Request for Information on the Use of APIs in Higher Education Data and Student Aid Processes, 21449-21453 [2014-08649]

Agencies

• DEPARTMENT OF EDUCATION

[Federal Register Volume 79, Number 73 (Wednesday, April 16, 2014)]
[Notices]
[Pages 21449-21453]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-08649]


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DEPARTMENT OF EDUCATION

[Docket ID ED-2014-OUS-0040]


Request for Information on the Use of APIs in Higher Education 
Data and Student Aid Processes

AGENCY: Department of Education.

ACTION: Request for information.

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SUMMARY: To assist in its efforts to explore potential uses of 
Application Program Interfaces (APIs), the U.S. Department of Education 
(Department) requests information regarding the use of APIs in the 
context of higher education data and student aid programs and processes 
at the Department. We invite ideas, information, and feedback from all 
interested parties for the purpose of making data and processes in 
higher education and student aid more open and accessible to students 
and families, in the most secure manner, as they make an investment in 
postsecondary education.

DATES: Written submissions must be received by the Department on or 
before June 2, 2014.

ADDRESSES: Submit your comments through the Federal eRulemaking Portal, 
by submitting them to the email address APIRFI@ed.gov, or via postal 
mail, commercial delivery, or hand delivery. We will not accept 
comments by fax. To ensure that we do not receive duplicate copies, 
please submit your comments only one time. In addition, please include 
the Docket ID and the term ``Application Program Interfaces response'' 
at the top of your comments.
     Federal eRulemaking Portal: Go to https://www.regulations.gov to submit your comments electronically. Information 
on using Regulations.gov, including instructions for accessing agency 
documents, submitting comments, and viewing the docket, is available on 
the site under ``Are you new to this site?''
     Email: To submit comments via email, send them to the 
address APIRFI@ed.gov.
     Postal Mail, Commercial Delivery, or Hand Delivery: If you 
mail or deliver your comments, address them to David Soo, Attention: 
API RFI, U.S. Department of Education, 400 Maryland Avenue SW., Room 
7E316, Washington, DC 20202.
     Privacy Note: The Department's policy for comments 
received from members of the public (including comments submitted by 
mail, commercial delivery, or hand delivery) is to make these 
submissions available for public viewing in their entirety on

[[Page 21450]]

the Federal eRulemaking Portal at https://www.regulations.gov. 
Therefore, commenters should be careful to include only information 
that they wish to make publicly available on the Internet.
    Submission of Proprietary Information: Given the subject matter, 
some comments may include proprietary information as it relates to 
confidential commercial information. The Freedom of Information Act 
defines ``confidential commercial information'' as information the 
disclosure of which could reasonably be expected to cause substantial 
competitive harm. You may wish to request that we not disclose what you 
regard as confidential commercial information.
    To assist us in making a determination on your request, we 
encourage you to identify any specific information in your comments 
that you consider confidential commercial information. Please list the 
information by page and paragraph numbers.
    This is a request for information (RFI) only. This RFI is not a 
request for proposals (RFP) or a promise to issue an RFP or a notice 
inviting applications (NIA). This RFI does not commit the Department to 
enter into any agreement of any kind for any supply or service 
whatsoever. The examination of information submitted in response to 
this RFI will in no way, expressed or implied, obligate the Department 
to purchase, rent, or otherwise acquire the information demonstrated, 
displayed, or furnished. Further, the Department is not seeking 
proposals and will not accept unsolicited proposals. The Department 
will not endorse any information you submit in response to this RFI and 
will not give any special consideration to such information on any 
future procurement. The Department will not pay for any information or 
administrative costs that you may incur in responding to this RFI. You 
may not file any claim against the Department or otherwise seek 
compensation for any information submitted in response to this RFI. If 
you do not respond to this RFI, you may still apply for future 
contracts and grants. The Department posts RFPs on the Federal Business 
Opportunities Web site (https://www.fbo.gov). The Department announces 
grant competitions in the Federal Register (https://www.gpo.gov/fdsys). 
It is your responsibility to monitor these sites to determine whether 
the Department issues an RFP or NIA after considering the information 
received in response to this RFI. The documents and information 
submitted in response to this RFI become the property of the U.S. 
Government and will not be returned.

FOR FURTHER INFORMATION CONTACT: David Soo, U.S. Department of 
Education, 400 Maryland Avenue SW., Room 7E316, Washington, DC 20202. 
Telephone: (202) 401-0429.
    If you use a telecommunications device for the deaf (TDD) or a text 
telephone (TTY), call the Federal Relay Service (FRS), toll free, at 1-
800-877-8339.

SUPPLEMENTARY INFORMATION: 

Background

    A postsecondary education is among the most important investments 
students can make in their futures. However, obtaining postsecondary 
education has grown increasingly expensive, and the processes by which 
students get information about, apply for, and finance higher education 
can be challenging and complex, particularly for low-income and first-
generation college-goers. While a college education remains a valuable 
investment overall--average weekly earnings for those with a 
postsecondary degree or certificate exceed those of individuals with 
only a high school diploma, according to the Bureau of Labor 
Statistics--the average borrower with a bachelor's degree now graduates 
with more than $29,400 in debt, according to 2012 data from the 
National Postsecondary Student Aid Study. Moreover, college completion 
rates remain relatively low: Data from the National Center for 
Education Statistics indicate that only 58 percent of full-time 
students who began college in 2004 earned a four-year degree within six 
years. Students and families need reliable, timely information in an 
open and accessible format to identify, afford, and complete a degree 
or program that is affordable and will help them reach their 
educational and career goals.
    The Administration has made access, affordability, quality, and 
completion in higher education centerpieces of its education agenda. 
With more jobs than ever requiring education beyond a high school 
diploma, higher education is the clearest pathway into the middle 
class. President Obama challenged all Americans early in his 
Administration to commit to at least one year of postsecondary 
education or training--whether at a four-year college, two-year 
college, or technical or trade school--and set a goal for the nation 
that America would once again lead the world in college completion by 
the year 2020. In support of these objectives, the Department provides 
over $150 billion each year in student financial aid, consisting of 
grants, loans, and work-study opportunities to students attending 
postsecondary institutions nationwide. While these resources help 
students afford and complete postsecondary education, their utility 
only goes as far as the public's awareness of and access to them. The 
Department recognizes that other stakeholders--including cities and 
States, non-profit and community-based organizations, and developers 
and entrepreneurs--all have a role to play in increasing access to and 
awareness of the resources and information available from Federal 
sources to help students and families access, afford, and complete 
college.
    In August 2013, President Obama announced an ambitious agenda that 
aims to increase college value and affordability for American families. 
His plan includes measuring college performance through a new ratings 
system so students and families have the information to select schools 
that provide the best value; removing barriers that stand in the way of 
competition and innovation, particularly in the use of new technology, 
and shining a light on the most cutting-edge college practices for 
providing high value at low costs; and helping student borrowers 
struggling with their existing debt by ensuring that all borrowers who 
need it have access to the Pay As You Earn plan, capping loan payments 
at 10 percent of income. To promote innovation and competition in the 
higher education marketplace, the President's plan calls for publishing 
better information on how colleges are performing, helping demonstrate 
that new approaches can improve learning and reduce costs, and offering 
colleges regulatory flexibility to innovate. In issuing this agenda, 
the President is challenging colleges and other higher education 
leaders to develop and adopt more innovative and promising practices 
that have the potential to dramatically improve affordability and 
quality.
    As part of that agenda, the Administration held an ``Education 
Datapalooza'' in January 2014 to encourage entrepreneurs, technology 
leaders, college researchers and practitioners, students, and others to 
develop new tools, services, and applications (apps) to help students 
evaluate and select colleges, navigate how they could finance a higher 
education, and improve teaching and learning. During the Datapalooza, 
the Administration announced that it would explore the use of 
Application Program Interfaces (APIs) as a way to help students, 
families, and other stakeholders access key education

[[Page 21451]]

processes, programs, and data as they make decisions about and 
investments in higher education. The Department will use the feedback 
it receives from this Request For Information (RFI) to explore ways in 
which it could integrate APIs into existing resources in collaboration 
with external parties and providers.

Introduction

    Through this RFI, the Department invites institutions and systems 
of higher education; students and parents; software developers, 
designers, and entrepreneurs; college counselors and guidance 
counselors; consumer advocates; the financial aid community; research 
and data experts; think tanks; privacy advocates; government agencies 
and officials who provide citizen-facing services; stakeholders and 
experts in higher education and/or technology; and any other interested 
party to provide ideas and feedback on the potential development of 
APIs using higher education data, programs, and frequently used forms 
(particularly in student aid) at the Department. Consistent with the 
Administration's approach of shared responsibility to promote better 
access, affordability, quality, and completion in higher education 
across the country, the Department seeks ideas and feedback from all 
sectors on how to best use freely available government data and 
processes to build products, services, and apps that advance 
postsecondary education, provide critical information to students, and 
help colleges innovate in creative and powerful ways. Individuals or 
organizations with expertise in developing and implementing APIs and/or 
facilitating college access and aid are strongly encouraged to respond.
    An API is a set of software instructions and standards that allows 
machine-to-machine communication. Web APIs support sharing content and 
data between communities and applications and can take many forms, 
including enabling third parties to query a data set at a granular 
level or submit new data on behalf of a user. APIs allow developers 
from inside and outside government to build apps, widgets, Web sites, 
and other tools based on government information and services to let 
consumers access government-owned data and participate in government-
run processes from more places on the Web, even beyond Federal domains. 
Well-designed APIs support interoperability and openness to make data 
and processes freely available for use within agencies, between 
agencies, in the private sector, or by citizens. However, government 
has to ensure the security and privacy of the data it maintains, 
especially when the information of students and families is involved. 
Openness can lead to risks to privacy and security that must be fully 
considered and addressed.
    APIs can be read-only, which allows a consumer to read material on 
a third-party app or Web site, or read-write, which allows a consumer 
to interact with and submit information, such as completing an online 
form. Read-only APIs have already been successfully integrated into 
some Department resources, including data from the Integrated 
Postsecondary Education Data System (IPEDS), available at www.ed.gov/developer. An example of a read-write API is the functionality that 
allows individuals to complete tax returns on third-party Web sites and 
then submit that information to the Internal Revenue Service (IRS).
    This RFI seeks to explore potential ways in which the Department 
can expand on its successful efforts to increase and enhance access to 
information on higher education already published on the Department's 
Web site, including through IPEDS, EDFacts, and other National Center 
for Education Statistics surveys related to higher education; data held 
by the Department's Office of Federal Student Aid (FSA); and data 
available elsewhere in the Department that focuses on higher education. 
The Department also seeks feedback on options for read-only and read-
write APIs that could increase access to and use of benefits, forms, 
and processes offered for programs authorized under title IV of the 
Higher Education Act of 1965, as amended (HEA), including in the 
submission of the Free Application for Federal Student Aid (FAFSA); 
enrollment in Income-Driven Repayment (IDR) programs; enrollment in the 
Public Service Loan Forgiveness program; participation in processes 
offered by title IV aid servicers in repaying Federal student loans; 
and use of loan counseling and financial literacy and awareness tools.
    APIs could enable the development of new tools to provide consumers 
with better and more complete information about college affordability 
and performance, as well as other resources to enable informed decision 
making, including by expanding enrollment in student aid programs and 
increasing accuracy and completion in accessing these programs. 
Accordingly, the Department is soliciting feedback and ideas on 
potentially using APIs (either read-only or read-write) in the broadest 
context of higher education data and processes, including those 
discussed previously and others not explicitly listed in this notice. 
Suggestions about additional data that the Department could collect, or 
about other innovative or technology-based solutions that could better 
expand access to information and student aid programs in higher 
education, would fall outside the scope of this RFI. Nonetheless, the 
Department is open to all ideas.
    Through this RFI, the Department is also particularly interested in 
specific ways in which APIs can be used effectively while continuing to 
safeguard student privacy and data and maintain the integrity of the 
taxpayer investment in Title IV student aid through prevention of 
fraud, misrepresentation, and abuse. Before releasing many types of 
records about individuals, the Department generally must obtain the 
individual's prior written consent under the Privacy Act of 1974, as 
amended (Privacy Act), which requires the individual to specify to whom 
the record(s) may be disclosed, which record(s) may be disclosed, and, 
where applicable, during which time frame the record(s) may be 
disclosed. In addition, to implement the principles of the Open 
Government Directive, the Office of Management and Budget (OMB) 
Memorandum 10-23 requires the Department to take a number of steps to 
engage with the public directly and through third-party applications. 
To both protect privacy and encourage the open exchange of information, 
we are interested in suggestions on how APIs can be developed and 
implemented to ensure both that students maintain free access to 
Federal Student Aid programs, and that there is strict adherence to 
Federal security guidelines and privacy laws, regulations, and guidance 
documents.
    Information gathered through this RFI will inform possible 
development of APIs for higher education data and student aid processes 
at the Department. Following the deadline for comments on this RFI, the 
Department will take all ideas received into consideration as it 
explores the possibility of greater use of APIs in higher education. At 
this time, the Department is not formally committing to any expansion 
of the use of APIs in higher education data or student aid processes, 
nor is the Department obligating or intending to obligate any 
appropriated funds for the development of any API. Further, by issuing 
this RFI, the Department is not committing to any current or future 
acquisition of any API or any other related information submitted in 
response to this RFI. Responses to this RFI will not be considered by 
the Department as offers and therefore

[[Page 21452]]

cannot be accepted by the Department to form a binding contract. 
Although this RFI is a significant opportunity to contribute to the 
development of the Department's college value and affordability agenda, 
the Department will continue to seek input in other forums on 
innovation in higher education--focused on APIs and other approaches--
in the spirit of advancing access and promoting success in higher 
education.

Context for Responses

    The primary goal of this RFI is to gather information that will 
help the Department explore the possible use of APIs in expanding 
access to higher education data and student aid programs and processes 
consistent with applicable security and privacy requirements. The 
Department has developed several questions to guide input, but 
reiterates that these questions are only guides. This is not a 
solicitation for API proposals. Submissions do not have to respond to 
the specific questions, nor are submissions expected to respond to all 
questions. Comments may be provided in any format. Information may also 
be provided that is not responsive to a particular question but may 
still be helpful. However, the Department encourages commenters to be 
as specific as possible in their responses so as to best inform our 
ongoing work in this area.

Questions

A. Information Gaps and Needs in Accessing Current Data and Aid 
Programs

    1. How could data sets that are already publicly available be made 
more accessible using APIs? Are there specific data sets that are 
already available that would be most likely to inform consumer choice 
about college affordability and performance?
    2. How could APIs help people with successfully and accurately 
completing forms associated with any of the following processes: FAFSA; 
Master Promissory Note; Loan Consolidation; entrance and exit 
counseling; Income-Driven Repayment (IDR) programs, such as Pay As You 
Earn; and the Public Student Loan Forgiveness program?
    3. What gaps are there with loan counseling and financial literacy 
and awareness that could be addressed through the use of APIs to 
provide access to government resources and content?
    4. What services that are currently provided by title IV student 
loan servicers could be enhanced through APIs (e.g., deferment, 
forbearance, forgiveness, cancellation, discharge, payments)?
    5. What current forms or programs that already reach prospective 
students or borrowers in distress could be expanded to include broader 
affordability or financial literacy information?

B. Potential Needs To Be Filled by APIs

    1. If APIs were available, what types of individuals, 
organizations, and companies would build tools to help increase access 
to programs to make college more affordable?
    2. What applications and features might developers, schools, 
organizations, and companies take interest in building using APIs in 
higher education data and services?
    3. What specific ways could APIs be used in financial aid processes 
(e.g., translation of financial aid forms into other languages, 
integration of data collection into school or State forms)?
    4. How can third-party organizations use APIs to better target 
services and information to low-income students, first-generation 
students, non-English speakers, and students with disabilities?
    5. Would APIs for higher education data, processes, programs or 
services be useful in enhancing wraparound support service models? What 
other types of services could be integrated with higher education APIs?

C. Existing Federal and Non-Federal Tools Utilizing APIs

    1. What private-sector or non-Federal entities currently offer 
assistance with higher education data and student aid programs and 
processes by using APIs? How could these be enhanced by the 
Department's enabling of additional APIs?
    2. What private-sector or non-Federal entities currently work with 
government programs and services to help people fill out government 
forms? Has that outreach served the public and advanced public 
interests?
    3. What instances or examples are there of companies charging fees 
to assist consumers in completing otherwise freely available government 
forms from other agencies? What are the advantages and risks to 
consider when deciding to allow third parties to charge fees to provide 
assistance with otherwise freely available forms and processes? How can 
any risks be mitigated?
    4. Beyond the IRS e-filing example, what other similar examples 
exist where Federal, State, or local government entities have used APIs 
to share government data or facilitate participation in government 
services or processes--particularly at a scale as large as that of the 
Federal Student Aid programs?

D. Technical Specifications

    1. What elements would a read-write API need to include for 
successful use at the Department?
    2. What data, methods, and other features must an API contain in 
order to develop apps accessing Department data or enhancing Department 
processes, programs, or services?
    3. How would read-only and/or read-write APIs interact with or 
modify the performance of the Department's existing systems (e.g., 
FAFSA on the Web)? Could these APIs negatively or positively affect the 
current operating capability of such systems? Would these APIs allow 
for the flexibility to evolve seamlessly with the Department's 
technological developments?
    4. What vulnerabilities might read-write APIs introduce for the 
security of the underlying databases the Department currently uses?
    5. What are the potential adverse effects on successful operation 
of the Department's underlying databases that read-write APIs might 
cause? How could APIs be developed to avoid these adverse effects?
    6. How should APIs address application-to-API security?
    7. How should the APIs address API-to-backend security issues? 
Examples include but are not limited to authentication, authorization, 
policy enforcement, traffic management, logging and auditing, TLS 
(Transport Layer Security), DDoS (distributed denial-of-service) 
prevention, rate limiting, quotas, payload protection, Virtual Private 
Networks, firewalls, and analytics.
    8. How do private or non-governmental organizations optimize the 
presentation layer for completion and accuracy of forms?
    9. What security parameters are essential in ensuring there is no 
misuse, data mining, fraud, or misrepresentation propagated through use 
of read-only or read-write APIs?
    10. With advantages already built into the Department's own 
products and services (e.g., IRS data retrieval using FAFSA on the 
Web), how would new, third-party API-driven products present advantages 
over existing Department resources?
    11. What would an app, service or tool built with read-write API 
access to student aid forms look like?

E. Privacy Issues

    1. How could the Department use APIs that involve the use of 
student

[[Page 21453]]

records while ensuring compliance with potentially applicable statutory 
and regulatory requirements, such as the Family Educational Rights and 
Privacy Act (20 U.S.C. 1232g; 34 CFR Part 99) and the Privacy Act (5 
U.S.C. 552a and 34 CFR Part 5b)?
    2. How could APIs ensure that the appropriate individual has 
provided proper consent to permit the release of privacy-protected data 
to a third party? How can student data be properly safeguarded to 
prevent its release and use by third parties without the written 
consent often required?
    3. How might read-only or read-write APIs collect, document, and 
track individuals' consent to have their information shared with 
specific third parties?
    4. How can personally identifiable information (PII) and other 
financial information (of students and parents) be safeguarded through 
the use of APIs?
    5. What specific terms of service should be enabled using API keys, 
which would limit use of APIs to approved users, to ensure that 
information is not transmitted to or accessed by unauthorized parties?
    6. What are the relative privacy-related advantages and 
disadvantages of using read-only versus read-write APIs for student aid 
data?

F. Compliance Issues

    1. What are the relative compliance-related advantages and 
disadvantages of using read-only versus read-write APIs for student aid 
data?
    2. How can the Department prevent unauthorized use and the 
development of unauthorized products from occurring through the 
potential development of APIs? How might the Department enforce terms 
of service for API key holders, and prevent abuse and fraud by non-API 
key holders, if APIs were to be developed and made available?
    3. What kind of burden on the Department is associated with 
enforcing terms and conditions related to APIs?
    4. How can the Department best ensure that API key holders follow 
all statutory and regulatory provisions of accessing federal student 
aid funds and data through use of third-party products?
    5. How could prior consent from the student whom the data is about 
be provided for release of privacy-protected data to third party 
entities?
    6. How should a legal relationship between the Department and an 
API developer or any other interested party be structured?
    7. How would a legal relationship between the Department and an API 
developer or any other interested party affect the Department's current 
agreements with third-party vendors that operate and maintain the 
Department's existing systems?
    8. What disclosures should be made available to students about what 
services are freely available in government domains versus those that 
could be offered at a cost by a third party?
    9. If the Department were to use a third-party application to 
engage with the public on its behalf, how could the Department ensure 
that the Department follows the protocols of OMB Memorandum 10-23?

G. Policy Issues

    1. What benefits to consumers or the Department would be realized 
by opening what is currently a free and single-point service (e.g., the 
FAFSA) to other entities, including those who may charge fees for 
freely-available services and processes? What are the potential 
unintended consequences?
    2. How could the Department ensure that access to title IV, HEA 
student aid programs truly remains free, even amidst the potential 
development of third-party apps that may charge a fee for assistance in 
participating in free government programs, products, and services with 
or without providing legitimate value-added services?
    3. What other policy concerns should the Department consider with 
regard to the potential development of APIs for higher education data 
and student aid processes at the Department?
    4. How would APIs best interact with other systems already in use 
in student aid processes (e.g., within States)?
    5. How would Department APIs benefit or burden institutions 
participating in title IV, HEA programs?
    6. While the Department continues to enhance and refine its own 
processes and products (e.g., through improvements to FAFSA or the IDR 
application process), how would third-party efforts using APIs 
complement or present challenges to these processes?
    Accessible Format: Individuals with disabilities can obtain this 
document in an accessible format (e.g., braille, large print, 
audiotape, or compact disc) on request to the program contact person 
listed under the For Further Information Contact section of this 
notice.
    Electronic Access to This Document: The official version of this 
document is the document published in the Federal Register. Free 
Internet access to the official edition of the Federal Register and the 
Code of Federal Regulations is available via the Federal Digital System 
at: www.gpo.gov/fdsys. At this site you can view this document, as well 
as all other documents of this Department published in the Federal 
Register, in text or Adobe Portable Document Format (PDF). To use PDF 
you must have Adobe Acrobat Reader, which is available free at the 
site. You may also access documents of the Department published in the 
Federal Register by using the article search feature at: 
www.federalregister.gov. Specifically, through the advanced search 
feature at this site, you can limit your search to documents published 
by the Department.

    Authority:  20 U.S.C. 3402(4).

    Dated: April 11, 2014.
Jamienne S. Studley,
Acting Under Secretary.
[FR Doc. 2014-08649 Filed 4-15-14; 8:45 am]
BILLING CODE 4000-01-P