Earlier today, the U.S. Department of Education released non-regulatory guidance for the Student Support and Academic Enrichment Grant (SSAEG) program (as authorized by Title IV, Part A of the Every Student Succeeds Act). This guidance is important, because it lays out in (debatably) human-readable language how the Department interprets the legislative language and intent of Congress in implementing specific provisions and programs in the nation’s new K-12 education law. State departments of education lawyers and staff (and savvy school district leaders) will use this guidance to move forward with their plans for implementing the SSAEG program to meet state and local needs in concert with other education policy priorities and funding plans. Vendors and other school service providers will also review the guidance to shape the development and marketing of their offerings to K-12 schools.
I’ve previously written and spoken about the SSAEG program, since it includes the only educational technology authority (and funding) directed to K-12 districts and schools under current federal education law. For instance, I’ve done my own independent read and review of the legislative text. I’ve offered advice to state departments of education on the steps they can take to maximize the impact of the program. And, I’ve commented on a proposal by the U.S. Department of Education to restructure the funding formula to increase the odds of program impact.
The 47-page guidance document covers a range of important topics, including details about the role of state departments of education in implementing the program, school district and consortia application requirements, and the applicability of provisions related to: ‘supplement, not supplant,’ accessibility, targeting of services, and private school participation. The guidance also clarifies and provides numerous examples of allowable uses of funds under the program, the standards of evidence to be applied in selecting interventions, as well as general advice on effective program implementation.
In reviewing the guidance, I am struck by three things: (1) how the Department interpreted the allowable funding provisions with respect to technology purchases, (2) how the Department referenced evidence to justify technology investments under program authority, and (3) the proverbial elephant in the room that the guidance doesn’t address (i.e., the overall funding level and structure of the program and what affect it will have on program implementation and impact). More on each of these below.
Do You Understand the Words Coming Out of My Mouth?
The U.S. Department guidance seems to clearly communicate that they interpret ESSA to – in fact – mandate a 15 percent cap on spending on all technology devices, software, and systems under the educational technology priority of the SSAEG program. While other ESSA programs (such as Title I) allow for less restrictive purchase of educational technology, the Department in both their language and numerous examples seem to draw a hard line on their interpretation under SSAEG. For example:
- The guidance clearly states that up to 15 percent of SSAEG technology program funds can be spent on technology, with at least 85 percent reserved for technology-related professional development. No other categories of allowable expenditures under the technology authority are offered.
- By technology, the Department means: “devices, equipment, software applications, platforms, digital instructional resources and/or other one-time IT purchases.” This seems all-encompassing to me. Perhaps an enterprising marketer may disagree, but I tend to think they will be on shaky ground to argue that their school technology is not covered under this definition.
- Under the other two program authorities under SSAEG – ‘Well-Rounded Educational Opportunities’ and ‘Safe and Healthy Students’ – there are no examples of allowable technology-based solutions offered by the Department. Based on my experience, I think it a mistake to read this as an oversight or omission.
I happen to be well aware that many creative ideas were advanced by lobbyists on how to interpret this 15 percent provision on technology purchases under the SSAEG program. My read is that they were completely and utterly rebuffed: Ann Whalen 1 – EdTech Lobby 0.
But Enough About Me, Let’s Talk About You… What Do YOU Think of Me?
For each of the three broad programmatic foci of the SSAEG program, the Department provides commentary and numerous examples of promising programs (many pointing to quantitative improvements in student outcomes). While the Department includes a disclaimer that the included examples and research citations are not endorsements, it nonetheless provides insight into the social networks and broader education dialogue that influence Department staff and leadership.
It is for this reason that is incredibly striking to me that the Department cites no independent study or source in the discussion of the technology authority under SSAEG; rather, all citations are to Department publications (or those of its contractors). This is in stark contrast to a broader set of citations in discussions about the ‘Well-Rounded Educational Opportunities’ and ‘Safe and Healthy Students’ authorities.
While the writing of non-regulatory guidance should not be held to the same standard as an academic literature review, one is nonetheless left wondering how meaningful this omission might be. Was it simply a lack of interest or care by Department staff? Is this a symptom of a lack of coordination across internal offices within the agency? Do ED staff even have access to independent sources of rigorous research and information on educational technology implementation and outcomes? Given apparent (if not actual) conflicts of interest in writing and research about educational technology, is there even agreement about what constitutes an independent, honest broker source of information? The U.S. Department of Education released its first national educational technology plan 20 years ago. Are there no touchstone reports or studies that ED felt it important to reference to help the broader education community make best use of federal program dollars?
Instead of speculating on the answers to these questions, let me just offer up a caution of sorts: Wikipedia defines groupthink as “a psychological phenomenon that occurs within a group of people in which the desire for harmony or conformity in the group results in an irrational or dysfunctional decision-making outcome. Group members try to minimize conflict and reach a consensus decision without critical evaluation of alternative viewpoints by actively suppressing dissenting viewpoints, and by isolating themselves from outside influences.”
My takeaway: If we expect technology to be treated as a serious education policy issue, we should expect and demand better.
The Elephant in the Room
Despite the claims that the SSAEG program would boost technology funding for schools (and even setting aside the ruling on the 15 percent cap), based on what we know about the structure of the program and federal appropriations the reality is far different.
For its part, the guidance offered by the Department attempts to draw the distinction on what provisions apply to school districts on either side of the $30,000 funding dividing line. This is the special legislative rule that is designed to reduce burden for school districts receiving small allocations under the SSAEG program. This is an important provision that requires clarity.
Nonetheless, the reality of the matter is that most (and by most, I mean the vast majority of) school districts in the country will get very small allocations under the SSAEG program. The guidance document itself would lead readers to believe that the program will be offering significant new funding to meet myriad needs facing schools. Stay tuned, but the reality seems likely to be far, far more modest. Modest as in allocations of well under $30,000 per district (like $5,000 or less) to meet the three broad priorities served by the program: ‘Well-Rounded Educational Opportunities,’ ‘Safe and Healthy Students,’ and ‘Effective Use of Technology.’ As such, many of the provisions related to needs assessment, program implementation, and funding priorities discussed in the guidance will be simply irrelevant to many states and even more school districts.
Of course, in the future, perhaps we could see dramatically increased funding levels for SSAEG…but I’d not bet on it. And, of course, a new Administration could issue revised guidance that might change the Department’s interpretation of allowable expenditures or other important program rules.
As always, I welcome your comments and questions.