1. Make public, rapidly, all USDOE program offices' work, including correspodence, re requiring SEAs to correct negative audit findings, especially those related to USDOE-funded program implementation and SEAs' objections to corrective action recommendations. Make public, rapidly, USDOE assessments of actual SEA implementation of corrective actions. Stop blindly accepting SEA assurances that they have actually implemented effective corrective action. Start sanctioning SEAs which have given false assurances in this regard ... please. Remember the Virgin Islands?
2. Require actual physical audit and verification of underlying student-related data at the LEA, IEA and SEA level instead of just accepting edit checks and the like on data.
3. Since the USDOE OIG found years ago that many LEAs, IEAs and thus SEAs were mis-reporting kids with disabilities in the "moved, known to continue" exiting category instead of reporting them as dropouts, start a new, serious USDOE OIG audit program to assess the validity of reports of students exiting in this category.
4. OSEP is notorious for refusing to release SEA data re kids with disabilities, on reasonably specious bases, for years and years after the data has been received by USDOE. Establish a rule that this data, and ALL student-related data, submitted to USDOE by SEAs be made publicly available one year after submission to USDOE. We don't need stale numbers which have been massaged by SEAs and OSEP for lengthy periods of time. OSEP's latest reason for refusing to release SEA data re disabled kids is based on the contention that it can withhold because it hasn't decided on the format to use to present the data when it gets around to making it public. Chart or table? Puhleez! Give us the numbers; we can decide on the format ourselves.
5. Establish a high-level taskforce, with membership from Homeland Security IT professionals, re the security of student- and family-related data in LEA databases. Have the taskforce establish minimum security standards for LEA, IEA, SEA and school IT systems containing student-related data. Have the taskforce establish minimum recommended credentials for persons operating these databases and IT systems and make them public!
6. Require all evaluations of USDOE-funded programs to be made public within 6 months after completion.
7. Require that all audits of LEAs, IEAs and SEAs made in connection with any federal laws be made public within 6 months after completion.
8. Read all evaluations and audits done on programs funded in whole or in part with federal funds. Yes! Actually read them to see what you are funding and what our tax monies have been spent for. Stop accepting SEAs' own summaries of these evaluation reports instead of plowing all the way through them yourselves.
9. Where evaluations show that federal grant programs at the LEA and IEA level have failed to meet objective grant goals, require that entities applying for new or continued grants in the same areas write up formal analyses of why the prior grant program project failed and require that applications for new or continued grants in the same areas specifically deal with the failures previously identified.
10. For special education, stop "verifying" what SEAs submit solely via visits to SEAs and start auditing and verifying underlying submissions from LEAs and IEAs to the SEAs.
11. Separate USDOE compliance functions from program/operations functions inasmuch as there is an inherent conflict, and the folks who want to, and get to, give out the money always win. And the folks who think the money may have been stolen or wasted always lose.
12. Make ALL SEA data submissions public one year after receipt by USDOE, including all student-related numbers.
13. Sanction at least one major grant recipient - a SEA - for wrongly certifying that data it has submitted to USDOE is verified and accurate when it's not. Make the sanction significant.
14. Require in all federal grant programs that SEAs which receive the money make all the underlying data they receive re these programs public within 6 months of receipt. ALL of it. If they claim lack of IT/capacity to do so, use ARRA reporting as a model and haveUSDOE set up the mega web site where this information will be displayed.
15. Generally. open up the publicly-funded education system so that data and decisions made by all levels of government are available to the public - and quickly.
Generally, USDOE supports a Garbage In-Garbage Out data process and thus the data which it ultimately decides to make public is highly inaccurate and virtually totally unverified. "Misleading" is often a charitable adjective. As the federal dollars spent on education grow, this becomes more and more inappropriate and wasteful. If the data USDOE receives is nonsense, it is impossible to assess whether any particular federal program has "worked" or not.
16. Hold a monthly mandatory meeting for all USDOE personnel, from the top down, and remind everyone at each such meeting that USDOE's clients are students and their families - not SEAs, not IEAs, not LEAs and not schools. And when this upsets folks, do it again, and again, and again. Make Secretary Duncan be the first presenter.
17. Stop accepting SEA submissions and assurances as valid. Start auditing, verifying and rejecting those which do not meet stringent data quality standards for accuracy and reliability.