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.