Costs Are Hypothesized, Not Assumed
The white paper is explicit that any future ROI or savings projection must come from real pilot data and should never be presented as established fact before that data exists. Hypothesized benefit categories — reduced breach costs, reduced help-desk burden, faster emergency response — are named as things to be measured, not claimed in advance.
Governance With Built-In Limits
The proposed multi-stakeholder oversight body sits at a national layer while local and institutional systems remain the system of record for day-to-day identity issuance, attestation, and revocation — preserving the local control emphasized throughout the framework. Critically, the oversight body’s authority and the registry’s scope are proposed to be subject to periodic legislative or regulatory review, not open-ended by default.
A Phased, Opt-In Path Forward
Policy recommendations call for establishing the Contact Initiative as a voluntary interoperability standard endorsed — not mandated — by federal education authorities, preserving state and local control. Any adopting state or district would be required to complete the open legal-review items before handling real student data, and initial pilots would be funded through a competitive grant mechanism rather than an unfunded mandate, with results published regardless of outcome.