30 day public comments

Department of Education
Request for Comment: Ronald E. McNair Postbaccalaureate Achievement Program Annual
Performance Report, Docket ID, ED–2016–ICCD–0072
Field 32a-g, Research Benchmarks
Field 33a-g, Other Scholarly Activity Benchmarks
Field 34a-g, McNair Research Internship Benchmarks
Taken as a whole, the effort to identify specific parts that constitute research may be a good idea,
but as with many things, the devil that is in the details raises problems that limit both the ability
to report and usefulness of what is reported. First, it is unclear that the Department needs the
information to provide effective oversight of McNair programs. To the extent that the
Department wishes to see what each program does (34a-g), there may be merit in gathering some
of this information, but the limitations of the proposed benchmarks runs counter to the
Department’s own guidelines issued in 2010. At that time, the Department noted that many
things could be included in research and scholarly activities. Unfortunately, the existing list
seems to limit the idea of “many things” to mean only a few. Even within those few issues, a
problem remains with the benchmark “Published Research Paper” (32f, and 34f). Certainly
publication is a desirable goal, but it does not happen within the bounds of a summer research
project. Publication may happen as part of Other Scholarly Activities (benchmark 33f), but given
the time necessary for peer review, it is equally likely that publication may not happen until a
McNair participant has completed a bachelor’s degree and moved on to graduate school. A more
meaningful benchmark would be something such as “submitted a paper for publication” because
that is indeed a scholarly activity regardless of whether the paper is published.
The Research Benchmarks listed in 32a-g are the same as those listed for the McNair Research
Internship (34a-g), but problems increase for the Research set. A McNair participant may be
involved in an REU at a distant university or even deeply involved with sophisticated research at
our own university. As directors, we are unlikely to know exactly what the students are required
to do, but that does not mean that the students are not involved in meaningful research that may
lead to publications. Whatever publications result from the research will be related to the
timeline of the lab and the publication cycle, rather than a particular set of a few benchmarks.
Given those realities, the set of benchmarks is too narrow and too limiting. There seems to be no
reason for the Department to need information about activities that REUs or labs might do to
advance various research agenda or even to give undergraduate students exposure to quality
research experiences. Moreover, many REUs are funded by grants from NIH or NSF, sources
that the Department of Education does not oversee. For that reason too, it remains unclear why
the Department would need the information or what the Department would do with the
information it obtained. Once again, the narrowly defined set of benchmarks conflicts with the
Department’s 2010 assessment that research may include a wide variety of activities.
Given the Department’s view that scholarly activities can include many things, the limited list
offered as the set of benchmarks for Other Scholarly Activities (benchmarks, 33a-g) are simply
too limited to achieve whatever broad purpose the Department might hope to achieve. As a
consequence, because it remains unclear why the Department wants the information, and how
the Department would use the information, I suggest that all three sets of benchmarks (32a-g,
33a-g, and 34a-g) be omitted from the performance report.

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10/24/16
Comments on revised draft of proposed changes to the McNair APR
Submitted by: Jo Hinsdale, PhD
Director, McNair Scholars Program
Westminster College, Salt Lake City, Utah

Thank you for the opportunity to comment on the revised draft of proposed changes to the
McNair APR. I appreciate the Department’s responsiveness to the concerns expressed by the
McNair community, particularly with regard to Fields 32, 33, and 34 on Research or Other
Scholarly Activities.
I also acknowledge that the Department would like to “gain a more holistic understanding of
how projects operate” by collecting information on benchmarks related to research and other
scholarly activities. However, it is concerning to many of us to collect such information on our
reporting document. As I mentioned in a phone conversation with Julie Laurel, perhaps the
Department and McNair staff could collaborate with either the Council of Graduate Schools or
the Council for Opportunity in Education to design and administer a survey that would provide
the type of information the Department seeks. There are a number of seasoned McNair
professionals who would very likely be willing assist either organization with such a project,
myself included.
Field 29 Graduating Cohort Year: I noticed that there is a typographical error in the Note to
this field. Currently, it reads: “For example, if the participant earned a bachelor’s degree (or
equivalent) on May 15, 2007, then the participant’s bachelor’s degree cohort year is option 5
(2006-07)….” This should actually be option 6 for 2006-07. Also, the ( mark is missing from in
front of the word “or.”
Thank you again for the opportunity to respond to the Draft McNair APR.