Before attempting to summarise the arguments for and against this mandate, it is worth highlighting the following points from the Department of Labour’s Solicitation for Grant Applications:

The programme, which is releasing $500 million in the first instance, states its aim as follows:

“The TAACCCT provides community colleges and other eligible institutions of higher education with funds to expand and improve their ability to deliver education and career training programs that can be completed in two years or less, are suited for workers who are eligible for training under the Trade Adjustment Assistance for Workers program, and prepare program participants for employment in high-wage, high-skill occupations.”

It goes on to state that:

“The Department is interested in accessible online learning strategies that can effectively serve the targeted population. Online learning strategies can allow adults who are struggling to balance the competing demands of work and family to acquire new skills at a time, place and pace that are convenient for them.”

The SCORM mandate appears under the heading Funding Priorities:

“All successful applicants that propose online and technology-enabled learning projects will develop materials in compliance with SCORM, as referenced in Section I.B.4 of this SGA. These courses and materials will be made available to the Department for free public use and distribution, including the ability to re-use course modules, via an online repository for learning materials to be established by the Federal Government.”

And the Creative Commons mandate is covered in Funding Restrictions: Intellectual Property rights.

“In order to further the goal of career training and education and encourage innovation in the development of new learning materials, as a condition of the receipt of a Trade Adjustment Assistance Community College and Career Training Grant (“Grant”), the Grantee will be required to license to the public (not including the Federal Government) all work created with the support of the grant (“Work”) under a Creative Commons Attribution 3.0 License (“License”).”

It is interesting to note that although the call mandates license and content interoperability formats it does not mandate the use of a specific metadata standard:

“All grant products will be provided to the Department with meta-data (as described in Section III.G.4) in an open format mutually agreed-upon by the grantee and the Department.”

The section in question refers to an appendix of keywords and tags which grantees are advised to use. Although I am unclear from the call whether “grant products” refers to bids and documentation or actual educational resources.

To coincide with the publication of the call, Creative Commons issued a press release with the following endorsement from incoming CEO Cathy Casserly:

“This exciting program signifies a massive leap forward in the sharing of education and training materials. Resources licensed under CC BY can be freely used, remixed, translated, and built upon, and will enable collaboration between states, organizations, and businesses to create high quality OER. This announcement also communicates a commitment to international sharing and cooperation, as the materials will be available to audiences worldwide via the CC license.”

Some bloggers, including Dave Cormier, University of Prince Edward Island, and Stephen Downes, National Research Council of Canada, initially responded with cautious optimism, seeing this initiative as a possible step towards ending “the text book industry as we know it.”

Cormier commented:

“This kind of commitment from the government, money at that scale, that much commitment to the idea of creative commons… this tells me that we might be ready to rid ourselves of the $150 introductory textbook and move to open content.”

Downes concurred because:

“First, government support removes the risk from using a Creative Commons license. Second, it’s enough money. $2 billion will actually produce a measurable amount of educational content. And third, it’s not the only game in town.”

However Cormier was sufficiently incensed about the inclusion of the SCORM mandate to launch a petition on twitter titled “Educational professionals against the enforcement of SCORM by the US Department of Education.”

(In actual fact the TAACCCT call comes from the Department of Labour rather than the Department of Education.)

Rob Abel, CEO of IMS, also responded in no uncertain terms to the inclusion of the SCORM mandate. In a blog post and open letter of IMS members Abel quoted President Obama’s pledge to “remove outdated regulations that stifle job creation and make our economy less competitive,” adding that the inclusion of the SCORM mandate is a “clear violation” of this pledge. Abel claimed that the SCORM mandate is a “ticking time” bomb that will “add enormous cost to the creation of the courses and to the platforms that must deliver them” and “stifle the intended outcomes of the historic TAACCCT investment”. Abel provides a long and detailed critique of SCORM and points out that, “IMS has spent the last five years bringing to market standards that will actually deliver on what SCORM promised” namely Common Cartridge, Learning Tools Interoperability (LTI), and Learning Information Services (LIS).

Chuck Severence, University of Michigan School of Information and IMS consultant,
agreed with Abel’s comments while expanding his self-described rant into a critique of OER initiatives more generally. Severence argued that “this obsession with ‘making and publishing’ OER artefacts that are unsuitable for editing is why nearly all of this kind of work ends up dead and obsolete.” He adds that most OER initiatives “make some slick web site and then try to drive people to their site – virtually none of these efforts can demonstrate any real learning impact.” However Severence does believe that if educational resources are published in a remixable format with a creative commons license they can be of real value and cites his own book Python for Informatics by way of example. He also concedes that the problem is “difficult to solve” before concluding “IMS Common Cartridge is the best we have but it needs a lot more investment in both the specification and tools to support the specification fully.”

A rather more balanced argument was put forward by Michael Feldstein, Academic Enterprise Solutions, Oracle Corporation. While he agreed that mandating SCORM was a mistake he noted that SCORM and IMS CC have “substantially different affordances that are appropriate for substantially different use cases”. While recognizing that it is understandable that “the Federal government wants to mandate a particular standard for content reuse” he added that mandating any specific standard, whether SCORM, IMS CC, RSS or Atom, is likely to be problematic because “educational content re-use is highly context-dependent”. Instead Feldstein suggests:

“The better thing to do would be to require that grantees include in their proposal a plan for promoting re-use, which would include the selection of appropriate format standards.”

Which is exactly the approach taken by the JISC / Higher Education Academy OER Programmes.

Reflecting on these developments from across the pond I have to agree that mandating the use of SCORM for the creation of open educational resources does strike me as being somewhat curious to say the least. This is very much at odds with the approach taken by the JISC / HEA OER Programmes. UK OER does not mandate the use of any specific standards however there are detailed technical guidelines for the programme and CETIS provides technical support to all projects. However the TAACCCT programme is not an OER programme in the same sense as the JISC / HEA UK OER Programmes. It’s interesting to note that while the White House announcement by Hal Plotkin focuses squarely on open education resources, the call itself uses slightly different terminology, referring instead to “open-source courses”.

As CETIS Scott Wilson pointed out on twitter, given TAACCCT’s focus on adaptive self-paced interactive content, the initaitive appears to be more akin to the National Learning Network’s NLN Materials programme which ran for five years from 1999 and which also mandated the use of SCORM with a greater or lesser degree of success, depending on your perspective. This reflection led Amber Thomas of JISC to comment:

“It’s not that mandating standards for learning materials is always wrong, it was the right thing for the NLN Materials – its more nuanced than that. It’s about the point people are at and which direction things need taking in.”

At this stage and at this remove it’s difficult to comment further without knowing more about the rationale behind the Department of Labour’s decision to mandate the use of SCORM for this particular programme. Needless to say, CETIS will be following these developments with interest and will continue to disseminate any further developments.