California’s planning process for a “Cradle-to-Career” data system has reached a critical juncture, as the Workgroup charged with making recommendations about the system considers governance options and the selection of an entity to manage it. Past efforts to develop a statewide data system in California were stymied over concerns about the make-up, roles, and responsibilities of the entity selected to manage the system, and how data collected by that entity would be used and by whom. The agenda for the June Workgroup meeting had called for a vote on the type of managing entity to recommend; however, group members indicated that they needed more time and additional information about the options.
One member suggested that the Workgroup develop a set of criteria for the selection of a managing entity and evaluate information about each option against those criteria. This is precisely the approach EdInsights took in the final report of our series examining California’s approach to gathering and sharing longitudinal data on students’ progress through the state’s education systems. The criteria we developed, shown in Table 1 below, largely overlap with those suggested by Workgroup members at the meeting. Primary among the criteria, in our view, should be a focus on the public good—that is, on ensuring that the managing entity for the data system has a mission focused on the use of the data to help various stakeholders understand student progress and outcomes, as well as attainment of equity goals, across the educational pipeline, in order to facilitate better-informed decisions.
Table 1: A Set of Criteria for Evaluating Governance Options
|Public Good||The mission is focused on using cross-sector data to produce information of value to policymakers, educators, students/families, and the public in a transparent way, for the purpose of improving student learning and other outcomes, including equity goals.|
|Data Security||Data are kept secure to ensure the privacy of individual students and to maintain compliance with state and federal laws.|
|Data Quality||Information in the data system is complete and accurate and relevant for addressing issues related to student success.|
|Cost and Time||The data system can be developed, maintained, and used in a reasonable timeframe and at a reasonable cost to provide a good return on taxpayers’ investment.|
|Technical Feasibility||The data system relies on well-established technology and allows for incorporating technical improvements over time.|
|Political Feasibility||The data system and resulting information/analyses can achieve and maintain the support and trust of various stakeholders.|
|Sustainability||The data system can be maintained through changes in leadership at the state, system, and institutional levels.|
Note: Table originally included in EdInsights’ report, A Hunger for Information: California’s Options to Meet its Statewide Education Data Needs
EdInsights assessed several options for a managing entity against the criteria, with two of the options being the same ones under consideration by the Workgroup—(1) a new state agency (or office within an existing agency), or (2) a joint powers authority (JPA) made up of agencies participating in the data system. Our final recommendation was based on what we learned through interviews with over 70 stakeholders, including state policy staff, state agency staff, local and system-level education officials, researchers, and education advocates. In addition, we pulled together an advisory group of stakeholders to review our criteria and weigh in about how the options stacked up against them. In the end, we determined that a state data agency/office created for the purpose of developing and managing a statewide data system would better meet the criteria than a JPA, with some of our considerations shown in Table 2 below. The governing board for the agency/office would need to include representation from among participating agencies, of course, but should be balanced with representation from other state entities (e.g., Legislative Analyst’s Office, Department of Finance, and other agencies with a broad focus on the public interest).
Table 2: Assessment of Options for a Managing Entity
|Criterion||Considerations and Comparisons|
|Public Good|| – A state agency/office could be assigned a clear cross-sector, neutral, statewide mission through the statute creating it, and be orientated toward transparent use of the data as part of that mission. While having no role in recommending policy, it would be oriented toward facilitating access to the data by applied researchers who could make recommendations based on their analyses. Its accountability to the interests of the public and taxpayers would be clear.
– A JPA would not be independent of the participating agencies. It would be less likely to adhere to a cross-sector, statewide mission and less oriented toward facilitating access to and use of the data for research due to conflicting priorities. It would offer little opportunity for oversight by the state or other stakeholders outside the participating agencies.
|Data Security||– Keeping individuals’ information secure in compliance with state and federal laws could be equally valued and implemented by either entity.|
|Data Quality|| – A state agency/office could have good leverage with participating agencies to ensure data quality.
– In a JPA, each agency would understand well the quality issues with its own data, but may have less leverage with each other than would a state agency to ensure overall data quality.
|Cost and Time|| – A state agency/office would take more time and resources to establish, though it could leverage existing state infrastructure to create some efficiencies. All staff and other resources of the entity would be dedicated to the state’s goals in establishing the data system. It would have to operate within state civil service and other processes that can be somewhat inflexible, although it could be exempted from some requirements in statute if deemed necessary.
– A JPA could be established quickly. However, existing agency staff have limited capacity to take on additional tasks, and any new staff or resources may not be dedicated solely to the statewide data work due to competing priorities at the agencies. It could receive grant funding, but those dollars would only supplement the state funds that would be primarily relied on to support it. Once established, it could operate with more flexibility, but not necessarily at less cost.
|Technical Feasibility||– Navigating the technical challenges involved in establishing a statewide data system could be done by either entity, though a state agency/office would provide the state with more direct control over technology investments to incorporate improvements or adapt to new needs over time than would be the case with a JPA controlled by the participating agencies.|
|Political Feasibility||– A state agency/office may face resistance from participating agencies who wish to maintain control of all uses of the data they collect, and may be drawn to a JPA for that reason. However, policymakers and other stakeholders would have the most trust in an independent, non-political state data office.|
|Sustainability|| – Once created (and funded), a state agency/office, with its cross-sector, statewide mission, would persist unless specifically eliminated by state policy.
– A JPA would require the continued commitment of all participating agencies. New leadership could change the priority assigned and resources allocated to the cross-sector, statewide role in the context of competing interests to address the agencies’ own priorities.
Note: Table adapted from one included in EdInsights’ report A Hunger for Information: California’s Options to Meet its Statewide Education Data Needs
Our highest priority was ensuring that the governance structure is focused on the transparent use of an important public resource—administrative data collected by public agencies—to achieve the greatest good for all Californians. Our research into California’s current data structures and processes, the history of prior attempts to create a statewide data system, and the challenges encountered in efforts to share and use data across agencies, pointed to governance by a non-political state data agency/office (with representation by the participating agencies) as the best option. This conclusion has also been reached by others who have examined the issue.
In the current context, with California’s dual health and economic crises related to COVID-19, it is even more important that the governance structure ensure access to and use of this resource to understand the impact of the crises on marginalized and vulnerable populations, and ways to mitigate the effects moving forward. While it may be challenging for the state to dedicate resources to the creation of a new entity, the costs may be less than assumed, and there are ways to leverage existing state investments. Creating an office within an existing state agency—one that is independent of the agencies that will be participating in the system—would minimize the need for new administrative overhead and could leverage office space and other infrastructure. And it is not clear that a JPA would cost less to operate once created, as any entity will need sufficient staff capacity and other resources to carry out its mission. The Workgroup is also considering an option we did not contemplate—a nonprofit auxiliary to an existing state agency. This option is worth considering in the context of our criteria (or a set developed by the Workgroup) to see if it might offer the benefits of a neutral state agency/office at less cost or with more flexibility, while maintaining the independence and public accountability that are advantages of a state entity.
As close observers of the state’s planning process, we are encouraged by the Workgroup’s determination to carefully evaluate governance options against a set of criteria. Most states already have data systems that merge individual-level K-12, postsecondary education, and workforce data, but not all of them have set up governance entities and structures that facilitate effective use of their data systems to inform decision-making by various constituencies. If California is to follow the example of the more successful states like Washington and Kentucky, ensuring that the Cradle-to-Career Data System is governed by a neutral entity with some independent authority and adequate resources to carry out its mission is critical.