{"API Evangelist"}

My Response To How Can the Department of Education Increase Innovation, Transparency and Access to Data?

I spent considerable time going through the Department of Education RFI, answering each question in as much detail as I possibly could. You can find my full response below. In the end I felt I could provide more value by summarizing my response, eliminating much of the redundancy across different sections of the RFI, and just cut through the bureaucracy as I (and APIs) prefer to do.

Open Data By Default
All publicly available data at the Department of Education needs to be open by default. This is not just a mandate, this is a way of life. There is no data that is available on any Department of Education websites that should not be available for data download. Open data downloads are not separate from existing website efforts at Department of Education, they are the other side of the coin, making the same content and data available in machine readable formats, rather than available via HTML—allowing valuable resources to be used in systems and applications outside of the department’s control.

Open API When There Are Resources
The answer to whether or not the Department of Education should provide APIs is the same as whether or not the agency should deploy websites—YES! Not all individuals and companies will have the resources to download, process, and put downloadable resources to use. In these situations APIs can provide much easier access to open data resources, and when open data resources are exposed as APIs it opens up access to a much wider audience, even non-developers. Lightweight, simple, API access to open data inventory should be default along with data downloads when resources are available. This approach to APIs by default, will act as the training ground for not just 3rd party developers, but also internally, allowing Department of Education staff to learn how to manage APIs in a safe, read-only environment.

Using A Modern API Design, Deployment, and Management Approach
As the usage of the Internet matured in 2000, many leading technology providers like SalesForce and Amazon began using web APIs to make digital assets available to 3rd party partners, and 14 years later there are some very proven approaches to designing, deploying and management APIs. API management is not a new and bleeding edge approach to making assets available in the private sector, there are numerous API tools and services available, and this has begun to extend to the government sector with tools like API Umbrella from NREL, being employed by api.data.gov and other agencies, as well as other tools and services being delivered by 18F from GSA. There are many proven blueprints for the Department of Education to follow when embarking on a complete API strategy across the agency, allowing innovation to occur around specific open data, and other program initiatives, in a safe, proven way.

Use API Service Composition For Maximum Access & Control
One benefit of 14 years of evolution around API design, deployment, and management is the establishment of sophisticated service composition of API resources. Service composition refers to the granular, modular design and deployment of APIs, while being able to manage who has access to these resources. Modern API access is not just direct, public access to a database. API service composition allows for designing exactly the access to resources that is necessary, one that is in alignment with business objectives, while protecting the privacy and security of everyone involved. Additionally service composition allows for real-time awareness of how all data, content, and other resources at the Department of Education are accessed and put to use, allowing new APIs to be designed to support specific needs, and existing APIs to evolved based upon actual demand, not just speculation.

Deeper Understanding Of How Resources Are Used
A modern API service composition layer opens up possibility for a new analytics layer that is not just about measuring and reporting of access to APIs, it is about understanding precisely how resources are accessed in real-time, allowing API design, deployment and management processes to be adjusted in a more rapid and iterative way, that contributes to the roadmap, while providing the maximum enforcement of security and privacy of everyone involved. When the Department of Education internalizes a healthy, agency-wide API approach, a new real-time understanding will replace this very RFI centered process that we are participating in, allowing for a new agility, with more control and flexibility than current approaches. A RFI cycle takes months, and will contain a great deal of speculation about what would be, where API access, coupled with healthy analytics and feedback loops, answers all the questions being addressed in this RFI, in real-time, reducing resource costs, and wasted cycles.

APIs Open Up Synchronous and Asynchronous Communication Channels
Open data downloads represents a broadcast approach to making Department of Education content, data and other resources available, representing a one way street. APIs provide a two-way communication, bringing external partners and vendors closer to Department of Education, while opening up feedback loops with the Department of Education, reducing the distance between the agency and its private sector partners—potentially bringing valuable services closer to students, parents and the companies or institutions that serve them. Feedback loops are much wider currently at the Department of Education occur on annual, monthly and at the speed of email or phone calls , with the closest being in person at events, something that can be a very expensive endeavor. Web APIs provide a real-time, synchronous and asynchronous communication layer that will improve the quality of service between Department of Education and the public, for a much lower cost than traditional approaches.

Building External Ecosystem of Partners
The availability of high value API resources, coupled with a modern approach to API design, deployment and management, an ecosystem of trusted partners can be established, allowing the Department of Education to share the workload with an external partner ecosystem. API service composition allows the agency to open up access to resources to only the partners who have proven they will respect the privacy and security of resources, and be dedicated to augmenting and helping extend the mission of the Department of Education. As referenced in the RFI, think about the ecosystem established by the IRS modernized e-file system, and how the H&R Blocks, and Jackson Hewitt’s of the world help the IRS share the burden of the country's tax system. Where is the trusted ecosystem for the Department of Education? The IRS ecosystem has been in development for over 25 years, something the Department of Education has to get to work on theirs now.

Security Fits In With Existing Website Security Practices
One of the greatest benefits of web APIs is that they utilize existing web technologies that are employed to deploy and manage websites. You don’t need additional security approaches to manage APIs beyond existing websites. Modern web APIs are built on HTTP, just like websites, and security can be addressed right alongside current website security practices—instead of delivering HTML, APIs are delivering JSON and XML. APIs even go further, and by using modern API service composition practices, the Department of Education gains an added layer of security and control, which introduces granular levels of access to all resource, something that does not exist for website. With a sensible analytics layer, API security isn’t just about locking down, it is about understanding who is access resources, how they are using them, striking a balance between the security and access of resources, which is the hallmark of APIs.

oAuth Gives Identity and Access Control To The Student
Beyond basic web security, and the heightened level of control modern API management deliver, there is a 3rd layer to the security and privacy layer of APis that does not exist anywhere else—oAuth. Open Authentication or oAuth provides and identity and access layer on top of API that gives end-users, and owner of personal data control over who access their data. Technology leaders in the private sector are all using oAuth to give platform users control over how their data is used in applications and systems. oAuth is the heartbeat of API security, giving API platforms a way to manage security, and how 3rd party developers access and put resources to use, in a way that gives control to end users. In the case of the Department of Education APIs, this means putting the parent and student at the center of who accesses, and uses their personal data, something that is essential to the future of the Department of Education.

How Will Policy Be Changed?
I'm not a policy wonk, nor will I ever be one. One thing I do know is you will never understand the policy implications in one RFI, nor will you change policy to allow for API innovation in one broad stroke--you will fail. Policy will have to be changed incrementally, a process that fits nicely with the iterative, evolutionary life cyce of API managment. The cultural change at Department of Education, as well as evolutionary policy change at the federal level will be the biggest benefits of APIs at the Department of Education. 

An Active API Platform At Department of Education Would Deliver What This RFI Is Looking For
I know it is hard for the Department of Education to see APIs as something more than a technical implementation, and you want to know, understand and plan everything ahead of time—this is baked into the risk averse DNA of government.  Even with this understanding, as I go through the RFI, I can’t help but be frustrated by the redundancy, bureaucracy, over planning, and waste that is present in this process. An active API platform would answer every one of your questions you pose, with much more precision than any RFI can ever deliver.

If the Department of Education had already begun evolving an API platform for all open data sets currently available on data.gov, the agency would have the experience in API design, deployment and management to address 60% of the concerns posed by this RFI. Additionally the agency would be receiving feedback from existing integrators about what they need, who they are, and what they are building to better serve students and institutions. Because this does not exist there will be much speculation about who will use Department of Education APIs, and how they will use them and better serve students. While much of this feedback will be well meaning, it will not be rooted in actual use cases, applications and existing implementations. An active API ecosystem answers these questions, while keeping answers rooted in actual integrations, centered around specific resources, and actual next steps for real world applications.

The learning that occurs from managing read-only API access, to low-level data, content and resources would provide the education and iteration necessary for the key staff at Department of Education to reach the next level, which would be read / write APIs, complete with oAuth level security, which would be the holy grail in serving students and achieving the mission of the Department of Education. I know I’m biased, because of my focus on APIs, but read / write access to all Department of Education resources over the web and via mobile devices, that gives full control to students, is the future of the agency. There is no "should we do APIs", there is only the how, and I’m afraid we are wasting time, and we need to just do it, and learn to ask these questions along the way.

There is proven technology and processes available to make all Department of Education data, content and resources available, allowing both read and write access in a secure way, that is centered around the student. The private sector is 14 years ahead of the government in delivering private sector resources in this way, and other government agencies are ahead of the Department of Education in doing this as well, but there is an opportunity for the agency to still lead and take action, by committing the resources necessary to not just deploy a single API, but internalize APIs in a way that will change the way learning occurs in the coming decades across all US institutions.


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?

Not everyone has the resources download, process and put open datasets to use. APIs can make all of the publicly available datasets more available to the public, allowing for easy URL access, deployment of widgets, visualizations as well as integration with existing tools like Microsoft Excel. All datasets should have option of being published in this way, but ultimately the Dept. of Ed API ecosystem should speak to which datasets would be most high value, and warrant API access.

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, 15 such as Pay As You Earn; and the Public Student Loan Forgiveness program?

APIs will help decouple each data point on a form. Introductory information, each questions, and other supporting resources can be broken up and delivered via any website, and mobile applications. Evolving a form into a linear, 2-dimensional form into an interactive application that people can engage with, providing the assistance needed to properly achieve the goals surrounding a form.

Each form initiative will have its own needs, and a consistent API platform and strategy from the department of Education will help identify each forms unique requirements, and the custom delivery of just the resources that are needed for a forms target audience.

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?

First, APIs can provide access to the content that educates students about the path they are about to embark on, before they do, via web and mobile apps they frequent already, not being required to visit the source site and learn. Putting the information students need into their hands, via their mobile devices will increase the reach of content and increase the chances that students will consume.

Second, APIs plus oAuth will give students access over their own educational finances, forcing them to better consider how they will manage all the relationships they enter into, the details of loans, grants and with the schools they attend. With more control over data and content, will come a forced responsibility in understanding and managing their finances.

Third, this process will open up students eyes to the wider world of online data and information, and that APIs are driving all aspects of their financial life from their banking and credit cards to managing their online credit score.

APIs are at the heart of all of the API driven digital economy, the gift that would be given to students when they first leave home, in the form of API literacy would carry with them throughout their lives, allowing them to better manage all aspects of their online and financial lives—and the Department of Education gave them that start.

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)?

A consistent API platform and strategy from the department of Education would provide the evolution of a suite of verified partners, such as title IV student loan services. A well planned partner layer within an ecosystem would allow student loan services to access data from students in real-time, with students having a say in who and how they have access to the data. These dynamics introduced by, and unique to API platforms that employ oAuth, provide new opportunities for partnerships to be established, evolve and even be terminated when not going well.

API platform using oAuth provide a unique 3-legged relationship between the data platform, 3rd party service providers and students (users), that can be adopted to bring in existing industry partners, but more importantly provide a rich environment for new types of partners to evolve, that can improve the overall process and workflow a student experiences.

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?

All government forms and programs should be evaluated for the pros / cons of an API program. My argument within this RFI response will be focused on a consistent API platform and strategy from the department of Education. APIs should be be part of every existing program change, and new initiatives in the future.

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?

A consistent API platform and strategy from the department of Education will have two essential components, partner framework, and service composition. A partner framework defines which external, 3rd party groups can work with Department of Education API resources. The service composition defines how these 3rd party groups can can access and ultimately use Department of Education API resources.

All existing groups that the Department of Education interacts with currently should be evaluated for where in the API partner framework they exists, defining levels of access for general public, student up to certified and trusted developer and business partnerships.

The partner framework and service composition for the Department of Education API platform should be applied to all existing individuals, organizations and companies, while also allow for new actors to enter the game, and potentially redefining the partner framework and add new formulas for API service composition, opening up the possibilities for innovation around Department of Education API resources.

2. What applications and features might developers, schools, organizations, and companies take interest in building using APIs in higher education data and services?

As with which Department of Education forms and programs might have APIs apply, which individuals, organizations and companies will use APIs, the only way to truly understand what applications might developers, schools, organizations and companies put APIs cannot be know, until it is place. These are the questions an API centric company or institution asks of its API platform in real-time. You can’t define who will use an API and how they will use it, it takes iteration and exploration before successful applications will emerge.

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)?

When a resource is available via an API, it is broken down into the smallest possible parts and pieces possible, allowing them to be re-used, and re-purposed into every possible configuration management. When you make form questions independently available via an API, it allows you to possible reorder, translate, and ask in new ways.

This approach works well with forms, allowing each entry of a form to be accessible, transferable, and open up for access, with the proper permissions and access level that is owned by the person who owns the format data. This opens up not just the financial aid process, but all form processes to interoperate with other systems, forms, agencies and companies.

With the newfound modularity and interoperability introduced by APIs, the financial aid process could be broken down, allowing parents to take part for their role, schools for theirs, and allow multiple agencies to be engaged such as IRS or Department of Veterans Affairs (VA). All of this allows any involved entity or system to do its part for the financial aid process, minimizing the friction throughout the entire form process, even year over year.

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?

Again, this is a questions that should be asked in real-time of a Department of Education platform. Examples of how 3rd party organizations can better target services and information to students, is the reason for an API platform. There is no way to no this ahead of time, I will leave to domain experts to attempt at answering.

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?

A sensibly design,deployed, managed and evangelized API platform would establish a rich environment for existing educational services to be augmented, but also allow for entirely new types of services to be defined. Again I will leave to domain experts to speak of specific service implantations based upon their goals, and understanding of the space.

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?

There are almost 10K public APIs available in the private sector. This should be viewed as a pallet for developers, and something that developers use as they are developing (painting) their apps (painting). It is difficult for developers to know what they will be painting with, without knowing what resources are available. The open API innovation process rarely is able to articulate what is needed, then make that request for resources—API innovations occurs when valuable, granular resources are available fro multiple sources, ad developers assemble them, and innovate in new ways.

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?

Another question that should be answered by the Department of of Education, and providing us with the answers. How would you know this without a properly definitely partner framework? Stand up an API platform, and you will have the answer.

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?

I can't speak to what is already going on in the space, regarding companies charging feeds to consumers, I am not expert on the education space at this level. This is just such a new paradigm made possible via APIs and open data, there just aren’t that many examples in the space, built around open government data.

First, the partner tiers of API platforms help verify and validate individuals and organizations who are building applications and charging for services in the space. A properly design, managed and policed partner tier can assist in mitigating risk in the evolution of such business ecosystems.

Second API driven security layers using oAuth give access to end-users, allowing students to take control over which applications and ultimately service providers have access to their data, revoking when services are done or a provider is undesirable. With proper reporting and rating systems, policing of the API platform can be something that is done within the community, and the last mile of policing being done by the Department of Education.

Proper API management practices provide the necessary identity, access and control layers necessary to keep resources and end-users safe. Ultimately who has access to data, can charge fees, and play a role in the ecosystem is up to Department of education and end-users when applications are built on top of APIs.

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?

This is a new, fast growing sector, and there are not a lot of existing examples, but there area few:

Open311
An API driven system that allows citizens to report and interact with municipalities around issues within communities. While Open311 is deployed in specific cities such as Chicago and Baltimore, it is an open source platform and API that can be deployed to serve any size market.

Census Bureau
The US Census provides open data and APIs, allowing for innovation around government census survey data, used across the private sector in journalism, healthcare, and many other ways. The availability of government census data is continually spawning new applications, visualizations and other expressions, that wouldn’t be realized or known, if the platform wasn’t available.

We The People
The We The People API allows for 3rd-Party integration with the White House Petition process. Currently only allowing for read only access to the information, and the petition process, but is possibly one way that write APIs will emerge in federal government.

There are numerous examples of open APIs and data being deployed in government, even from the Department of Education. All of them are works in progress, and will realize their full potential over time, maturation and much iteration and engagement with the public.

D. Technical Specifications

1. What elements would a read-write API need to include for successful use at the Department?

There are numerous building blocks can be employed in managing read-write APIs, but there are a couple that will be essential to successful read-write APIs in government:

Partner Framework
Defined access tiers for consumers of API data, with appropriate public, partner and private (internal) levels of access. All write methods are only accessible by partner and internal levels of access, requiring verification and certification of companies and individuals who will be building on top of API resources.

Service Management
The ability to compose many different types of API resource access, create service bundles that are made accessible to different levels of partners. Service management allows for identity and access management, but also billing, reporting, and other granular level control over how services are composed, accessed and managed.

Open Authentication (oAuth 2.0)
All data made available via Department of Education API platforms and involves personally identifiable information will require the implementation of an open authentication or oAuth security layer. oAuth 2.0 provides an identity layer for the platform, requiring developers to use token that throttle access to resources for applications, a process that is initiated, managed and revoked by end-users—providing the highest level of control over who has access to data, and what they can do with it, by the people who personal data is involved.

Federated API Deployments
Not all APIs should be deployed and managed within the Department of Education firewall. API platforms can be made open source so that 3rd party partners can deploy within their own environments. Then via a sensible partner framework, the Department of Education can decide which partners they should not just allow to write to APIs, but also pull data from their trusted systems and open API deployments.

APIs provide the necessary access to all of federal government API resources, and a sensible partner framework, service management layer in conjunction with oAuth will provide the necessary controls for a read / write API in government. If agencies are looking to further push risk outside the firewall, federated API deployments with trusted partners will have to be employed.

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?

There are about 75 common building blocks for API deployments (http://management.apievangelist.com/building-blocks.html), aggregated after looking at almost 10K public API deployments. Each government API will have different needs when it comes to other supporting building blocks.

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?

There are always risks with API access to resources, but a partner framework, service management, oAuth, and other common web security practices these risks can be drastically reduce, and mitigated in real-time

Isolated API Deployments
New APIs should rarely be deployed and directly connected to existing systems. APIs can be deployed as an isolated interface, with an isolated data store. Existing systems can use the same API interface to read / write data into the system and keep in sync with existing internal systems. API developers will never have access to existing system and data stores, just isolated, defined API interfaces as part of a secure partner tier, only accessing the services they have permission to, and the end-user data that has been given access to by end-users themselves.

Federated Deployments
As described above, if government agencies are looking to further reduce risk, API deployments can be designed and deployed as open source software, allowing partners with the ecosystem to download and deploy. A platform partner framework can provide a verification and certification process for federal API deployments, allowing the Department of Education to decide who they will pull data from, reducing the risk to internal systems, providing a layer of trust for integration.

Beyond these approaches to deploying APIs, one of the biggest benefits of web API deployments is they use the same security as other government websites, just possessing an additional layer of securing determining who has access, and to what.

It should be the rare instance when an existing system will have an API deployed with direct integration. API automation will provide the ability to sync API deployments with existing systems and data stores.

4. What vulnerabilities might read-write APIs introduce for the security of the underlying databases the Department currently uses?

As stated above, there should be no compromise in how data is imported into existing databases at the Department of Education. It is up to the agency to decide which APIs they pull data from, and how it is updated as part of existing systems.

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?

As stated above, isolated and external, federated API deployments will decouple the risk from existing systems. This is the benefit of APIs, is they can deployed as isolated resources, then integration and interoperability, internally and externally is up to the consumer to decide what is imported and what isn’t.

6. How should APIs address application-to-API security?

Modern API partner framework, service management and oath provide the necessary layer to identify who has access, and what resources can be used by not just a company and user, but by each application they have developed.

Routing all API access through the partner framework plus associated service level, will secure access to Department of Education resources by applications, with user and app level logging of what was accessed and used within an application.

OAuth provides a balance to this application to API security layer, allowing the Department of Education to manage security of API access, developers to request access for their applications, but ultimately control is in the hand of end users to define which applications have access to their data.

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.

Web APIs use the exact same infrastructure as websites, allowing for the re-use of existing security practices employed for websites. However APIs provide the added layer of security, logging, auditing and analytics provided through the lens of the partner framework, service composition and only limited by the service management tooling available.

8. How do private or non-governmental organizations optimize the presentation layer for completion and accuracy of forms?

Business rules. As demonstrated as part of a FAFSA API prototype, business rules for each form field, along with rejection codes can also be made available via an API resources, allowing for developers to build in a form validation layer into all digital forms.

After submission, and the first line of defense provide red by API developers building next generation forms, platform providers can provide further validation, review and ultimately a status workflow that allows forms to be rejected or accepted based upon business logic.

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?

A modern API service management layer allows the platform provider to see all API resources that are being access, by whom, and easily establish patterns for healthy usage, as well as patterns for misuse. When misuse is identified, service management allows providers to revoke access, and take action against companies and individuals.

Beyond the platform provider, APIs allow for management by end-users through common oAuth flows and management tools. Sometimes end-users can identify an app is misusing their data, even before a platform provider might. oAuth gives them the control to revoke access to their data, via the API platform.

oauth, combined with API service management tooling has allowed for a unique security environment in which the platform can easily keep operations healthy, but end-users and developers can help police the ecosystem as well. If platform providers give users the proper rating and reporting tools, they can help keep API and data consumers in check.

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?

While existing products and services developed within the department do provide great value, the Department of Education cannot do everything on their own. Because of the access the Department has, some features will be better by default, but this won’t be the case in all situations.

The Department of Education and our government does not have unlimited resources, and with access to ALL resources available via the department the private sector can innovate, helping share the load of delivering vital services. Its not whether or not public sector products and services are better than private sector or vice vera, it is about the public sector and private sector partnering wherever and whenever it make sense.

11. What would an app, service or tool built with read-write API access to student aid forms look like?

Applications will look like turbotax and tax act developed within the IRS ecosystem, and look like the tools developed by the Sunlight Foundation on top of government open data and APIs.

We will never understand what applications are possible until the necessary government resources are available. All digital assets should be open by default, with consistent API platform and strategy from the department of Education, and the platform will answer this question.

E. Privacy Issues

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

As described above the partner framework, service management and oAuth layer provides the control and logging necessary to execute and audit as part of any application statutory and regulatory requirement.

I can’t articulate enough how this layer provides a tremendous amount of control over how these resources are access, giving control to the involved parties who matter the most—end-users. All API traffic is throttled, measured and reviewed as part of service management, enforcing privacy that in a partnership between the Department of Education, API consumers and end-users.

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?

As articulated above the partner framework, service management and oAuth address this. This is a benefit of API deployment, breaking down existing digital access, providing access and granular control, combined with oAuth and logging of all access—APIs take control to a new level.

oAuth has come to represent this new balance in security and control of digital resources, allowing the platform, developers and end-users to execute within their defined role on the platform. This balance introduced by APIs and oAuth, allow data to be safeguarded, while also opening up for the widest possible use in the next generation applications and other implementations.

3. How might read-only or read-write APIs collect, document, and track individuals’ consent to have their information shared with specific third parties?

oAuth. Period.

4. How can personally identifiable information (PII) and other financial information (of students and parents) be safeguarded through the use of APIs?

Access of personally identifiable information (PII) via Department of Education APIs will be controlled by students and their parents. The most important thing you can do to protect PII is to give the owner of that data, education about how to allow developer access to it in responsible ways that will benefit them.

APIs open up access, while oAuth will give the students and parents the control they need to integrate with apps, and existing system to achieve their goals, while retaining the greatest amount of over safeguarding their own data.

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?

A well designed partner layer would define multiple level of access, combined with sensible service packages, will establish the terms of service levels that will be bundled with API keys and oAuth level identity and access to personally identifiable information.

Common approaches to deploying partner layers with appropriate service tiers, using oAuth have been well established over the last 10 years in the private sector. Controlling access to API resources at a granular level, providing the greatest amount of access that makes sense, while knowing who is access data and how they are using is what APIs are designed for.

6. What are the relative privacy-related advantages and disadvantages of using read-only versus read-write APIs for student aid data?

You will face many of the similar privacy concerns whether an API is read or write. If it is personably identifiable information, read or write access to the wrong parties violates a student's privacy. Just ensure that data is updated via trusted application providers is essential.

A properly defined partner layer will separate who has read and who has write access. Proper logging and versioning of data is essential to ensure data integrity, allowing end-users to manage their data via an application or system with confidence.

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?

APIs provide a single point of access to student aid data. With the implementation of proper partner framework, service management and oAuth every single action via this doorway is controlled and logged. When it comes to auditing ALL operations whether it is from the public, partners or internal, APIs excel in satisfying compliance concerns.

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?

As described above the partner framework, service management and oAuth will provide the security layer needed to manage 99% of potential abuse, but overall enforcement via the API platform is a partnership between the Department of Education, API consumers as well as end-users. The last mile of enforcement will be executed by the Department of Education, but it will be up to the entire ecosystem and platform to police and enforce in real-time.

3. What kind of burden on the Department is associated with enforcing terms and conditions related to APIs?

The Department of Education will handle the first line of defense, in defining partner tiers and service composition that wraps all access to APis. The Department will also be the last mile of decision making and enforcement when violations occur. The platform should provide the data needed by the department to make decision as well as the enforcement necessary in the form of API key and access revocation, and banning apps, individuals and business from the ecosystem.

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?

First line of define to ensure that API key holders follow all statutory and regulatory provision will be verification and validation of partners upon registration, applications going into production and availability in application galleries and other directories in which students discover apps.

Second line of defense will be reporting requirements and usage patterns of API consumers and their apps. If applications regular meet self-reporting requirements and real-time patterns establishing healthy or unhealthy behavior, they can retain their certification. If partners fail to comply they will be restricted from the API ecosystem.

Last line of defense is the end-users, the students and parents. All end-users need to be educated regarding the control they have, given reporting and ranking tools that allow them file complaints and rank the applications that are providing quality services.

As stated several times, enforcement will be a community effort, something the Department of Education has ultimate control of, but requires giving the community agency as well.

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?

An API with oAuth layer is this vehicle. Providing the access, logging all transactions, and holding all partners to a quality of service. All the mechanism are there, in a modern API implementation, the access just needs to be defined.

6. How should a legal relationship between the Department and an API developer or any other interested party be structured?

I’m not a lawyer. I’m not a policy person. Just can’t contribute to this one.

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?

All of this will be defined in each partner tier, combined with appropriate service levels. With isolated API deployments, this should not affect currently implementations.

However a benefit of consistent API strategy is that existing vendors can access resources via APis, increasing the agility and flexibility of existing contracts. APIs are a single point of access, not just for the public, but 3rd party partners as well as internal access. Everyone involved can participate and receive benefits of API consumption.

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?

A partner tier for the API platform will define the different levels of partners. Trusted, verified and certified partners will get different recommendation levels and access than lesser known services, and applications from 3rd party with lesser trusted levels of access.

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?

Again, the partner tier determines the level of access to the partner and the protocols of all OMB memorandum call be built in. Requiring all data, APIs and code is open sourced, and uses appropriate API access tiers showing how data and resources are accessed and put to use.

API service management provides the reporting necessary to support government audits and regulations. Without this level of control on top of an API, this just isn’t possible in a scalable way, that APIs plus web and mobile applications offer.

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?

Providing API access to government resources is an efficient and sensible use of taxpayers money, and reflect the mission of all agencies, not just the Department of Education. APIs introduce the agility and flexibility needed to deliver the next generation government application and services.

The economy in a digital age will require a real-time partnership between the public sector and the private sector, and APIs are the vehicle for this. Much like it has done for private sector companies like Amazon and Google, APIs will allow the government to create new services and products that serve constituents with the help of the private sector, while also stimulating job growth and other aspects of the economy.

APIs will not all be an up-side, each program and initiative will have its own policy problems and unintended consequences. One problem that plagues API initiatives is enough resources in the form of money and skilled works to make sure efforts are successful. Without the proper management, poorly executed APIs can open up huge security holes, introduce privacy concerns at a scale never imagined.

APIs need to be managed properly, with sensible real-time controls for keeping operations in check.

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?

Partner Framework + Service Management = Quality of Service Across Platform

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?

Not a policy or education expert, I will leave this to others to determine. Also something that should be built into API operations, and discovered on a program by program basis.

4. How would APIs best interact with other systems already in use in student aid processes (e.g., within States)?

The only way you will know is if you do it. How is the IRS-efile system helping with this, but it isn’t even a perfect model to follow. We will never know the potential here until a platform is stood up, and resources are made available. All signs point to APIs opening up a huge amount of interoperability between not just states and the federal government, but also with cities and counties.

5. How would Department APIs benefit or burden institutions participating in title IV, HEA programs?

If APIs aren’t given the proper resources to operate it can introduce security, privacy and support concerns that would not have been there before. A properly run API initiative will provide support, while an underfunded, undermanned initiative will just further burden institutions.

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?

These two things should not be separate. The internal efforts should be seen as just another partner layer within the API ecosystem. All future service and products developed internally within the Department of Education should use the same API infrastructure developed for partners and the public.

If APIs are not used internally, API efforts will always fail. APIs are not just about providing access to external resources, it is about opening up the Department to think about its resources in an external way that benefits the public, partners as well as within the government.