockpile should ensure that the majority of its new PPE purchases are for reusable respirators, not disposable N95s. The stockpile can also encourage further innovation by making advance market commitments for next-generation reusable respirators.

Recommendation 5. Leverage FEMA’s public outreach experience to increase “peacetime” adoption of reusable respirators.

To complement work on growing reusable respirator stockpiles and hardening manufacturing, FEMA can also help familiarize the workforce with these products in advance of a crisis. FEMA can use Ready.gov to encourage the general public to adopt reusable respirators in household emergency preparedness kits. It can also develop partnerships with professional groups like the American Industrial Hygiene Association (AIHA) or the Association for Health Care Resource & Materials Management (AHRMM) to introduce workers to reusable respirators and instruct them in their use cases during both business as usual and crises.

Conclusion

Given the high and growing risk of another pandemic, ensuring that we have an ample supply of highly protective respiratory PPE should be a national priority. With new reusable respirators hitting the market, the momentum around pandemic preparedness after the COVID-19 pandemic, and a clear opportunity to reaffirm prior commitments, the time is ripe for the next administration to make sure our workers are safe the next time a pandemic strikes.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

Ten years after the creation of the U.S. Digital Service (USDS) and 18F (an organization with the General Services Administration that helps other government agencies build, buy, and share technology products), the federal government still struggles to buy, build, and operate technology in a speedy, modern, scalable way. Cybersecurity remains a continuous challenge – in part due to lack of modernization of legacy technology systems. As data fuels the next transformative modernization phase, the federal government has an opportunity to leverage modern practices to leap forward in scaling IT Modernization.

While there have been success stories, like IRS’s direct file tool and electronic passport renewal, most government technology and delivery practices remain antiquated and the replacement process remains too slow. Many obstacles to modernization have been removed in theory, yet in practice Chief Information Officers (CIOs) still struggle to exercise their authority to achieve meaningful results. Additionally, procurement and hiring processes, as well as insufficient modernization budgets, remain barriers.

The DoD failed to modernize its 25-year-old Defense Travel System (DTS) after spending $374 million, while the IRS relies on hundreds of outdated systems, including a key taxpayer data processing system built in the 1960s, with full replacement not expected until 2030. The GAO identified 10 critical systems across various agencies, ranging from 8 to 51 years old, that provide essential services like emergency management, health care, and defense, costing $337 million annually to operate and maintain, many of which use outdated code and unsupported hardware, posing major security and reliability risks. Despite the establishment of the Technology Modernization Fund (TMF) with a $1.23 billion appropriation, most TMF funds have been expended for a small number of programs, many of which did not solve legacy modernization problems. Meanwhile the urgency of modernizing antiquated legacy systems to prevent service breakdowns continues to increase.

This memo proposes a new effort to rapidly scale proven IT modernization strategies across the federal government. The result will be a federal government with the structure and culture in place to buy, build, and deliver technology that meets the needs of Americans today and into the future. 

Challenge and Opportunity 

Government administrations typically arrive with a significant policy agenda and a limited management agenda. The management agenda often receives minimal focus until the policy agenda is firmly underway. As a result, the management agenda is rarely well implemented, if it is implemented at all. It should be noted that there are signs of progress in this area, as the Biden-Harris Administration publishing its management agenda in the first year of the Administration, while the the Trump Administration did not publish its management agenda until the second year of the administration. However, even when the management agenda is published earlier, alignment, accountability and senior White House and departmental  leadership focus on the management agenda is far weaker than for the policy agenda.

Even when a PMA has been published and alignment is achieved amongst all the stakeholders within the EOP, the PMA is simply not a priority for Departmental/Agency leadership and there is little focus on the PMA among Secretaries/Administrators. Each Department/Agency is responsible for a policy agenda and, unless, IT or other management agenda items are core to the delivery of the policy agenda, such as at the VA, departmental political leadership pays little attention to the PMA or related activities such as IT and procurement.

 An administration’s failure to implement a management agenda and improve government operations jeopardizes the success of that administration’s policy agenda, as poor government technology inhibits successful implementation of many policiesThis has been clear during the Biden – Harris administration as departments have struggled to rapidly deliver IT systems to support loan, grant and tax programs, sometimes delaying or slowing the implementation of those programs. 

The federal government as a whole spends about 80% of its IT budget on maintenance of outdated systems—a percentage that is increasing, not declining. Successful innovations in federal technology and service delivery have not scaled, leaving pockets of success throughout the government that are constantly at risk of disappearing with changes in staff or leadership. 

The Obama administration created USDS and 18F/Technology Transformation Services (TTS) to begin addressing the federal government’s technology problems through improved adoption of modern Digital Services. The Trump administration created the Office of American Innovation (OAI) to further advance government technology management. As adoption of AI accelerates, it becomes even more imperative for the federal government to close the technology gap between where we are and where we need to be to provide the government services that the American people deserve. 

The Biden administration has adapted IT modernization efforts to address the pivot to AI innovations by having groups like USDS, 18F/TTS and DoD Software Factories increasingly focus on Data adoption and AI. With the Executive Order on AI and the Consortium Dedicated to AI Safety the Biden-Harris administration is establishing guidelines to adopt and properly govern increasing focus on Data and AI. These are all positive highlights for IT modernization – but there is a need for these efforts to deliver real productivity. Expectations of citizens continue to increase. Services that take months should take weeks, weeks should take days, and days should take hours. This level of improvement can’t be reached across the majority of government services until modernization occurs at scale. While multiple laws designed to enhance CIO authorities and accelerate digital transformation have been passed in recent years, departmental CIOs still do not have the tools to drive change, especially in large, federated departments where CIOs do not have substantial budget authority.

As the evolution of Digital Transformation for the government pivots to data, modernizedAgencies/Department can leap forward, while others are still stuck with antiquated systems and not able to derive value from data yet. For more digitally mature Agencies/Departments, the pivot to data-driven decisions, automation and AI, offer the best chance for a leap in productivity and quality gains. AI will fuel the next opportunity to leap forward by shifting focus from the process of delivering digital services (as they become norms) and more on the data based insights they ingest and create. For the Agencies/Departments “left behind” the value of data driven-decisions, automation and AI – could drive rapid transformation and new tools to deliver legacy system modernization.

The Department of Energy’s “Scaling IT Modernization Playbook” offers key approaches to scale IT modernization by prioritizing  mission outcomes, driving data adoption, coordinating at scale across government, and valuing speed and agility because, “we underrate speed as value”. Government operations have become too complacent with slow processes and modernization; we are increasingly outpaced by faster developing innovations. Essentially, Moore’s Law (posited by Gordon Moore that the number of transistors in an integrated circuit doubles every 18 months while cost increases minimally. Moore’s law has been more generally applied to a variety of advanced technologies) is outpacing successful policy implementation.

As a result, the government and the public continue to struggle with dysfunctional legacy systems that make government services difficult to use under normal circumstances and can be crippling in a crisis. The solution to these problems is to boldly and rapidly scale emerging modernization efforts across the federal government enterprise – embracing leaps forward with the opportunistic shift of data and AI fueled transformation. 

Some departments have delivered notably successful modern systems, such DHS’ Global Entry site and the State Department’s online passport renewal service. While these solutions are clearly less complex than the IRS’ tax processing system, which the IRS has struggled to modernize, they demonstrate that the government can deliver modern digital services under the right conditions. 

Failed policy implementation due to failed technology implementation and modernization will continue until management and leadership practices associated with modern delivery are rapidly adopted at scale across government and efforts and programs are retained between administrations. 

Plan of Action 

Recommendation 1. Prioritize Policy Delivery through the Office of Management and Budget (OMB) and the General Services Administration (GSA) 

First, the Administration should elevate the position of Federal CIO to be a peer to the Deputy Directors at the OMB and move the Federal CIO outside of OMB, while remaining within the Executive Office of the President, to ensure that the Federal CIO and, therefore, IT and Cybersecurity priorities and needs of the departments and agencies have a true seat at the table. The Federal CIO represents positions that are as important as but different from those of the OMB Deputy Directors and the National Security Advisor and, therefore, should be peers to those individuals, just as they are within departments and agencies, where CIOs are required to report to the Secretary or Administrator. Second, Elevate the role of the GSA Administrator to a Cabinet-level position, and formally recognize GSA as the federal government’s “Operations & Implementation” agency. These actions will effectively make the GSA Administrator the federal government’s Chief Operating Officer (COO). Policy, financial oversight, and governance will remain the purview of the OMB. Operations & Implementation will become the responsibility of the GSA, aligning existing GSA authorities of TTS, quality & proven shared services, acquisitions, and asset management with a renewed focus on mission centric government-service delivery. The GSA Administrator will collaborate with the President’s Management Council (PMC), OMB and agency level CIOs to coordinate policy delivery strategy with delivery responsibility, thereby integrating existing modernization and transformation efforts from the GSA Project Management Office (PMO) towards a common mission with prioritization on rapid transformation. 

For the government to improve government services, it needs high-level leaders charged with prioritizing operations and implementation—as a COO does for a commercial organization. Elevating the Federal CIO to an OMB Deputy Director and the GSA Administrator to a Cabinet-level position tasked with overseeing “Operations & Implementation” would ensure that management and implementation best practices go hand in hand with policy development, dramatically reducing the delivery failures that put even strong policy agendas at risk.

Recommendation 2. Guide Government Leaders with the Rapid Agency Transformation Playbook 

Building on the success of the Digital Services Playbook, and influenced by the DOE’s “Scaling IT Modernization Playbook” the Federal CIO should develop a set of “plays” for rapidly scaling technology and service delivery improvements across an entire agency. The Rapid Agency Transformation Playbook will act both as a guide to advise agency leaders in scaling best practices, as well as a standard against which modernization efforts can be assessed. The government wide “plays” will be based on practices that have proven successful in the private and public sectors, and will address concepts such as fostering innovation, rapid transformation, data adoption, modernizing or sunsetting legacy systems, and continually improving work processes infused with AI. Where the Digital Services Playbook has helped successfully innovate practices in pockets of government, the Rapid Agency Transformation Playbook will help scale those successful practices across government as a whole. 

A Rapid Agency Transformation Playbook will provide a living document to guide leadership and management, helping align policy implementation with policy content. The Playbook will also clearly lay out expected practices for Federal employees and contractors who collaborate on policy delivery. 

Recommendation 3. Fuel Rapid Transformation by Creating Rapid Transformation Funds

Congress should create Rapid Transformation Funds (RTF) under the control of each Cabinet-level CIO, as well as the most senior-IT leader in smaller departments and independent agencies. These funds would be placed in a Working Capital Fund (WCF) that is controlled by the cabinet level CIO or the most senior IT leader in smaller departments and independent agencies. These funds must be established through legislation. For those departments that do not currently have a working capital fund under the control of the CIO, the legislation should create that fund, rather than depending on each department or agency to make a legislative request for an IT WCF. 

This structure will give the CIO of each Department/Agency direct control of the funds. All RTFs must be under the control of the most senior IT leader in each organization and the authority to manage these funds must not be delegatable.The TMF puts the funds under the control of GSA’s Office of the Federal Chief Information Officer (OFCIO) and a board that has to juggle priorities among GSA OCIO and the individual Departments and Agencies. Direct control will streamline decision making and fund disbursement. It will help to create a carrot to align with existing Federal Information Technology Acquisition Reform Act (FITARA) (i.e., stick) authorities. In addition, Congress should evaluate how CIO authorities are measured under FITARA to ensure that CIOs have a true seat at the table.

The legislation will provide the CIO the authority to sweep both expiring and canceling funds into the new WCF. Seed funds in the amount of 10% of department/agency budgets will be provided to each department/agency. CIOs will have the discretion to distribute the funds for modernization projects throughout their department or agency and to determine payback model(s) that best suit their organization, including the option to reduce or waive payback for projects, while the overarching model will be cost reimbursement.

The RTF will enhance the CIO’s ability to drive change within their own organization. While Congress has expanded CIO authorities through legislation three different times in recent years, no legislation has redirected funding to CIOs. Most cabinet level CIOs control a single digit percentage of the Department’s IT budget. For example, the Department of Energy CIO directly controls about 5% of DOE’s IT spending. Direct control of a meaningfully sized pool of money that can be allocated to component IT teams by the cabinet level CIO enables that cabinet level CIOs to drive critical priorities including modernization and security. Without funding, CIO authorities amount to unfunded mandates. The RTF will allow the CIO to enhance their authority by directly funding new initiatives. A reevaluation of the metrics associated with CIO authorities would ensure that CIOs have a true seat at the table.

Recommendation 4. Ensure transformation speed through continuity by establishing a Transformation Advisory Board and department/agency management councils. 

First, OMB should establish a Transformation Advisory Board (TAB) within the Executive Office of the President (EOP), composed of senior and well-respected individuals who will be appointed to serve fixed terms not tied to the presidential administration and sponsored by the Federal CIO. The TAB will be chartered to impact management and technology policy across the government and make recommendations to change governance that impedes rapid modernization and transformation of government. Modeled after the Defense Innovation Board, the TAB will focus on entrenching rapid modernization efforts across administrations and on supporting, protecting, and enhancing existing digital-transformation capabilities. Second, each department and agency should be directed to establish a management council composed of leaders of the department/agency’s administrative functions to include at least IT, finance, human resources, and acquisition, under the leadership of the deputy secretary/deputy administrator. In large departments this may require creating a new deputy secretary or undersecretary position to ensure meaningful focus on the priorities, rather than simply holding meaningless council meetings. This council will ensure that collaborative management attention is given to departmental/agency administration and that leadership other than the CIO understand IT challenges and opportunities. 

A Transformation Advisory Board will ensure continuity across administrations and changes in agency leadership to prevent the loss of good practices, enabling successful transformative innovations to take root and grow without breaks and gaps in administration changes. The management council will ensure that modernization is a priority of departmental/agency leadership beyond the CIO.

Ann Dunkin contributed to an earlier version of this memo.

This idea was originally published on November 13, 2020; we’ve re-published this updated version on October 22, 2024.