International Education and Foreign Languages: Keys to Securing America's Future (2007)

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10 Increasing the Numbers of Underrepresented Minorities in International Service I t is generally recognized that the upper reaches of the U.S. diplomatic corps do not reflect the diversity of the nation. To address this, former secretary of state Colin Powell made the recruitment of minorities at the U.S. Department of State a top priority, stating that he wanted a foreign service that “looks like America” (Powell, 2003). However, recruitment efforts at the late stages of a student’s career might also be augmented by reaching out to them at earlier ages, to encourage interest in international affairs, the study of languages, and study abroad. While minority students make up 30 percent of the population of postsecondary students, they make up only 15 percent of the students who choose to study abroad (Institute of International Education, 2004). The Institute for International Public Policy (IIPP) was created in Title VI by Congress in 1992 with the specific mission of preparing minority students for careers in international service. When the law was passed, the Senate Committee on Labor and Human Resources noted with concern that only 13 percent of those serving in the U.S. foreign service were minorities, and only 6 percent were black (Slater, 2006). Around that time, just below 25 percent of the U.S. labor force consisted of people in minority groups, and 11.1 percent of the workforce was black. In 2004, 30 percent of the U.S. labor force consisted of people in minority groups; this is predicted to rise to about 35 percent in 2014 (Toosi, 2005). There are two ways Title VI and Fulbright-Hays (Title VI/FH) pro- grams strive toward the goal of increasing representation of minorities in international service. The first and most direct way is through IIPP. The second way that this goal is pursued is through projects that have some 196 

INCREASING UNDERREPRESENTED MINORITIES IN SERVICE 197 focus on underrepresented groups, but are funded under other Title VI/FH programs, such as Business and International Education (BIE), Centers for International Business Education and Research (CIBER), Language Re- source Centers (LRC), and National Resource Centers (NRC). Title VI/FH efforts to increase minority representation also differ in the organizational level of their focus. IIPP’s Fellowship Program focuses on individual par- ticipants by encouraging their interest in possible careers in international affairs, helping them learn a language, providing them with study abroad opportunities, preparing them for and assisting them with graduate stud- ies, and helping them enter employment in an international field. IIPP’s Institutional Resource Development Grant Program and the projects funded through other Title VI/FH programs focus at the level of the educational institutions and ways that those institutions can more effectively engage and educate minority students on international issues. IIPP conducted an internal review in 2006 that provides some of the data for this chapter (United Negro College Fund Special Programs Cor- poration, 2006). In addition, the committee commissioned an analysis of ongoing IIPP data and award information across programs to identify ways in which Title VI/FH programs are attempting to increase the number of underrepresented minorities in international service (Joyner, 2006a). Most of the material in this chapter is drawn from these two sources. Joyner’s analysis included a review of data collected by IIPP as well as its internal review of its activities; a review of narrative information provided to the U.S. Department of Education (ED) by institutions that received grants through Title VI/FH programs; and a search of the Evaluation of Exchange, Language, International and Area Studies (EELIAS) database using the mi- norities subject area to identify other Title VI/FH programs that included a focus on minorities. Joyner notes that this methodology may not have identified all the projects that are targeting efforts toward underrepresented minorities; the strategy used at the time of the committee’s review to code subject areas in EELIAS may not have identified all relevant projects. She identified some projects that were not picked up by the subject area search but did not conduct a systematic search of all projects. IIPP FELLOWSHIP PROGRAM IIPP is a fairly new program, created in 1992 when the Higher Educa- tion Act was reauthorized. The program officially began in 1994 with a congressional appropriation of approximately $1 million. The first award   Subject areas were coded by the ED contractor managing the EELIAS system based on their review of the project abstract. In ED’s proposed redesigned system, subject area will be entered by the grantee. 

198 INTERNATIONAL EDUCATION AND FOREIGN LANGUAGES was made to the United Negro College Fund, which established the insti- tute. The grant was later transferred to the United Negro College Fund Special Programs Corporation, which competed for it successfully in the most recent competition in 2004. The current grant (FY 2004 through FY 2008) provides $4,871,428 in total funding for the four years. ED describes its grant to IIPP as being intended to “establish an insti- tute designed to increase the representation of minorities in international services, including private international voluntary organizations and the U.S. Foreign Service” (see http://www.ed.gov/programs/iegpsiipp/index. html, accessed Nov. 2006). Program administrators identify part of their goal as increasing the numbers of members of racial and ethnic minority groups going into the nation’s foreign policy institutions with a broader goal of “enhanc[ing] U.S. national security and global competitiveness by promoting excellence, international service and awareness among a broader, more representative cross-section of the American citizenry” (see http://www.uncfsp.org/iipp/content/objectives.cfm, accessed Feb. 2007). There are two main projects under IIPP: the Fellowship Program, which reaches individual students, and the Institutional Resource Development Grant Program, which targets institutions. Under the institutional program, only one project is currently in operation, the Globalizing Business Schools project, whereby historically black colleges and universities are paired with CIBERs to internationalize the institutions’ business curriculum. Two previous projects, no longer funded, involved creation of an Asian studies program and Chinese language studies through distance learning for pre- dominantly minority-serving institutions. Given that there are no available evaluations of the prior projects and an evaluation of the current project is still under way, the committee was not able to come to any conclusions regarding the Institutional Resource Development Grant Program. IIPP’s primary emphasis is on its Fellowship Program, which offers a comprehensive six-component program to undergraduates who are mem- bers of racial and ethnic minority groups aimed at preparing them for ca- reers in international affairs. A total of 20 students enter the program each year. Since the program’s inception in 1994, there have been 254 partici- pants. IIPP reports that the racial/ethnic breakdown of participants to date is 48.6 percent black, 24.1 percent Hispanic, and 15.6 percent Asian/Pacific Islander; with the remainder in other categories or not reported (United Negro College Fund Special Programs Corporation, 2006). Participants are predominantly female—almost 75 percent. The figure reflects enroll- ments nationwide: 65 percent of black undergraduates and 74 percent of black graduate students are female (Toosi, 2005). IIPP cites a study by the Institute for International Education (2002), which reports that 65 percent of participants in study abroad programs are female, to suggest that the gender imbalance is not unusual and to highlight that the percentage of 

INCREASING UNDERREPRESENTED MINORITIES IN SERVICE 199 women admitted to IIPP is higher than the national average for students in study abroad programs. Fellowship students are offered the following program components: • Sophomore Summer Policy Institute—students are introduced to international affairs as a field of study; included is a trip to Washington, DC, for briefings at foreign policy agencies and nonprofits, such as the Council on Foreign Relations. • Junior Year Study Abroad—students study abroad for a semester during their junior year at an accredited institution, following preparation and orientation sessions. IIPP pays for half of the total cost of the semester abroad, including program fees and personal expenses. • Junior Summer Policy Institute—preparation for graduate study. Students attend an eight-week Junior Summer Policy Institute at the Uni- versity of Maryland School of Public Policy during the summer following overseas study. The institute is designed to prepare fellows for the rigor of graduate programs and the graduate school application process. • Summer Language Institute—intensive language study to prepare students for a career or to facilitate acceptance into graduate school. Most fellows study at the Middlebury College Language Schools in Vermont. • Internship—usually at one of the 100 federal agencies with area or language needs. • Graduate Fellowships—students are encouraged to enroll in gradu- ate programs in international relations or a related field. Joyner (2006b) found that students participating in the program are not required to participate in all components; in fact, according to data provided by IIPP, only 16 percent can be shown to have done so. Almost all (99 percent) of program graduates completed the initial Sophomore Summer Policy Institute, and 82 percent studied abroad. Most (91 percent) also completed the Junior Summer Policy Institute. The completion rate for other components was less impressive—35 percent completed the Sum- mer Language Institute, 56 percent completed internships, and 43 percent went on to graduate school (Joyner, 2006b). However, students can skip the language portion if they feel they have adequate skills, and others may choose to attend graduate school at a later date. IIPP estimates that the program spends, on average, approximately $70,000 to $80,000 per student for those who participate in the full set of activities. Each of the components listed above costs between $9,000 and $12,000 per student, except for the Graduate Fellowship, which costs IIPP $15,000. The IIPP cost is matched by the graduate institution the student is attending. Given the Fellowship Program’s design (i.e., the number of years re- 

200 INTERNATIONAL EDUCATION AND FOREIGN LANGUAGES quired to complete all components and the relatively small number of students in any given year) and its relatively short number of years in op- eration, one would not expect to see a large number of program graduates in international service careers. The first participants entered as college sophomores in summer 1995, and it takes several years to complete an undergraduate degree and a master’s degree and then find employment. By IIPP’s own estimate, there are only 141 graduates who would meet these criteria. IIPP did conduct a survey to collect placement data on the first seven cohorts of the program—those IIPP considers to have had time to com- plete graduate school and enter the workforce. However, they point out several limitations similar to the ones related to NRC graduate placement data discussed in Chapter 6, including the lack of employment history for 35 percent of the students in these seven cohorts (placement data are also unknown for about one-third of NRC graduates). For participants who did provide employment data, responses are difficult to interpret because the employment categories are not well defined in the survey. Participants’ employment choices were business, government, international organization, educational organization, nonprofit organization, and research organiza- tion, with no definitions or instructions on how the categories differed (United Negro College Fund Special Programs Corporation, 2006). Of the 141 participants in the first seven cohorts, employment data were obtained for 93 of them. The program could clearly document only 38 placements (27 percent of all participants and 41 percent of those for whom placement data were available) that they would consider a success: 22 participants employed in government and another 16 employed at an international organization. IIPP considers employment in either government or an international organization to represent employment in a position “congruent with the IIPP program.” Given the ambiguity in definitions, however, it is unclear whether this number overstates or understates the number of program alumni in international service. For example, those employed in government could be employed in federal, state, or local government and in any kind of capacity, engaged in activity with no rela- tionship to international affairs. Those who found employment in other categories—educational, nonprofit, or research—might indeed be engaged in international activities. There is also no record of how many program graduates found employment with the State Department, in accord with ED’s goals. The goals of IIPP’s internal evaluation also included assessing the pro- gram’s impact on the participants’ personal and professional lives. Of the 212 students who had entered in cohorts 1 through 10, 122 (57.5 percent) completed the web-based survey that elicited self-reports on this aspect of the program. Their responses indicated that the program led to multiple 

INCREASING UNDERREPRESENTED MINORITIES IN SERVICE 201 personal benefits, such as an enhanced personal support network, goal fo- cus, and personal insight; increased commitment to work in international service; and provided multiple professional benefits, including expanded ca- reer options and improved knowledge of international issues and events. The internal evaluation also identified several ways in which IIPP could improve its activities, including the collection of better data on employment outcomes and doing more to encourage and facilitate careers in interna- tional service. The latter point is an important one. While IIPP participants report that the program has had a positive impact on them, it is not yet getting large numbers of participants into international service. The Fellow- ship Program produced only 212 students from underrepresented groups in its first 10 years, and only a small number of the graduates who might be expected to be employed can be shown to have gained employment in international service or to be pursuing such employment. Its evaluation states that there is a “gap between the commitment to international ser- vice, the percentage of fellows that major in this area in graduate school, and the number of fellows that pursue a career in international service” (United Negro College Fund Special Programs Corporation, 2006, p. 39). Former IIPP fellows have recommended that the program explore service agreements with federal agencies (as with the National Security Education Program); agreements with federal agencies and other organizations to open entry-level positions would have to be negotiated as a means to address this problem. IIPP also concluded that career advising had to be strengthened in order to get more participants employed in international service careers, and that current and former participants could be better used in a network- ing or mentoring role in order to help other participants with decisions about graduate school or career opportunities. OTHER TITLE VI-FUNDED PROJECTS AIMED AT MINORITY STUDENTS Projects other than IIPP aimed at increasing opportunities for minori- ties in international careers fall into two categories: outreach to students and faculty and research on barriers to fuller participation of underrepre- sented minorities in international service. Table 10-1 summarizes some of the institutional efforts to increase minority representation that have been funded by other programs under Title VI/FH. For example, two CIBER programs have collaborated with IIPP, through its Institutional Resource Development Grant Program, in involving historically black colleges and universities. The University of Washington NRC has introduced Arabic classes in Seattle high schools with high minority enrollments. The University of the Incarnate Word, which serves predominantly Hispanic students, has received a BIE grant to sup- 

202 INTERNATIONAL EDUCATION AND FOREIGN LANGUAGES TABLE 10-1  Title VI-Funded Institutional Projects Related to Increasing Representation of Minorities Grant Grantee Cycle Description Program: Institute for International Public Policy (IIPP) United Negro FY Administers training, institutional resource development, College Fund 2004- outreach, and research programs aimed at involving a more Special Programs 2008 representative cross-section of the American citizenry in Corporation international affairs. Program: Business and International Education (BIE) University of the FY The grantee, a Hispanic-serving institution, will expand Incarnate Word 2005- internships and study abroad and other opportunities for 2006 students to acquire international business expertise in the European Union; and strengthen faculty expertise and instructional resources on the European Union. Program: Center for International Business Education (CIBER) Indiana FY The grantee’s CIBER participated in a consortium project that University- 2002- pairs eight business schools with a partner from the community Bloomington 2005 of historically black colleges and universities. This CIBER assisted Norfolk State University with a BIE proposal to ED. A collaboration with IIPP. Texas A&M FY One of this CIBER’s outreach activities is its membership in the University 2002- CIBER/United Negro College Fund initiative to promote the 2005 internationalization of business education at historically black colleges and universities. A collaboration with IIPP. Program: Language Resource Centers (LRC) University of FY The grantee, an LRC, has focused on distance learning of less Hawaii-Manoa 2002- commonly taught languages, particularly Asian languages. One 2005 project extended instruction to the beginning and second-year levels via a mix of face-to-face and online instruction. Testing of the beginning-level Mandarin Chinese course was done in cooperation with the United Negro College Fund and Dillard University in New Orleans. A collaboration with IIPP. Program: National Resource Centers (NRC) University of FY The Center for Southeast Asian Studies has emphasized Hawaii-Manoa 2003- mentoring faculties from other minority-serving institutions in 2005 Southeast Asian studies. A collaboration with IIPP. University of FY One outreach activity of this NRC was to teach Arabic in four Washington 2003- Seattle public high schools, three of which were in economically 2005 disadvantaged neighborhoods with a high proportion of minorities enrolled. 

INCREASING UNDERREPRESENTED MINORITIES IN SERVICE 203 TABLE 10-1  Continued Grant Grantee Cycle Description Program: International Research and Studies (IRS) National FY The National Association for Equal Opportunity in Higher Association 2005- Education, an association of 118 historically and predominantly for Equal 2007 black colleges and universities, will conduct a survey of these Opportunity institutions to understand their current status and capacity in Higher to provide instruction in common and less commonly taught Education foreign languages as well as international studies. United Negro FY This project has four goals: (1) to provide relevant and College Fund 2005- comprehensive data about the attitudes and participation Special Programs 2006 patterns of minority undergraduates with respect to Corporation international education activities and programs; (2) to identify factors that impact their participation; (3) to develop replicable strategies and assessment tools that institutions can use to assess and increase minority participation; and (4) to widely disseminate the results in an effort to broaden the national dialogue among federal, state, and campus leaders on international education issues to include topics of access, diversity, and minority student interests and needs. University of FY A national study of the effects of institutional factors at public Pittsburgh 2003- four-year colleges and universities on the participation of 2004 undergraduate ethnic and racial minorities in international education opportunities. SOURCE: Joyner (2006b). port study of the European Union. In addition to the above efforts, three research projects have been funded by IRS to address barriers to minority participation in international programs and subsequent careers. These studies may yield useful insights about how to increase minority representation in international education. Joyner (2006b) concludes that the initiatives that are attempting institutional change have the potential to affect a larger number of students than does IIPP’s Fellowship Program. Current Title VI/FH programs aside from IIPP might be reworked in such a way as to involve more minority students, even at the high school level. Although there have been no studies of the success of these programs, it appears that adding a component of outreach to minority students under other Title VI programs, such as NRC, LRC, Undergraduate International Studies and Foreign Language, BIE, and CIBER, is worth exploring. 

204 INTERNATIONAL EDUCATION AND FOREIGN LANGUAGES OTHER FEDERAL PROGRAMS WITH SIMILAR GOALS Other federal programs with similar goals appear to be reaching out to far larger numbers of students in minority groups and getting them to study abroad, attend graduate school, and go into international service careers. These programs appear to have a strong expectation that participants will continue in international service careers. Some State Department programs feature mentors who are currently in the Foreign Service to guide students along in the process. While the committee did not undertake any review of the effectiveness of these programs and makes no judgments about them, we discuss these programs for the purpose of rough comparison and to place Title VI/FH programs such as IIPP in the context of similar programs that also seek to increase minority interest in international careers. The State Department’s Thomas Pickering Foreign Affairs Fellowship Program identifies promising students interested in careers at the State Department. The legislation creating the program states that “special em- phasis” should be placed on recruiting minority students. Fellowships are awarded each year on the basis of academic merit and financial need to sophomore or senior students attending a four-year college or university. Participants selected as sophomores are eligible to receive funding for their junior and senior years and first year of graduate school. Participating schools provide financial support for the final year of graduate study, based on need. Students selected as seniors are eligible to receive funding for both years of graduate school. Participants then attain a master’s degree in a field related to interna- tional affairs from a leading graduate school. Also, participants complete two required paid internships: a 10-week domestic internship in various offices throughout the State Department, depending on their academic interest, and a 10-week internship at a U.S. embassy or consulate abroad. In addition, all participants partner with a senior Foreign Service officer as a mentor prior to the start of their graduate studies; the mentor keeps in touch with the student to help make decisions about graduate study and to prepare academically for the Foreign Service examination. Administrators of the Pickering Program report that the mentoring component is crucial to its success. There also is a service requirement for the Pickering Program; that is, fellows are contractually tied to employment as Foreign Service officers. Students completing the undergraduate fellowship serve for a period of at least 4.5 years, and graduate fellows must serve for a period of at least 3 years. The Pickering Program has a high completion rate: 94.5 percent. Since the program’s inception in 1992, it has funded 325 participants, and of 

INCREASING UNDERREPRESENTED MINORITIES IN SERVICE 205 these, fewer than 20 fellows have withdrawn or resigned. Again, adminis- trators attribute this in part to the mentoring aspect of the program. A total of 40 new fellows are chosen each year. For an annual budget of $5 million (FY 2007), the program funds 118 students at various stages of their studies (email correspondence with State Department staff, January 3, 2007). Additional programs that seek to increase minority interest in interna- tional careers also exist: • The Charles Rangel International Affairs Graduate Fellowship Pro- gram (administered by Howard University), is very similar to the Pickering Program but is even more specifically aimed at getting minority students into graduate international affairs programs and then into the Foreign Service. Like IIPP, it starts with a summer session following the students’ junior year to prepare them for graduate school and educate them about career paths. As with the Pickering Program, participants benefit from two internships: one with a member of Congress and another at a U.S. embassy overseas. Participants are required to attend graduate school in a relevant field and then take the State Department’s Foreign Service examination. Current Foreign Service officers act as mentors. A total of 10 fellowships of up to $28,000 are awarded annually. • The Louis Stokes Educational Scholarship Program was created by U.S. Representative Louis Stokes (D-OH), whose tenure in Congress included chairmanship of the House Intelligence Committee. The purpose is to bring more women and minorities into employment with the federal law enforcement and intelligence agencies. The program is administered in different ways by participating agencies. At the National Security Agency (NSA), for example, applicants for the Stokes language program must be minority college sophomores majoring in foreign languages, with at least six credits completed in Arabic, Chinese, Farsi, or Korean. They must have a minimum college freshman grade point average of 3.0. Grantees work during the summer at NSA in areas related to their course of study. They receive tuition at the college of their choice, reimbursement for books and fees, housing and travel, a year-round salary, and employment with NSA after graduation for at least 1.5 times the length of study. • The Gilman Scholarship, sponsored by the State Department, aims to broaden the student population that studies abroad by supporting un- dergraduates who have been traditionally underrepresented and those who might otherwise not participate due to financial constraints. This includes students studying in nontraditional locations, community college students, students of diverse ethnic backgrounds, students representing a diverse range of institutions and institutional types, students with disabilities, and students of nontraditional age. The scholarship program provides awards 

206 INTERNATIONAL EDUCATION AND FOREIGN LANGUAGES to students who are receiving federal Pell grant funding at a two-year or four-year college or university; the average award is approximately $4,000. There were 351 recipients in 2004-2005. • The Public Policy and International Affairs Fellowship Program, formerly known as Woodrow Wilson Fellowships in Public Policy and International Affairs, has produced over 2,500 alumni since its inception in 1980. Interestingly, it is not a federal program; instead, it was formed when a number of professional associations for policy analysts and public administrators joined with foundations to address the problem of minority representation in positions of leadership in public service. Increasing mi- nority representation in international service was added as a goal in 1989. The program targets minority students in their junior year of college. Par- ticipants are expected to attend a junior summer institute to prepare them for graduate study; to attend graduate school and earn a degree related to public policy, public administration, or international affairs; and then to pursue employment in a public service-related career. The graduate schools that form the consortium of participating institutions represent the nation’s major public policy graduate schools. Graduates of the program have gone on to employment with the State Department. CONCLUSIONS AND RECOMMENDATIONS International education programs appear to have had little effect so far on the number of underrepresented minorities in international service, but it is possible to make more of an impact in the future. Currently, primary responsibility for encouraging minority involvement in international stud- ies seems concentrated in one program, IIPP. There are two problems with this approach. First, IIPP is not reaching very many students and, second, greater potential may exist under other component parts of Title VI/FH to reach many more minority students. The goal of maximizing interest by minority students in foreign languages, area, and international studies is too important to be left to one corner of Title VI/FH; instead, efforts in this area should be made across a wide variety of the programs. IIPP has enrolled approximately 250 students over the past 12 years, but the grantees can document only 22 students who have entered any kind of government employment and only 16 who work for an international organization. While this may be an undercount, and collection of data and analysis of job placements of graduates are difficult in general, the IIPP Program has not yet demonstrated significant results and has few graduates to date and significant costs per fellow. The general awareness of what IIPP does is quite low; it might attract more students with a significant interest in international service or the Foreign Service if its profile was raised. The small number of graduates and significant costs per fellow for all 

INCREASING UNDERREPRESENTED MINORITIES IN SERVICE 207 components is influenced by the comprehensive design of the program. Yet few fellows complete all components of the program—particularly the final components. Fewer, more targeted components would enable more students to participate and might result in more fellows completing the program and pursuing international careers. This would require an assess- ment of the relative contributions of each component and should include exploration of promising models from other similar programs. IIPP has engaged in some institutionally based collaborative efforts with other Title VI-funded projects, but no information is available about how successful those have been. Recommendation 10-1:  The Institute for International Public Policy should redesign its activities in order to increase graduation rates and facilitate entry in careers in international service. In considering how to redesign its programs, IIPP should examine other programs with similar goals, such as PPIA and the Pickering, Rangel, and Stokes fellowship programs. This should include exploring how these pro- grams nurture an interest in international service, encourage completion of the program, and facilitate graduates’ employment in the Foreign Service, other federal bureaucracies, and international organizations. IIPP might also do well to partner with institutions, such as those in PPIA’s consortium of graduate schools, that already graduate large numbers of students who go on to careers in international affairs. IIPP should also explore opportunities for direct partnerships with potential government employers. In addition, in accord with the recommendations of its internal review, IIPP should also make more use of program alumni as mentors to assist current participants in completing the program and finding relevant employment. Mentors can also be identified at the foreign affairs bureaucracies who could advise par- ticipants wishing to pursue a career in international service; the Pickering and Rangel fellowship programs might serve as models. There is potential in efforts under a wide variety of Title VI/FH pro- grams to reach out to minority students. Greater responsibility for this important goal should be shared among as many of the programs as pos- sible. Because foreign language, area, and international studies programs are already established at a wide variety of college campuses with significant minority enrollments, minority outreach should be emphasized. ED should do more to increase the numbers of minority students who see international service as a viable career track and to indicate their interest in grantees reaching this population. This might include ensuring that new initiatives aimed at K-12 include efforts to recruit minority students. Universities’ abil- ity to attract minority students will be dependent in part on the interests students bring with them from high school. 

208 INTERNATIONAL EDUCATION AND FOREIGN LANGUAGES Recommendation 10-2:  The Department of Education should encour- age Title VI and Fulbright-Hays grantees to actively recruit minority members. The potential reach of other Title VI/FH programs is far greater than IIPP alone and ED should convey its interest in enhanced efforts to recruit minority students. Applicants might be encouraged, for example, to con- duct outreach to K-12 school districts with large minority enrollments or heritage and immigrant populations, and ED might facilitate partnerships between Foreign Language Assistance Program grantees with substantial minority enrollments and Title VI grantees. ED could award points for such efforts in the review process. To help raise awareness of interest in recruit- ing members of minority groups and to collect information on the overall number of minority students who participate in Title VI/FH, ED might also consider requiring grantees to report the number of minority students served via its online grantee monitoring system. The feasibility of this data collection should be discussed as part of the recommended continuous im- provement process (see Chapter 11).