Technology vs. Title I
In a prior post, I noted that there is a disparity between current federal fiscal requirements and the way districts and schools are implementing instructional technologies. The technologies are way ahead of the assumptions that underlie the fiscal requirements. This is resulting in frustration for district program and fiscal directors who now have to be more creative in order to be compliant, and that is not good because it makes things unnecessarily complicated.
-- Check out the cross-post with our good (and cynical, insightful) friends at Title I-derland. --
No one doubts that the fiscal rules serve an important purpose. Let’s use Title I’s “supplement, not supplant requirement” as an example. The purpose of the requirement is basically to ensure that Title I funds are used to add on to and not replace state and local funds. The requirement applies in a “targeted assistance” or “schoolwide” setting. The distinction is important but the issue emerges most frequently in the targeted assistance setting, so let’s examine that first. (I’ll discuss schoolwide in more depth in a subsequent post. Also, be sure to check out Melissa Junge and Sheara Krvaric’s paper on SNShere and here.).
Auditors will look at each individual cost supported with Title I funds and ask three questions. If the answer is “yes” to any of the three, it is presumed that the federal funds supplant or replace state or local funds, and that creates a fiscal liability.
- Does the state or district require the program or services at issue regardless of the availability of federal funds?
- Did the state or district use state or local funds to pay for the program or services in prior years?
- Are state and local funds used to pay for the program or services for non-Title I eligible students?
The rule makes sense when applied to physical goods and services. It loses usefulness, however, with emerging virtual educational technologies. To clarify this point, I spoke to Michael Horn, the co-founder and executive director of Education of Innosight Institute, a nonprofit think tank devoted to applying the theories of disruptive innovation to problems in the social sector (he knows his stuff, so pay attention).
Michael points out that the market for personalized, tech-driven, academic instruction is growing. It took a foothold with credit recovery courses, grew into advanced coursework and is now making headway in high schools, with the lower grades close behind. Every year, additional evidence pops up to support his thesis, such as Rocketship Education and Grockit’s adaptive and collaborative instruction technologies. The list is growing — quickly.
These instructional tools are blurring the distinction between supplemental and non-supplemental services. Consider “game” learning as an example. One of the reasons that gaming is a hot education topic these days is because it requires students to master a topic before moving on. The technology adapts to the student’s level, and the student plays the game until he or she masters it. That is typically the opposite of what happens in a traditional classroom. (See Michael’s Education Next article on that here.)
Finally, Michael makes the point that smart district managers should deploy successful technologies as broadly as they can. Part of their job description is — or should be — to maximize the return on their investment (ROI) according to fiscal and academic indicators. Unlike the case with traditional “supplemental” material, the walls of a classroom, school or district do not bind instructional technology. The costs of scaling up, if they exist at all, are minimal. The ROI logic is clear. Why isn’t this happening more quickly? The current federal fiscal rules are, no doubt, part of the reason.
Now, go back and look at the three questions that give rise to the presumption of supplanting. The third, in particular, is problematic. The district cannot use state or local funds to pay for services that are also provided to Title I students with Title I funds. If we think it through, that means that Title I cannot be used for a program that can provide both supplemental instruction to eligible at-risk students and basic services for non Title I eligible students. In other words, Title I cannot handle the emerging adaptive instructional technology programs that can and are doing both. The result is inefficient. Compliance concerns are undermining smart business rules that focus on efficiency and effectiveness.
I think it’s crazy and totally unproductive — unless you are an auditor or attorney. I am pretty sure that is not what Congress intended to do with these rules, although with all the attorneys doing policy work in DC — guilty — you can never be too sure.