On February 28, 2011, the President issued a memorandum to Federal agencies entitled “Administrative Flexibility, Lower Costs, and Better Results for State, Local, and Tribal Governments.” In that Memorandum, the President asked Federal agencies, in consultation with State, local, and tribal governments, to take actions that would provide increased flexibility—where it will yield the same or improved outcomes at lower cost—in Federal programs administered by State, local, and tribal governments.
As part of its efforts to meet the objectives of the Memorandum and to encourage the greater use of existing flexibilities, the Department is writing today to solicit ideas for three different types of pilot projects. Two of these types of projects would allow for the relaxation or waiver of requirements related to either (1) time-and-effort reporting under Office of Management and Budget (OMB) Circular A-87 or (2) the documentation or demonstration of compliance with other administrative record-keeping and reporting requirements similar to time and effort. In exchange for granting flexibility in either of these areas, the Department would require entities selected for a pilot project to use alternative methods of ensuring that Federal education dollars are appropriately used to meet overarching program goals—for example, by measuring outputs or improvements in student achievement associated with Federal investments. The Department is looking for examples of burdensome administrative record-keeping and reporting requirements as well as ideas on what alternative methods for ensuring proper oversight of Federal funds might be.
The Department is also interested in ideas for a third type of project that would consider better mechanisms for taking advantage of the existing flexibility that allows for the consolidation of funds by schools that operate a Title I, Part A (Title I) program under the Schoolwide Programs authority in section 1114 of the Elementary and Secondary Education Act of 1965, as amended (ESEA). This flexibility can reduce requirements associated with time-and-effort reporting, in addition to providing other benefits. The Department is also interested in ideas for how we could better promote this existing but underutilized consolidation authority.
Based upon ideas received in the three areas listed above, the Department will solicit applications for a small number of pilot projects. Pilot projects may be led by State educational agencies, local educational agencies (LEAs or school districts), or consortia of LEAs within a State. The Department believes that pilot projects can help identify best practices as well as options for amending time and effort and other reporting requirements more generally. These efforts will seek alternative ways to reach the same goals as time-and-effort reporting—strong and transparent fiscal accountability—while placing a greater focus on measuring the results the programs are designed to achieve. By reducing reporting burden and replacing it with more effective alternatives, States and districts will have the opportunity to realize efficiency gains and cost savings, an important objective in a time of constrained resources. Comments received in response to this post will inform that solicitation, but we cannot guarantee that all ideas put forth will be reflected in the project solicitation. Each of the anticipated project types is described in greater detail below.
(1) Alternatives to time-and-effort reporting that track measurable and meaningful outcomes
Time-and-effort reporting is a government-wide requirement that provides a uniform approach for allocating costs. This means being able to verify that individuals whose salaries are supported by a Federal program are spending the appropriate amount of time carrying out the allowable activities of that program.
Though time-and-effort reporting is intended to ensure the proper allocation of Federal funds, we have heard that the process of fulfilling its documentation requirements can be overly burdensome. This type of reporting also does not provide information on the services given or, more importantly, the impact of those services on the students who are the intended beneficiaries of the Federal funds. Consequently, we are interested in exploring alternatives under which we would waive the requirement for time-and-effort reporting in exchange for grantees providing strong performance-based reporting and auditing. This could, for example, include developing a new set of indicators—using existing student performance data available to schools or using newly collected data—that would provide information to auditors and others on areas such as the achievement of students served by the relevant Federal programs. We encourage ideas for employing existing data in innovative ways and bringing together traditionally separate reporting systems to produce a fuller picture of how Federal funds are used to benefit the students they are intended to serve.
The Department is interested in both general comments and specific recommendations on the design elements of this pilot. Recommendations might include suitable outcome measures for the students served under affected programs, how progress will be determined, and how much progress is sufficient. We are also interested in the identification of barriers that might prevent implementation and what role the Department can play in relieving these barriers.
(2) Alternatives to other administrative record-keeping and reporting requirements similar to time and effort that utilize measurable and meaningful outcomes
In addition to time-and-effort reporting, the Department has other standards for administrative record keeping and reporting. These standards are also intended to ensure the proper use of Federal dollars and protect the taxpayers’ interests. And in many cases Federal requirements defer to State standards or requirements. Nonetheless, we are concerned that there may be record-keeping and reporting requirements that are particularly time-consuming, not aligned with State or local fiscal accounting needs, or ineffective at producing data that are relevant and useful to the State or district. We believe that there could be ways to reduce these administrative record-keeping and reporting requirements while still ensuring the proper use of Federal funds. Successful ideas in this area would be ones that do not change overall policy requirements—such as serving students from low-income families—but instead find better ways to demonstrate compliance.
(3) Better ways to take advantage of, or promote, the existing flexibility allowing the consolidation of funds in schoolwide program schools
The ESEA allows a school that has at least 40 percent students from low-income families to operate Title I as a schoolwide program. This program allows a school to use Title I funds, together with other Federal, State, and local funds, to upgrade its entire educational program in order to improve the academic performance of the lowest-achieving students. Implementing a schoolwide program provides Title I schools with significantly more flexibility in the use of Title I and other Federal funds. A school implementing a schoolwide program may consolidate Federal funds with State and local funds and spend those funds to carry out its schoolwide plan, which must be designed to meet the needs of students in the school, as identified through a comprehensive needs assessment. If a school consolidates its Federal funds, it is exempt from most of the statutory and regulatory requirements of the Federal programs whose funds are consolidated, provided the school meets the intent and purposes of those programs. Moreover, the school need not maintain separate fiscal accounting records by program that identify the specific activities supported by the Federal funds. For example, personnel in a schoolwide program school that consolidate Federal, State, and local funds generally do not have to keep time-and-effort records. (See Non-Regulatory Guidance, Title I Fiscal Issues, page 49, available at http://www2.ed.gov/programs/titleiparta/fiscalguid.pdf.)
Currently, only a small number of schools are taking advantage of the flexibility to consolidate funds. We are interested in understanding why this flexibility is not used more often and what can be done to better promote it. The Department would particularly like to know if there are barriers at the State or district level to implementing this flexibility and, where appropriate, what role the Department can play in reducing these barriers. In addition, we are interested in ideas for pilot projects that would present better ways of consolidating funds, consistent with the law, to encourage more eligible schools to use this flexibility.
Principles for idea development
Below are three principles that we ask commenters to consider in developing pilot ideas. In addition, we ask that all project ideas submitted include descriptions of how they will result in a quantifiable reduction in burden, especially in terms of time saved for teachers so they can focus more time on student learning, and in terms of any cost savings.
Provide evidence that funds are producing outcomes tied to overall program goals. We are interested in ideas for projects that waive or reduce administrative record-keeping and reporting requirements in exchange for providing outcome-based evidence about the effectiveness of Federal programs. We can envision a number of ways projects could follow this principle. For example, a district might measure whether teachers supported by specific Federal programs contribute to raising student achievement for individuals served by those programs. Or a district might choose to break down existing data on academic outcomes in a new way to show that students receiving services under a Federal program are demonstrating improved results.
Encourage the use of data and the development and linkage of data systems. We are interested in ideas for projects that would use data systems to automate the time-and-effort reporting process. For example, rather than having teachers fill out time sheets, districts might document time and effort through a process in which personnel, financial, and student databases connect so that a district can generate reports to demonstrate that teachers supported by Federal programs are serving students who are eligible to receive benefits under those programs.
Pursue reforms that have long-term efficiency and productivity benefits. Related to the data system principle outlined above, we are interested in ideas for projects whose initial efforts would lead to greater benefits in the long run, especially in terms of burden reduction, efficiency, and productivity. For example, a data system that meets the time-and-effort reporting requirements by connecting personnel, financial, and student learning databases could be later employed for performance-based budgeting to ensure that highly effective teachers are equitably distributed or to provide achievement information that can drive practice.
Process for submitting ideas
The Department is encouraging all interested parties to submit, in the comment section below, ideas about pilot projects in the three areas described above. We ask that States, districts, schools, and others consider the principles outlined above as they think about creative ideas in the three areas. In addition, ideas submitted for the first two project types should include new measures of ensuring that Federal education dollars are being appropriately used to meet overarching program goals. We encourage an active and open dialogue on the ideas that are generated in order to help us bring the most promising ideas forward for action.
Guidelines for Submission
So that we receive ideas in the most usable format, we are asking respondents to follow certain guidelines when posting ideas. Please include the following information in a clearly identified manner:
- Your organization
- The Federal program(s) involved
- The specific burden you are addressing with your proposed project
- Your idea related to that burden
- What requirements or burdensome elements you would need waived by the Department, OMB, or your State in order to move forward with your idea or pilot project
- The process you would use for establishing goals and measuring outcomes if your pilot idea were implemented
As an alternative to submitting comments on this post, respondents may submit ideas or questions directly to the Department by sending an e-mail with the above information to BurdenPilots@ed.gov. Please note that portions of ideas submitted via e-mail may be posted on the blog to encourage discussion.In order to provide additional time for interested parties to develop and submit ideas we will continue to accept comments on a rolling basis.
The implementation of a pilot project pursuant to this notice will not affect any State- or district-level statutory or regulatory requirement related to Federal civil rights laws, providing a free appropriate public education to students with disabilities, or serving English Learners in accordance with the law.