Comments on the US DoEd Proposed Rule - Open Textbook Pilot Program
I submitted the following comment today on the Department of Education’s proposed rule “Open Textbook Pilot Program.” The deadline to submit a comment is April 30, so read the rule and get your comments in soon. It may surprise readers to find me arguing against requirements of openness in some of my comments. But in the spirit of “pragmatism before zeal,” I argue in my comments specifically against three unintended consequences of open requirements as they pertain to LMSs, efficacy research, and assessment security / adoptability. It is true that, if the Department acts on my first two comments below, there are aspects of the work that might otherwise have been open that will not end up being open. However, if the Department does act on these comments, the parts of the work that are open will be more widely adopted, will result in more students saving more money, and, most importantly, will result in more students learning more. ...