Blog

The U.S. Department of Education recently proposed significant changes to the Education Department General Administrative Regulations (EDGAR), which govern how the Department makes billions of dollars of discretionary grants every year. Last week, America Forward responded through a public comment in partnership with the Coalition for Evidence-Based Policy and Results for America. 

In general, our organizations strongly support efforts to improve the accessibility and impact of federal grantmaking, and appreciate the Department of Education’s long leadership in driving evidence-based solutions. However, we are concerned that several of the proposed changes may have counterproductive effects.

Our comments emphasized the following points: 

• Preserve evidence standards that distinguish rigorous evidence. The Department proposed to replace three current EDGAR definitions of evidence-based approaches (strong, moderate, and promising evidence) with simpler definitions aligned to the statutory Every Student Succeeds Act (ESSA) evidence definitions at 20 U.S.C. 7801(21)(A)(i). However, as America Forward and Results for America discussed in a report earlier this year, moving to the ESSA standards would substantially weaken all three standards of evidence by eliminating key protections against cherrypicking, core methodological standards, and consideration of the context in which programs are implemented. This action would, in fact, constitute a step back from the standards promulgated under the first Trump Administration that explicitly sought to align the Department’s regulatory approach with ESSA’s provisions, while maintaining a higher standard of rigor under EDGAR.

• Expand capacity for evidence reviews while maintaining strong standards and avoiding gaming. The Department also proposed The NRPM also proposes to add a new definition of “evidence framework” that would, at the Department’s discretion, shift the burden of evidence review from Department-funded evidence reviewers to reviewers funded by third parties. We appreciate the Department’s emphasis on accelerating the process of reviews and expanding accessibility, including by enabling potential applicants to pre-assess the evidence standard for which their cited research would qualify. However, we are concerned that the Department’s proposed approach would lead to unintended consequences that threaten the rigor of evidence and, ultimately, the impact of public investments under evidence-based grantmaking priorities. 

• Ensure reliability and accessibility of funding. We appreciate the Department’s intent to maximize outcomes from public investments. However, we are concerned that several other proposed changes would have counterproductive impacts in implementation, including a competitive preference on direct cost rates, references to “merit-based” hiring, and allowing terminations for convenience.

We look forward to continuing to support efforts to strengthen the use of evidence-based approaches, and support robust evidence-building, at the Department of Education and across the federal government.