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Saturday, July 24, 2010

Regulation Writing is a Difficult Job

By Georgia Perry-Ray - Regulatory Analyst & Communications Specialist

Regulation writing is a difficult job. Not only does the writer need to think of what he or she is trying to convey but to whom. The audience in many cases will have diverse education levels with limited internal knowledge of the writer’s organization or its processes and procedures. Often is the case when the reader does not have the same expertise or background as the writer. Then add another layer with the burden of ensuring all of the legal aspects of the regulation are covered so as to not leave any “loop holes” and the problem is compounded.

Government regulation writers particularly struggle with this issue as the regulation often bounces back and forth for review with the legal department and the departments that are trying to disseminate the information. By the end of the process sometimes the regulation does not even resemble the original draft at all and may not even end up with the same meaning as was originally intended by law. This is true when writing regulations for internal or external use but can be particularly frustrating for the audience that is outside of that particular governmental system. For example, all of us who have ever filed a tax return and had to read through the Internal Revenue Service’s “simplified tax return filing instructions” has experienced first hand the result of regulation writing that has fallen short of our STEM motto “Write it so they can read it”. Just trying to find out if you qualify to have the Taxpayer Advocate Service (TAS) help you with the IRS red tape can be a chore as the Advocate’s office also has” rules” that must be met before you can use their service. They are –

“If you have tried to resolve a tax problem with the IRS and are still experiencing delays or are facing economic harm, you may request the assistance of TAS.

In situations where IRS actions prevent you from providing for necessities such as housing, transportation or food; or if you own a business and are unable to meet basic expenses such as payroll, you may request the assistance of TAS.

If you face a delay of more than 30 days to resolve a tax related problem, or are not receiving a response by the date promised, you may also request assistance from TAS.”[1]

Our learning level analysis of this “simple criteria” at STEM is as follows:

1. The concept "economic harm" is basic college level economics, which many people have not learned. Moreover, the concept of "economic" is not normally applied to personal situations, such as the IRS encounters. The concept of economic harm needs to be spelled out in plain language. Several examples from ordinary life will be required to communicate this concept to ordinary people.

2. The concept "Systemic" is taken from advanced college level biology. Moreover, the concept "Systemic problem" is here a technical word of art, referring to the system of IRS regulations and procedures. This concept will be difficult to convey to ordinary people, who do not know how the IRS operates. It will even be difficult for IRS personnel.

3. The concept "normal channels" requires technical knowledge of what normal IRS channels are. Ordinary people will not know this and in some cases the folks “helping the individual determine if they qualify may not know what “normal channels” are if they do not work in that particular department.

And you thought just getting IRS to fix your problem was the difficult part.

We are by no means singling out the Taxpayer Advocate’s office for criticism as they do perform a valuable and independent service when dealing with IRS and the tax law challenges individuals face every day, nor for that matter just IRS. This is just one example of the problems a regulatory writer faces when trying to convey information to a diverse audience. Knowing your audience plays a vital role inside and outside of your organization and can greatly impact how that regulation is put into practice.

[1] Excerpt from Toolkit-2010 TAS

Thursday, July 8, 2010

STEM Education is a Regulatory Regime

By David Wojick Ph.D.
Co-Director of the STEM Education Center

Every state now has detailed standards that govern STEM education. We have listed them here . The names of these standards vary widely, which is in itself confusing, so I will refer to them all as “Standards of Learning” or simply SOLs.

With the rise of SOLs over the last few decades, STEM education has become in effect a regulatory regime. What concepts are taught in which grades is now mandated by rule, sometimes even by law. Compliance is determined by testing. Viewed as regulations, the SOLs we have seen are woefully inadequate. They are not being written as regulations should be, even though they are de facto regulations. Instead they are typically written as lofty and vague goal statements, which makes for a great deal of confusion at the compliance level, which is in the classroom.

Consider for example this typical SOL requirement: "The student will investigate and understand that magnets have an effect on some materials, make some things move without touching them, and have useful applications."

Note that there are two basic requirements, one for investigation and the other for understanding. These seem to have equal weight, but in reality it is probably only understanding that can be tested for. The investigation requirement is hopelessly vague.

Three concepts are required to be understood, but the third, "useful applications," is also completely vague. How will it be tested for? Moreover, this is a Kindergarten SOL and it is questionable whether children so young can even understand the abstract concept of "useful applications," which is quite sophisticated. If not then the requirement is impossible as stated.

In short, viewed as a regulation this simple looking SOL requirement is simply dreadful. And so it is with most STEM SOLs that we have examined. We are not experts on STEM education per se, and education is not the issue here. Rather we are experts on regulatory and scientific communication who have spent three years analyzing STEM SOLs from a regulatory point of view. In a regulation every word counts, so every word must be clear. Regulations are not goals, they are commands.

Effective regulation requires effective communication to the compliance community, in this case to the teachers, and then to the students. Our motto: "Write it so they can read it" begins with the standards themselves. The goal of regulation is not simply words on paper reflecting lofty goals, it is real world behavior based on realistic goals. We do not see this in today's SOLs.

The solution is to approach standards as regulations, as instruments of communication, not as vague goal statements. Everyone in the system needs to know what the rules are, including the students and their parents. Clarity, communication and realism must be the first priority.

For more on confusion in standards: http://www.stemed.info/standards_and_policy.html

For background information on my regulatory communication work, see:
“Engineer tackles Regulatory Confusion. Logician shears woolly regulations.”

Wednesday, July 7, 2010

Science Standards across the States

By: Criss Livingston MA
STEM Education Consultant

In the United States, K-12 science teachers must adhere to rigid state standards that their students are tested and evaluated on as required by the No Child Left Behind Act of 2001. These standards are designed to teach the core science concepts at specific grade levels. While individual states design the standards, classroom teachers are responsible for implementing them. Many teachers have limited time frames (in the day and for the year) to teach the abundance of science concepts. Due to the limited amount of time, most teachers are rushed to complete the material and find they are unable to go in depth with a concept or explore it further. Also, many aspects of a concept can be often overlooked or left out completely. Experiments and lab time which are important to science because they teach the scientific methods and critical thinking skills are left out. Teaching without going in depth can produce students who are test savvy, but do not have complex problem solving skills.

Science standards are needed to keep pace in the global markets. Some time ago, the United States became concerned about lagging behind their international peers in the science field. In 1995, the National Science Education Standards (NSES) were produced and published in 1996; however these were not accepted by the state legislatures and boards as their state standards. As established by the National Research Council, the NSES are guidelines for the science education in primary and secondary schools in the United States. Currently, there are no National Standards.

The STEM Ed team has discovered that by not having National Science Standards, the United States lacks consistency of science standards from state to state. Currently, each state’s Department of Education develops, writes, and publishes standards of science education which they believe should be taught.

For example, in Virginia, a fourth grader may be studying photosynthesis while a student in Alaska will not learn about photosynthesis until the sixth grade. See: Photosynthesis Table. This is just one of the many problems the STEM Education Center discovered when we created our grade level stratification or GLS terms based on state standards

Another example: The concept of “battery” is not listed in the Alaska or Arizona standards, but becomes an implied term when teaching electricity. While students in California begin learning about the concept of battery in the third grade and continue building upon it in the fourth grade and again in the High School. See: Battery Table.

The STEM Ed team has spent the last few years looking at state standards and analyzing their science concepts to find similarities and differences. Because different states teach the same concept at different grades, it is difficult to compare state test results among the fifty states.
For more information on the Science behind the GLS, please see the STEM Ed’s website: www.stemed.info