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The U.S. Department of Education stuck to its guns in releasing final rules for the $650 million , or i3, grant program, standing firm in the face of criticism that its proposed guidelines demanded too much from applicants in the way of private-sector match and evidence to back up their proposals.
In the final rules and application for the program, released March 8, department officials left intact a demand that applicants secure 20 percent in matching funds from the private sector.
But in a nod to concerns that such a requirement could be burdensome, particularly to smaller districts and in a difficult economy, the department relaxed the timing so that prospective grant recipients don鈥檛 need to secure the private funding until they鈥檝e been notified that they are in line to win.
In essence, a foundation or other organization will know that its matching donation is a sure-fire bet.
鈥淥nce you鈥檙e eligible to be a winner, we hope we鈥檝e made it much easier to find those dollars,鈥 said James H. Shelton, the department鈥檚 assistant deputy secretary for innovation and improvement.
In addition, the department is still allowing applicants to seek a waiver of the matching-funds requirement at the time they apply.
The U.S. Department of Education released final regulations governing the Investing in Innovation, or i3, grant program. Among the highlights:
ELIGIBILITY
School districts and nonprofits (only if they鈥檙e partnered with a district or a consortium of public schools) are eligible to apply.
PURPOSE
The goal is to scale up innovative ideas that can improve achievement among at-risk students.
AWARDS
鈥 鈥凄别惫别濒辞辫尘别苍迟鈥 grants of up to $5 million must be linked to programs that have 鈥渞easonable research-based findings or theories.鈥
鈥 鈥淰补濒颈诲补迟颈辞苍鈥 grants of up to $30 million will go to programs supported by 鈥渕oderate鈥 evidence.
鈥 鈥淪cale up鈥 grants of up to $50 million will go for programs that have 鈥渟trong鈥 evidence of success and can be scaled up to the national, regional, or state level.
TIMING
The deadline for applying is May 11. All funds must be awarded by Sept. 30, 2010.
GRANT REQUIREMENTS
Applicants, unless granted a waiver, must secure a 20 percent private-sector match before they can win a grant.
BONUS POINTS
Applicants will get a competitive advantage for focusing on early education, college access, rural schools, and students with disabilities and those who are limited-English-proficient.
SOURCE: U.S. Department of Education
The matching requirement had been one of the most criticized elements of the i3 program鈥檚 draft guidelines, which were unveiled in October. Few other changes were made to the proposed guidelines for the grant program, which is meant to foster and expand innovative education strategies at the district level.
The competition, funded by the American Recovery and Reinvestment Act, is open to school districts and nonprofit partners working with a district or consortium of schools. It will provide awards of up to $55 million each. Applications are due in mid-May, with awards made in September.
In Syracuse, N.Y., city schools鈥 Superintendent Dan Lowengard plans to apply for a $30 million validation grant to expand his 20,900-student district鈥檚 Say Yes to Education program, which is part of a New York-based nonprofit that works in five cities to expand college access for low-income students.
In Syracuse, the program provides support services in a few schools, starting as early as the elementary grades, to get students on a college-bound track, and eventually provide qualifying students with college scholarships.
Mr. Lowengard essentially has a ready-made proposal鈥攖he matching dollars will come from the Say Yes nonprofit, which will also provide the evidence to help back up the program.
鈥淲e have the model, and we鈥檙e trying to implement it, but it鈥檚 going slowly,鈥 he said. 鈥淲hat the $30 million would do is ensure it鈥檚 a district-wide program, and not just in a few of our schools.鈥
The i3 program is the second of two high-profile competitive-grant programs funded by the economic-stimulus law, and is illustrative of the Obama administration鈥檚 desire to push education improvement through competition for federal dollars. The other program, the $4 billion Race to the Top competition, is open only to states.
Despite its smaller prize, the i3 program has drawn intense interest because it鈥檚 open to districts and nonprofits, and is much more open-ended in the kinds of proposals being sought.
The heart of the i3 program also remains intact: The $650 million will be divided into three tiers of awards, with the most lucrative going to those proposals that have the most evidence of past success in helping students.
Despite complaints during the public-comment period that the Education Department wouldn鈥檛 be requiring enough evidence from applicants鈥攐r would be demanding too much鈥攐fficials made no changes to how much research is needed to back up applicants鈥 proposals.
Grant Levels Vary
The largest, or 鈥渟cale up,鈥 grants鈥攚orth up to $50 million each鈥攚ill require 鈥渟trong鈥 evidence, such as program evaluations that used random assignment of students.
The second-tier, 鈥渧alidation鈥 grants of up to $30 million each will go to proposals that show 鈥渕oderate鈥 evidence, such as those that use sophisticated statistical techniques to try to measure the true effects of a program.
The final-tier, 鈥渄evelopment鈥 grants are wild cards to a degree; they are $5 million awards to proposals that are each based on a 鈥渞easonable鈥 hypothesis or theory.
鈥淭he overall design of the competition tries to account for the importance of evidence at each stage of innovation,鈥 Mr. Shelton said.
The rigid rules on evidence are likely to relegate rural school districts, in particular, to competing in the small-dollar 鈥渄evelopment鈥 category, said Doris Terry Williams, the executive director of the Arlington, Va.-based Rural School and Community Trust, which is working with rural districts and schools to develop consortia that would apply for these grants.
鈥淭he really stressful thing is there really are innovations around rural school, but they have not been subjected to that gold standard for research and innovation, so they don鈥檛 get listed as models or strategies,鈥 she said.
For each tier, the level of evidence required is an all-or-nothing eligibility requirement that will be judged by department officials; an applicant that doesn鈥檛 have the research to back up a proposal for that particular tier should not bother applying.
Eye on Evidence
While the level of evidence did not change from the original proposal, the final rules do spell out how much emphasis the department is placing on evidence鈥攁nd what criteria will matter most for each level of grant.
Each tier will be scored on a 100-point scale, based on seven criteria: need for and quality of the project; evidence; applicant鈥檚 track record of success; quality of proposed evaluation of a winning project; ability to scale up; sustainability; and quality of management plan and personnel.
In the largest, scale-up grants, evidence is what matters most: It鈥檚 worth 20 percent of an applicant鈥檚 grade. For the smallest, development grants, evidence is worth just 10 percent. But those smallest grants place a significant amount of weight on the need for the project, and the applicant鈥檚 track record鈥攅ach is worth 25 percent of the final grade.
鈥淔or innovation, it鈥檚 not just about coming up with cool inventions; it鈥檚 about finding things that can go to scale,鈥 Mr. Shelton said.
The department also kept competitive priorities that will reward applicants with bonus points if their proposals focus on early education, college access, students with disabilities and limited English proficiency, and rural schools. Each of those categories would earn an applicant one bonus point, except for the rural schools category, which garners two bonus points on the 100-point scale.
The department is bracing for more than 1,000 applications to be judged by peer reviewers hand-picked for their experience, and who will be vetted to minimize or eliminate conflicts of interest.