Public Comments and Letters of Support
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The undersigned organizations submit this joint comment to express serious concerns about the proposal by the Office of Management and Budget (OMB) to both overhaul its existing, nonbinding “Guidance for Federal Financial Assistance” and at the same time convert it into a government-wide regulation that would legally bind federal agencies and their recipients and subrecipients (collectively “recipients”) of federal grants and other forms of federal financial assistance. The proposal would elevate the Trump administration’s preferences over Congressional mandates for how taxpayer dollars should be spent, judicial interpretations of what is or is not lawful, expert judgments of the rigor and quality of proposed research and programming, and state and local leaders’ understanding of what their communities most need to thrive.
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We are a coalition of nonprofit organizations, current and former executives from federal, state, and local government, and other leaders committed to building and using data and evidence to improve outcomes for the American people. While we support language in the proposed rule that would allow federal funding to continue to be invested in building and using data and evidence to deliver better outcomes for residents, we are concerned with several provisions that would mark a fundamental departure from a results-oriented federal financial assistance framework.
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To Speaker Johnson, Minority Leader Jeffries, Chairman Guthrie, and Ranking Member Pallone: We share the urgency you feel to pass legislation to protect our nation’s young people online. However, we respectfully urge you to reject the KIDS Act.
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The undersigned disability, civil rights, and education organizations strongly oppose the Administration’s efforts to transfer the Office of Special Education and Rehabilitative Services (OSERS) from the U.S. Department of Education (ED) to the Department of Health and Human Services (HHS) and the Office for Civil Rights (OCR) to the Department of Justice (DOJ) through Interagency Agreements (IAAs). These agreements undermine the core foundation of federal disability, education, and civil rights policy and implementation.
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On Tuesday, June 16, 2026, InnovateEDU’s CEO Erin Mote testified before the Senate HELP Subcommittee on Education and the American Family during a hearing titled “The Future of K-12 Education in the Age of Artificial Intelligence.” In her testimony, Mote drew a clear distinction between purpose-built educational technology (EdTech) and general consumer tools, noting that consumer platforms operate outside the robust privacy guardrails of FERPA and COPPA. She proposed a modernized procurement framework centered on evidence-based tools that demonstrate a clear “return on instruction” (ROI). Furthermore, Mote emphasized the urgent need for federal investment into researching the cognitive impacts of AI on children and advocated for a new Learning Sciences Benchmark to ensure AI tools align with proven instructional practices while reinforcing the essential role of human relationships in education.
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We, the undersigned organizations and individuals, write to you as stewards of America’s scientific enterprise. Restoring full leadership and governance at the National Science Foundation (NSF) is a key national priority, critical to U.S. economic competitiveness and national security amid escalating global competition.
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We, the 97 undersigned organizations, write to express our deep concern regarding the status of FY25 funding for the Institute of Education Sciences (IES) and to urge immediate action to ensure that these funds are fully apportioned and obligated before they lapse on September 30, 2026. Congress provided FY25 funding to IES that, based on statute, the agency has two years to spend. However, based on publicly available data, approximately $289 million of FY25 IES funding has not yet been apportioned to program accounts and does not appear to be on track for timely obligation. Approximately 36 percent ($289 million) of FY25 IES funding could lapse on September 30, 2026, if swift action is not taken.
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The 2024 Nation’s Report Card revealed that our public education system has not yet returned to pre-COVID-19 pandemic levels, emphasizing the need for investment in education R&D. Therefore, we urge the House of Representatives Subcommittee on Labor, Health and Human Services, Education, and Related Agencies to provide increased funding for the Institute of Education Sciences, restore funding for the Education Innovation and Research (EIR) programs to FY23 levels, and allocate funding towards the Department of Labor’s Data Quality Initiative (WDQI) and for restoring the Office of Educational Technology (OET). Furthermore, we call for full funding for the Individuals with Disabilities Education Act (IDEA) and investment to address the teacher workforce crisis.
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Our FY27 language and funding requests reflect a results-oriented focus. They prioritize approaches that are grounded in rigorous research, strengthened through continuous evaluation, and proven effectiveness in communities across the country. By emphasizing what works, Congress can promote innovation while maintaining strong stewardship of public funds. Our requests are designed to reinforce this commitment across the Departments of Labor; Health and Human Services; Education; Housing and Urban Development; as well as Financial Services and General Government. Together, these language and funding requests would continue to build the evidence base and improve outcomes for young people, families, and communities nationwide.
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InnovateEDU congratulates Senators Budd and Kim on the introduction of the Artificial Intelligence-Ready Data Act (S.4098) in the United States Senate. To ensure the Act’s framework is as robust for the education sector as it is for the National Oceanic and Atmospheric Administration (NOAA), we recommend applying Section 4 standards to programs at the the National Center for Education Statistics (NCES) and the Institute of Education Sciences (IES), like the Making high-value assets like the National Assessment of Educational Progress (NAEP), the Common Core of Data (CCD), and the Statewide Longitudinal Data Systems (SLDS).
Letter to Sens Kim and Budd - Artificial Intelligence Ready Data Act.pdf
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In partnership with InnovateEDU and the EDSAFE AI Alliance US Policy Working Group (USPWG) and Industry Council—representing coalitions of over 150 leading education, technology, and civil rights organizations and companies advocating for a safe, accountable, fair and transparent, and efficacious approach to the use of AI in education—respectfully write to urge the Secretary of Education, Senate HELP and Commerce Committees, and House Education and Workforce and Energy and Commerce Committees to take administrative action to immediately reinstate the U.S. Department of Education (USED)’s Office of Educational Technology (OET).
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The need for increased investment in education R&D has never been more urgent. The 2024 Nation’s Report Card revealed that student performance has declined to historic lows in key subjects and grade levels. Forty-five percent of 12th graders scored below the basic level in math, and 32 percent scored below basic in reading—the highest percentages ever recorded. Achievement gaps between the highest- and lowest-performing students have widened, and only one-third of graduating seniors demonstrated readiness for entry-level college math. These results demand a robust, evidence-based response powered by a federal education R&D infrastructure that supports states and local education efforts.
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While EALA views the NSESS as a powerful opportunity to bridge a 25-year data gap, its ultimate success depends on its ability to capture the lived realities of our schools and communities and their ability to provide a “free appropriate public education to eligible children with disabilities,” as established in the Individuals with Disabilities Education Act (IDEA).
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Plyler v. Doe is not immigration policy by court order. It is a constitutional recognition that children are not responsible for the circumstances of their birth or arrival, and that a country which denies children an education pays a price no one can afford.
The undersigned organizations urge the members of this Subcommittee to keep the focus of this hearing where it belongs: on the children sitting in classrooms across this country, on the communities their families have built, and on the forty years of evidence that educating every child is not a burden. It is the foundation of our nation.
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Dear Governor Hochul, Majority Leader Stewart-Cousins, and Speaker Heastie:
On behalf of InnovateEDU and a broad coalition of industry leaders, parents, and New York educators, we are writing to urge you to include dedicated funding for a pilot of the Artificial Intelligence Literacy Act’s (S7691) Digital Equity Competitive Grant program in the FY 2027 Executive Budget, and the Senate and Assembly one-house budget resolutions.
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InnovateEDU recommends that the NSF lead the creation of a national public AI infrastructure and "AI workforce hubs" to unify data interoperability, secure research, and STEM talent pipelines. Additionally, we advocate for modernizing workforce readiness through Learning and Employment Records (LERs) and establishing rigorous, independent benchmarks for educational AI tools to ensure they are safe, accessible, and pedagogically sound.
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We urge the NSF to recognize AI in Education (K-12 through adult learning) as foundational and essential for preparing the current and future workforce to meaningfully participate in an AI-integrated economy. By prioritizing AI in Education, the NSF can build the talent pipeline necessary to sustain American leadership in critical technologies.
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We, the undersigned, write in support of the New Essential Education Discoveries (NEED) Act. This legislation will strengthen education research and development (R&D) to improve student learning and sharpen the United States’ competitive edge in an increasingly technology-rich world.
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On behalf of InnovateEDU and the undersigned organizations, we are writing to express our support for the proposed amendment to the New York State Technology Law (S7599C) to require New York state and local government agencies to publicly disclose and assess their use of automated and artificial intelligence–based decision-making systems, maintain a statewide inventory of such tools, and ensure that their implementation does not infringe upon employee rights, collective bargaining agreements, or civil service protections.
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In responding to OTSP’s request for information, we emphasize that regulatory reform should focus on coherence, modernization, and public capacity to ensure that innovation in AI education prepares current and future students to enter an AI-infused workforce while advancing human flourishing, transparency, and national strength.
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We commend the IES and the Department of Education for initiating this effort to redesign and strengthen the nation’s premier education research infrastructure. This process arrives at a pivotal moment, one where the U.S. must harness emerging technologies, rebuild public trust in data and Gold Standard Science, and ensure that every learner, every school model, and every community benefits from evidence-based innovation.
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On behalf of the 44 organizations listed below, we are writing to urge your support for meaningful federal investment in educator preparation programs in the FY26 budget. U.S. Department of Education programs are critical for ensuring that every student has access to well-prepared, effective educators.
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On behalf of InnovateEDU, aiEDU, and the undersigned organizations, we are writing to express our support for the proposed amendment to the Elementary and Secondary Education Act of 1965 (ESEA) to encourage states to develop standards for elementary and secondary education for artificial intelligence (AI) and other emerging technologies.
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On behalf of the students and families in our communities, the undersigned local educational agencies and community-based organizations write to express strong support for the Schools and Libraries (E-Rate) Program and its continued funding under the Universal Service Fund.
Coalition Letter Bipartisan Working Group Letter on Universal Service Fund_09.15.25.pdf
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Keep Our Communities Connected’s responses emphasize the need for Congress to modernize the Fund, safeguard its fiscal sustainability, implement transparency and accountability measures, including better data collection from the FCC, and ensure that it remains future-ready to support education, healthcare, and economic mobility for all Americans.
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On behalf of the undersigned members of the National English Learner Roundtable and partner civil rights and education organizations, we write to express grave concern over the recent rescission of the U.S. Department of Education’s (ED) and U.S. Department of Justice’s (DOJ) joint 2015 Dear Colleague Letter: English Learner Students and Limited English Proficient Parents (“2015 guidance”).
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We appreciate the Department’s continued commitment to improving data transparency regarding the educational experiences of students in the nation’s nearly 100,000 public schools. The CRDC provides much-needed data and transparency for assessing educational quality, identifying concerning trends in resource allocation, and empowering families and advocates to push for policies that ensure all students, including students of color and students with disabilities, have access to high-quality education.
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We represent a coalition of organizations dedicated to the safety, privacy, and well-being of children in our increasingly digital and AI-driven world. Together, we advocate for the passage of Assembly Bill 1064 (Bauer-Kahan), which establishes critical regulations for the development and use of artificial intelligence systems that interact with children.
Support for AB 1064 - Leading Ethical AI Development (LEAD) for Kids.pdf
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Dear Senator Capito,
We are writing to thank you for your leadership in urging the Trump administration to release critical funding for the 2025-2026 school year that had been illegally withheld.
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The comments below outline both opportunities for federal investment and suggested revisions to the proposed priority to ensure education stakeholders are adequately equipped to procure, implement, and evaluate AI technologies in their local educational contexts.
We recommend that the Department expand this priority to explicitly include a focus on engaging educators, students with disabilities, and their families. This expanded focus will enable them to engage in informed discussions about protecting privacy and critically assessing the use and appropriateness of AI in education.
We offer specific recommendations to strengthen the scope, clarify terminology, and ensure implementation strategies that improve student outcomes, increase and improve educators’ AI knowledge, capacity, and effectiveness, cultivate community trust, and increase students’ preparedness to enter an AI-integrated workforce.
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InnovateEDU commends the National Science Foundation’s TIP Directorate for its focus on advancing high-potential, high-impact research and innovation. As this work continues, we urge the TIP Directorate to directly connect future funding opportunities to the K–12 education system and workforce development pipelines.
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We encourage the National Science Foundation to recognize AI in education, including K-12, higher education, and Adult Learning Opportunities, as an essential area for AI innovation and to prioritize data interoperability as the foundation for secure, accessible, and scalable technology ecosystems.