On May 21, U.S. Department of Education (USED) Secretary Linda McMahon proposed her first set of supplemental grant priorities. This Deep Dive provides information about the following:

• Overview of USED Supplemental Priorities and their Importance
• Summary of Secretary McMahon’s Proposed Supplemental Priorities
  • Promoting Evidence-Based Literacy
  • Expanding Education Choice
  • Returning Education to the States
• Process for Submitting Public Comments

Overview of USED Supplemental Priorities and their Importance

Every Secretary of Education has the ability to identify a set of priorities for any competitive grant to supplement any priorities already established by Congress for that grant. Thus, these supplemental Secretarial priorities do not impact formula programs such as Title I. Secretary McMahon’s supplemental priorities, once finalized, will replace former USED Secretary Miguel Cardona’s, which themselves replaced the priorities he inherited. Secretaries sometimes update their own supplemental priorities to help drive funding toward emerging priorities. Indeed, in its press release, USED noted that Secretary McMahon anticipates publishing additional priorities later this year.

Competitive grant priorities can play a significant role in determining who gets funded to do what. Once the menu of supplemental priorities is established, the Secretary can choose to insert any of those in any grant competition, and also decide how the priorities will be used in the competition. At the Secretary’s discretion, the priorities can be deployed in three ways:

• In some grants, the Secretary may establish that a particular priority is an absolute priority that applicants must address in their application to qualify for funding. This means that an entire grant program’s funds will go to proposals aligned with the chosen absolute priority.
• For other competitions, the Secretary may set one of the priorities as a competitive priority that awards additional points to applicants should they choose to address the priority in their application. This can be a significant lever to advance an administration’s agenda as applicants are likely to propose to use funding in line with a competitive priority given that extra points make them more likely to win the funding.
• A third use of the priorities is as an invitational priority, which encourages aligned proposals but does not award them additional points in the grant competition.

Note that, per the notice, the “Secretary may choose to use an entire priority for a grant program or a particular competition or use one or more of the priority's component parts.”

Summary of Secretary McMahon’s Proposed Supplemental Priorities

Secretary McMahon can use the supplemental priorities in currently-authorized as well as future discretionary grant programs. The Secretary named three priorities: (1) Evidence-Based Literacy, (2) Education Choice, and (3) Returning Education to the States. These would replace any other agency-wide supplemental priorities published prior to January 20, 2025.

(1) Promoting Evidence-Based Literacy

The first priority, “Promoting Evidence-Based Literacy,” is focused on using federal education funds to support proficiency in reading through “Science of Reading”-aligned instruction. The priority states that programs “should be supported by strong or moderate evidence that relates to explicit, systematic, and intentional instruction in phonological awareness, phonic decoding, vocabulary, language structure, reading fluency, and reading comprehension.”

Note that this priority incorporates ESSA’s evidence tiers, but it would limit qualifying evidence only to Tier 1, which requires experimental studies (e.g., randomized control trials), and Tier 2, which requires quasi-experimental studies. The other two tiers of evidence—covering correlational studies and research-based-but-untested innovations—are excluded from the proposed priority.

(2) Expanding Education Choice

The second priority, “Expanding Education Choice,” provides a mechanism to direct competitive grant funding to choice mechanisms ranging from vouchers and homeschooling to tutoring and open enrollment. The proposed priority provides a “menu” of options for grantees to expand school choice, including the following (click here to view the full language in the proposed priority):

(a) Public charter schools and other innovative school models, such as public laboratory schools, public microschools, course-based choice, or regional academies;

(b) Open enrollment or course-based choice;

(c) Dissemination of information for all education choice options for students, including private school enrollment, education savings accounts, tax credit scholarships, home-based learning and homeschooling, learning pods and co-ops, public charter schools, and district public schools through open enrollment or course based choice;

(d) Development or implementation of education savings accounts;

(e) Education savings accounts;

(f) Home-based education programs;

(g) Dual or concurrent enrollment programs or early college high schools or other programs where secondary school students begin earning credit toward a postsecondary degree or industry-recognized credential prior to high school graduation;

(h) Education services that accelerate learning such as high-impact tutoring;

(i) Military schools or academies;

(j) Other high school or postsecondary level programs like distance education, competency-based or skills-based education, pre-apprenticeships, apprenticeships, work-based learning, or shortened time-to-degree models;

(k) Part-time coursework and career preparation; or

(l) Programs or coursework that lead to in-demand, industry-recognized credentials.

Although some of the options include programming that can take place within the traditional public school system, such as apprenticeships or early college high schools, the Secretary can decide to use just some of the component parts of a priority, meaning that these public-school-friendly options may not appear in the actual grant competitions.

(3) Returning Education to the States

The third priority, “Returning Education to the States,” declares that “education decisions should be made at the State level, and that those states must be empowered to create opportunity through policies that are more responsive, effective, and aligned with the needs of their communities.” Whenever the Secretary chooses to incorporate this priority in a competition, programs funds will prioritize proposals that will be carried out by one or more of the following (click here to view the full language in the proposed priority):

(a) State educational agencies;

(b) Governors;

(c) State workforce development agencies or boards;

(d) State vocational rehabilitation agencies;

(e) State higher education agencies;

(f) Entities identified, designated, or endorsed by a Governor or chief State education official for purposes of implementing the project or proposal;

(g) An Indian Tribe, Tribal organization, or Tribal educational agency;

(h) Consortia of the entities identified under this priority.

In practice this priority could mean that other eligible entities for a competitive grant program such as non-profit organizations, universities, or even school districts would be at a significant disadvantage. However, option “f” appears to open the door for an entity outside the state government that might not otherwise be eligible to receive a grant (or priority points) so long as a state official endorses them.

Process for Submitting Public Comments

At the moment, these are only proposed priorities, and the public can offer comments on what Secretary McMahon has proposed. The Secretary is not obligated to heed such comments, and significant changes are unlikely, but it is important to understand what the Administration is prioritizing for current and future grantmaking. Comments can be submitted on regulations.gov until June 20, 2025, after which comments will be reviewed and a Notice of Final Priorities will be published.