School Improvement RFP of the Week (1): Reading First Center Teaches Us About Conflicts of Interest
From Monday's issue of K-12Leads and Youth Service Markets Report
Announcement: Reading First Center for Technical Assistance Due July 21 (Jun 20), US Department of Education
Their Description: Under the Reading First Center for Technical Assistance the contractor shall provide technical support services, research, and capacity building activities for State and local Reading First Programs. The purpose of the Center is to deepen and update State understanding of scientifically based reading research (SBRR) and to facilitate, through multi-faceted technical assistance, the implementation and evaluation of Reading First efforts at all levels. The contractor shall be able to: 1) serve as a high-quality resource on scientifically based reading research; 2) provide technical assistance to build Local Educational Agency (LEA) and State Educational Agency (SEA) internal capacity to administer the program; 3) provide consultative assistance to individual states and districts; 4) propose expert speakers for conferences and meetings; and 5) identify and disseminate resource materials.
The amount of award fee the Contractor earns, if any, is based on a subjective evaluation by the Government of the quality of the Contractor’s performance in accordance with the award fee plan. The Government will determine the amount of award fee every 12 months beginning with the end of the 12th month of the base period. The Fee Determination Official (FDO) will unilaterally determine the amount of award fee.....
(A) The contractor, subcontractor, employee or consultant, has certified that, to the best of their knowledge and belief, there are no relevant facts or circumstances which could give rise to an organizational or personal conflict of interest... (or apparent conflict of interest) for the organization or any of its staff, and that the contractor, subcontractor, employee or consultant has disclosed all such relevant information if such a conflict of interest appears to exist to a reasonable person with knowledge of the relevant facts.
Conflicts may arise in... situations:
1. [A] potential contractor, subcontractor, employee or consultant has access to non-public information through its performance on a government contract.
2. [A] potential contractor, subcontractor, employee or consultant has worked, in one government contract, or program, on the basic structure or ground rules of another government contract...
3. Impaired objectivity - a potential contractor, subcontractor, employee or consultant, or member of their immediate family... has financial or other interests that would impair, or give the appearance of impairing, impartial judgment in the evaluation of government programs, in offering advice or recommendations to the government, or in providing technical assistance or other services to recipients of Federal funds as part of its contractual responsibility.
“Impaired objectivity” includes... : financial interests or reasonably foreseeable financial interests in or in connection with products, property, or services that may be purchased by an educational agency, a person, organization, or institution in the course of implementing any program administered by the Department; significant connections to teaching methodologies that might require or encourage the use of specific products, property or services; or significant identification with pedagogical or philosophical viewpoints that might require or encourage the use of a specific curriculum, specific products, property or services.
My Thoughts: The history of Reading First is one of actual and perceived conflicts of interest - personal, institutional, business, political, ideological and pedagogical. One way to begin repairing the damage done in the implementation of a laudable set of NCLB provisions would be for this center to wind up in the hands of what I’ve analogized to the construction industry’s “consulting architect.”