Let the Sunshine In

Evidence-based decision-making requires data. We can disagree over the merits of using evidence to make decisions and we can also worry about the quality of the data collected, but if we hope to ground decisions in facts we need data.

As all higher education researchers know, there are enormous barriers that prevent the use of data in decision-making about program effectiveness. Think it's difficult to study the k-12 system? Come over to the dark side sometime, where de-centralized colleges and universities get to act independently when making decisions about granting data access, and nearly all find some convoluted way to hide behind FERPA.

Oh FERPA, that big hairy monster that claims to protect students' rights by shielding them from the benefits of evidence-based practices. Paying skyhigh tuition to your college while assuming they have ensured the way they teach actually "works"? Think again--- in all likelihood, the only people who've looked at the data are on the inside; administration-paid institutional researchers who are over-worked and underpaid, and most importantly tasked with responding to administrator whims and reporting requirements-- leaving little time for deep, thoughtful inquiry.

FERPA is very often used to deny external researchers access to student record data. Most often, we are simply told "Can't. FERPA doesn't allow it." "Oh that FERPA, that silly, silly FERPA. We WANT to give you the evidence we're doing a great job, but sorry, can't compromise student privacy."

Most of this is completely bogus, and thankfully the Data Quality Campaign has been working to reform FERPA, bringing it into the 21st century with all of its security protections. Back in April DQC had a big win, when the Department of Education released new proposed amendments to FERPA. The changes would "facilitate fuller access for research and evaluation purposes to student data contained in state longitudinal data systems (SLDSs) in order to increase accountability and transparency for educational outcomes and to contribute to a culture of innovation and continuous improvement in education, while at the same time enhancing privacy protections through expanded requirements for written agreements as the basis for disclosures of data and US ED enforcement mechanisms. They would authorize fuller, more cost effective use of state-level student data for research, evaluation, and accountability, subject to clear privacy protections, as well as effective use of data across all levels of education to evaluate and improve education programs."

Rock on! This was simply an excellent step.

Oh but wait-- here comes Dupont Circle. This morning, around 30 higher education associations released a letter objecting to the proposed regs. They are all for research, they say, but the privacy protections aren't strong enough.

Why am I not surprised? I hate to be so cynical, but if these associations really were supportive of the main reform goals, the letter could have begun with much stronger, clearer statements about the need for higher education to benefit from research-based practices, and denouncing the historical resistance to that culture. The privacy concerns could then be framed as necessary modifications to "make this work"-- instead, the letter comes off as weak whining at best, and typical platitudes about protecting student privacy at worst.

In recent years I've watched brave colleges and universities step up to facilitate external research and integrate it into their practices. The University of Wisconsin System and the Wisconsin Technical Colleges are among them. Let's hope their national associations get on board.

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