NCME Joins Friends of IES Coalition in Comments Urging Withdrawal of Proposed EDGAR Revisions
The National Council on Measurement in Education (NCME) joined 33 other organizations in the Friends of the Institute of Education Sciences (IES) coalition in submitting formal comments on Wednesday, September 23, in response to the U.S. Department of Education’s proposed revisions to the Education Department General Administrative Regulations (EDGAR) (Docket ID ED-2026-OPEPD-2542). The signatories include scientific and professional societies from across the research community, among them organizations representing mathematics, statistics, physics, psychology, political science, and population research.
The coalition noted that the FY 2027 Continuing Resolution bars implementation of the parallel OMB Uniform Guidance rule through December 11, 2026, and urged the Department to withdraw the proposed EDGAR changes. If the rulemaking proceeds, the coalition recommended that the Department:
- Preserve transparency by continuing to publish application notices, maximum award amounts, and funding priorities in the Federal Register.
- Keep grant decisions merit-based by removing a proposed preference for applicants with lower indirect cost rates, which the coalition argued would conflict with IES’s scientific peer review process.
- Continue annual obligation of multi-year grants rather than “frontloading” full award amounts, a shift that would reduce the number of research grants IES can fund each year.
- Remove “termination for convenience” language, which would disrupt long-range research planning, school and community partnerships, and graduate student support.
- Retain evidence definitions that reflect the full range of rigorous methods permitted under the Education Sciences Reform Act, including regression discontinuity designs, and keep What Works Clearinghouse standards as the common benchmark for levels of evidence.
The full comment letter is available here.
