Recently, Nora Gordon explained the evidence requirements of federal COVID aid in an article for Future Ed. Excerpts of the piece appear below:
The American Recovery Plan’s $123 billion Elementary and Secondary Schools Emergency Relief (ARP ESSER) fund requires that educators spend a significant portion of the money on things that have been found through research to make a difference for students. In reality, federal policymakers have given the education sector wide latitude in the evidence they bring to bear in spending Covid aid.
Districts, which receive the bulk of ESSER funds, must spend 20 percent of their money to address learning loss through the implementation of “evidence-based” interventions. States must also reserve funds for evidence-based interventions to address learning loss (5 percent of the total the state receives), to support evidence-based summer enrichment programs (1 percent of the total), and to support evidence-based comprehensive after-school programs (1 percent of the total).
What does evidence-based mean? The ARP uses the same definition as the federal Every Student Succeeds Act (ESSA), which establishes four tiers of evidence and requires a subset of struggling schools to use the top three levels.
Unlike ESSA, though, the Covid relief dollars can be spent on interventions with any of the four tiers of evidence, including the least demanding. That includes spending options that don’t appear in evidence lists or research clearinghouses. In its latest guidance, released in May, the U.S. Department of Education again clarified that any of the four tiers “counts.”
The most permissive option is for evidence that “demonstrates a rationale.” That’s because you don’t need a study of the specific activity, strategy, or intervention to demonstrate a rationale for its effectiveness.
What constitutes a rationale? The new guidance describes it like this:
- Explain the reasoning for how the intervention, if successful, would improve outcomes. For example, if the reading intervention focuses on teaching common sound-spelling patterns, you could express that reasoning in very few words: understanding common sound-spelling patterns helps students learn to read. This would make sense if you are targeting reading-related learning loss or want to improve reading more generally. The Regional Educational Laboratory Pacific offers resources for making a logic model, which is a more structured option for explaining the reasoning behind your choice of intervention. If you use another planning model in ongoing district work, such as a theory of action, you can use that to meet this requirement.
- The reasoning must be “based on high-quality research findings or positive evaluation.” High-quality research findings need not meet the strong, moderate, or promising levels described above: they could come from other types of research, whose methodologies don’t map to these definitions, or reflect a consensus view from a body of high-quality descriptive research. These findings, importantly, can relate to components of an intervention (like that instruction in common sound-spelling patterns helps students learn to read), and need not speak to a specific, often branded, intervention that incorporates the component. Reputable sources for accessible versions of such research findings include the federally-sponsored What Works Clearinghouse (WWC) Practice Guides, and academic sources like the Annenberg Institute’s Ed Research for Recovery, the Campbell Collaboration, the Evidence Project at the Center for Reinventing Public Education, and FutureEd. You could point to this WWC guide for research supporting your reasoning about the reading intervention.
- Finally, you must engage in “ongoing efforts to examine the effects of such activity, strategy, or intervention.” While this commitment may seem like an extra step, it is actually a benefit: it will help determine whether the intervention is working well, needs tweaking, or should go. It’s also the only way to build an evidence base on new approaches. To satisfy this requirement, you could commit to comparing reading scores for students participating in the intervention with groups of similar students, perhaps in different schools or cohorts, who didn’t have that option.
Education leaders should embrace the flexibility in ARP ESSER to make smart local choices about what to implement, driven by local needs and values, and not by misperceptions of which interventions count as evidence-based.