Responding to Dept. of Education’s RFI on APIs

The Department of Education has an RFI due tomorrow on the Use of APIs in Higher Education Data and Student Aid Processes. I submitted the following response:


The RFI asks how APIs for higher education data and programs can achieve policy goals of the Administration. As an expert on open government data, I am submitting this comment to address when APIs are useful.

Modern methods of information dissemination and service delivery recognize the long-standing role of mediators in facilitating citizen-government transactions. The media, educational institutions, and many others have long played a crucial role in helping citizens make use of information about higher education produced by the government and enroll in government services. The function of electronic standards for information dissemination and service delivery is to make mediation more efficient and therefore able to reach a wider audience. These new methods are a force multiplier for policy objectives.

Do Open Data First

An API is one of the two modern methods of information dissemination and service delivery specifically sought after by the Administration. Besides building APIs, creating open data — also called bulk, raw, and structured data — is also now an Administration goal as outlined in the White House’s Memorandum on Open Data (M-13-13).

It is important to understand when open data or an API is the right technology for a particular database or service.

Open data, when possible, is always both less costly to implement and more powerful than a “read API”. Here is a summary of why:

* Open data is static but APIs are dynamic. That means that APIs require long-term maintenance to ensure that the API remains continuously and indefinitely available. Open data is released once and updated periodically as needed.

* Open data provides a complete database but APIs provide only a small window into the data. That means that while open data can be used to build any application, an API can only be used to build applications that require a small amount of the data at a time.

* A *good* API requires that the agency do everything that good open data requires plus much more, including the creation of RESTful services, building around use cases, and creating “client libraries”.

A “read API” must do everything that open data does, plus much more. Therefore agencies should walk before they run. Build good open data first, validate that it meets the needs of users, learn how to do that well, and only after validation and learning invest in building an API to address additional use cases.

Open data should always be available before a “read API” is considered. The few cases were open data is not possible for information dissemination (when data changes in real time, like in the stock market, or the data is extremely large) are not likely to apply to data about higher education.

For an example of open data, the Census Bureau and the National Weather Service have been providing open data since the mid 1990s. The practices of open data have a 25-year history.

I advise against the implementation of any read APIs for a dataset before open data for that dataset is available and validated with stakeholders.

Not all open data is created equal. Well-designed open data will prove to be most useful for mediators — and thus the consumers. For more information on open data, please see:

* My book, Open Government Data: The Book, at
* Best practices for open data licensing, at

When to build APIs

That said, the above advice applies only to information dissemination. Read/write APIs are an excellent strategy for the enrollment in or participation in government services. In a read/write API, unlike a read-only API, the external user is submitting information — such as form values — in a transactional process. A read/write API decouples the customer’s experience from the business logic so that mediators can create new experiences but still be in compliant with the agency’s business logic.

Just as with information dissemination, mediators can be valuable during transactions. Different audiences might respond best to different ways in which the transaction occurs (off-line, on an iPad, in large print, in plain language, or using jargon when targeting domain experts, etc.). Using a read/write API, mediators can create new and tailored methods of performing the same transaction and best reach audiences that the agency alone could not best reach.

Since transactions are by their nature dynamic, open data would not meet this need.

Not all APIs are created equal. Exceptional APIs lower the barrier to entry and the ongoing costs for mediators. Poorly designed APIs could result in helping no one.

A well-designed API provides granular access, deep filtering, typed values, normalized tables, RESTful interfaces, multiple output formats, useful validation messages, use-case or intent-oriented URLs, documentation, client libraries, versioning, fast results, high uptime, easy on-boarding, interactive documentation, and a developer community hub. The best APIs are used by the agencies themselves inside their own products and services.

For more information on what makes a good API, please see my blog post “What makes a good API?” at

About Me

I am the founder of, a legislative transparency website that has been at the forefront of open government data since 2004, and I am the author of Open Government Data: The Book ( I formerly consulted for the Department of Health and Human Services on and currently consult for the Council of the District of Columbia. I can be reached at

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