Monday, October 19, 2009

When Innovation Isn't Innovative (or WI3)

October 6 Secretary of Education Duncan announced ED's priorities for grants under the $650 million Investing In Innovation Fund (I3). I'd recommend you read the regulations yourself to see what strikes you about the proposed regulations and associated grant making. The regulations were posted on October 9 for a 30 day public comment period.

I was excited by the title Investing In Innovation. There has been little educational innovation funded over the past 8 years. I was looking forward to seeing new ideas for teaching and learning being encouraged.
the Investing in Innovation Fund focuses on four key assurances, or education reform areas, that will help achieve this goal: (1) Improvements in teacher effectiveness and ensuring that all schools have effective teachers, (2) gathering information to improve student learning, teacher performance, and college and career readiness through enhanced data systems, (3) progress toward college- and career- ready standards and rigorous assessments, and (4) improving achievement in low-performing schools through intensive support and effective interventions.
Then I read the proposed regulations. Two of the categories, Scale Up, and Validation require that a proposal focus on programs that have already been shown to be successful. The third, the Development Grants section does provide limited funding for ideas that have not been tested.

There's no definition of Innovation, nor is there a sense that ED is really interested in innovation since most of the funding will go to activities that have a proven record of success.

In order to be eligible to submit a proposal, either by an LEA (local educational agency a.k.a. school district) or non-profit, the entity must have a proven record of "significantly closing the achievement gaps between groups of students." There is also a required 20% in-kind contribution from non-federal funds.

The regulations, as proposed, make it very difficult to generate any innovative ideas that could significantly improve the way we educate our youth. Basically ED is asking for a retooling of existing ideas. That doesn't fit my expectation for investing in innovation.

The 20% in-kind funding makes it impossible for many school districts or non-profit research and development organizations to submit a proposal.

As of today, 10 days into the comment period, there were 20 comments posted prior to mine. Though when I submitted my comments the system said it could take weeks before the submission appears online. I hope and encourage you to add your voice to the public comments.

There are many elements of the proposed rules and grants that could benefit from comment.

If we don't comment now, we have no right to complain about the final regulations.

The docket ID for making comments is ED-2009-011-0012