The Grant Center drafts APTS Comments on the Education Department General Administration Regulations
February 14, 2013
In December 2012, the U.S. Department of Education (DOE) released a notice inviting comments on the proposed changes to the Education Department General Administration Regulations (EDGAR). These regulations provide guidance to the DOE’s administration of formula and competitive grant programs. The proposed changes reflect the Department’s desire for a more effective and efficient process when selecting discretionary grantees, and to better focus applicants on the particular goals and objectives of the programs to which they are applying. APTS supports that objective and suggests some modifications that would provide greater opportunity for local stations serving their communities by providing critical educational services.
In particular, APTS provided comments on four of the five significant regulation changes proposed by the DOE. These include:
- Performance Measurement: Proposed changes would allow for predefined performance measurement requirements covering performance measures, baseline data, performance targets and performance data. APTS encourages the department to make clear the importance that these measurements are aligned to the goals of the program and take into consideration the size and scope of the grant, the applicant, and the medium for delivery of services and activities under the grant.
- Procurement and Subgrant Processes for Entities Name in Applications: The DOE proposes to revise the prohibition on subgrants to allow grantees to subgrant in order to meet the purposes of a particular program. The discretion of when to subgrant would be left to the DOE. APTS encourages this decision to subgrant be left at the local level and give the grantee the flexibility to determine whether they will subgrant, and to open the parameters of potential grantees to include community-based media organizations.
- Selection Criteria: The DOE revises language to require grantees with projects that integrate with or build on similar or related efforts, to use existing funding streams from other programs or policies supported by the community, state and federal resources. Given the difficulty of stations and other nonprofits in accessing multiple state and federal funding streams, APTS proposes the language be changed to make this regulation optional based on the extent to which grantees can practically access complimentary funding streams.
- Evidence of Effectiveness: Proposed changes would establish procedures for giving special consideration to applications supported by strong or moderate evidence of effectiveness. APTS supports these proposed changes, however, requests additional clarification that special considerations would apply to both existing programs with strong or moderate evidence of effectiveness, as well as new programs proposing to adopt and adapt such models.
The deadline for comment on these proposals was February 12, 2013. The Department now needs to prepare a response to each comment received, which it will publish in the same Federal Register notice that announces the final EDGAR changes. Because there are a large number of proposed changes, which may provoke a large number of comments, and because the final notice will need to go through Office of Management and Budget clearance, it is likely that the final regulations will not be issued for at least a few more months, and it is possible that they will not effect U.S. Department of Education grant-making until Fiscal Year 2014.
Read the comments in their entirety here.
Read the U.S. Department of Education’s proposed rules here.
Read the Grant News article which highlights the proposed changes to EDGAR.
