July 24, 2000

TO: Rep. Michael Castle, Chair, Subcommittee on Children, Youth, and Families Rep. William Goodling, Chair, Committee on Education and the Workforce

FR: Gerald Sroufe Director of Government Relations American Educational Research Association RE: INITIAL COMMENTS ON H.R. 4875

RE: INITIAL COMMENTS ON H.R. 4875

We welcome this opportunity to offer a perspective about H.R.4875, currently titled: Scientifically Based Education Research, Statistics, Evaluation, and Information Act of 2000. While we have had access to the bill for just over a week, and find that it involves much more than "simple" reauthorization of the Office of Educational Research and Improvement, Committee staff have helped us to anticipate the legislative proposals with regard to OERI, and to be prepared to share our perspective.

Members on the Committee will be interested to learn that our association has sponsored an independent Panel for the Improvement of Education Research (PIER) specifically to make recommendations to the Congress for the reauthorization of OERI. The PIER membership included prominent education researchers, representatives of associations and the business community, and policy makers. It was co-chaired by the Honorable Steve Gunderson and Lorrie Shepard, past president of AERA. (The full membership is attached.)

It appears that the bill now under consideration and the PIER recommendations share a number of basic premises, but that there are also some important differences. Areas of agreement include belief in the appropriateness of a strong federal role in the area of education research, understanding that the quality of education research must be improved, and insistence that research priorities and processes be independent of partisan politics. Among the significant differences in assumptions of PIER and the Committee bill are the following: (1) PIER believes that more effective communication of research findings to educators is a major shortcoming, noting that dissemination is at least as great a problem as quality of education research; (2) PIER advocates that the authorization include a plan for phased, substantial, increments of funding for education research, but not for additional bureaucracy; (3) PIER, recognizing the tumultuous history of new starts and restructuring already suffered by the federal education research agency, recommends minimal changes to achieve the reauthorization goals, and favors replication of structures and processes that have been successful in the Department of Education and other federal agencies. (4) Finally, PIER has drawn on the experience of the last decade to propose continued set-asides for essential research and dissemination programs such as the national education research centers, the national education regional laboratories, and field-initiated research.

There are areas of substantial agreement between H.R. 4875 and the PIER recommendations, as well as areas of inconsequential differences (e.g., establishing four year or six year terms for the head of the research agency). However, there are also areas of major disagreement -- related to the principles noted above -- that merit comment.

1. Dissemination is regarded as a central shortcoming of the federal education research program. Getting quality research to the field is a complex problem of long standing, one which has clearly not been solved by the two entities assigned this task in the bill: the education library and ERIC. PIER feels that it was essential to fix responsibility for this fundamental role at the very top of the organization: with the Assistant Secretary. The PIER recommendation makes coordination and dissemination the chief responsibilities of the head of the agency, leaving others the responsibility for conduct of quality research and statistics.

The panel notes that one of the strengths of the Department of Education is its many and varied links with the education practitioner community, something which agencies such as the National Research Council, National Science Foundation, and National Institutes of Health can not offer. (It is noted that the National Reading Panel report carried out by NICHD is to be disseminated by the Department of Education.) The panel judges the most appropriate source of education research priorities to be educators and policy makers in the field; and it is cognizant of the critical importance of education context in the conduct of effective education research.

2. PIER members considered and rejected the idea of moving OERI outside the Department of Education. They recommend that OERI remain within the department because: (1) in an applied field such as education, there must be the strongest possible link between research and practice, (2) PIER could see no viable future for an independent education research agency in competition with the National Research Council and other federal research agencies that conduct education research, and (3) PIER recognizes that funding and appointments for the proposed "independent" agency necessarily will be closely linked to the administration in office in any event.

PIER believes that it is possible to achieve political independence necessary for education research programs within the Department, and recommends the following: Creation of a National Center for Education Research (NCER) to parallel NCES, with an appointed, fixed-term Commissioner of Education Research, and an advisory board of experts.

3. Appropriation levels for education research have strangled the agency and made any efforts at internal improvement problematic. The seeds of failure of H.R. 4875 are carried in its assumption that a research agency can first "prove itself" with inadequate resources. As noted in studies by the National Research Council, the President's Advisory Panel on Science and Technology, and testimony by previous assistant secretaries of both parties, the poverty of resources has shaped the research agenda and is responsible for many of the most stringent criticisms of its work.

PIER acknowledges that a large influx of new money under present conditions would accomplish little, at least in the short run. But there is no reason an incremental plan for increased appropriations to support planning, recruitment, and increased productivity could not be authorized.

4. In addition to rejecting the idea of moving the agency outside the department, PIER also rejects the idea of a new title and elaborate restructuring of the agency. The agency has experienced so many efforts at fundamental reorganization -- from NIE to OERI to Institutes -- that it seemed prudent to propose only changes deemed essential to address problems that would enhance performance. PIER believes it makes sense to borrow from those organizational structures in the department that provided appropriate political independence and effectiveness, such as the National Center for Education Statistics.

5. AERA favors competition and peer review in all areas of education research. However, painful experience has taught the lesson that research programs that do not have mandated resource parameters are impossible to maintain. Consequently, while not presuming to determine the number of national research centers that should be funded, we urge that some stipulations be established regarding the length of contracts and the minimum amount of funding required for any established. Similarly, if there is to be a robust field-initiated research program, it is essential that the authorization provide a percentage set-aside. Prior to the set-aside now in place for field-initiated research, funding seldom exceeded $1 million dollars annually (for the entire program), and in some years was $0.

Several components of H.R. 4875 merit much more thought than we have been able to provide in this brief interval: (1) opening federal research competitions for national centers to for-profit groups or individuals, (2) burdening an authorization bill with excessively defined research procedures (the pending NSF reauthorization Bill, titled modestly, National Science Foundation Reauthorization Act, makes no effort to stipulate the research procedures of the agency), and (3) creation of an independent evaluation agency to evaluate federal education programs. The PIER discussions did not consider the need for an agency to supplement Congressional oversight, and concentrated on the need to provide research that would support improvement efforts such as Title I. However, we wish to continue our thinking about this interesting idea in the weeks ahead, along with the proposals for NAGB, NAEP, and NCES included in H.R. 4875.

We hope to have an opportunity to provide a more extensive and comprehensive perspective on H.R.4875 in the near future. Thank you for your attention to these comments. Please call on me for any additional information or for copies of the PIER Recommendations.

Copies: Members of the Committee

Attachments: PIER Principles for Reauthorization of OERI, PIER Panel Membership