About this time two years ago, President Obama went on his college affordability bus tour and unveiled his plan to take on the rising costs of higher education in front of thousands of students at SUNY Buffalo. Promoting innovation and competition was a key part of his plan and President Obama held up competency-based education (CBE) up as one of the “innovative new ways to prepare our students for a 21st century economy and maintain a high level of quality without breaking the bank.” The President touted Southern New Hampshire University’s College for America CBE approach. The university “gives course credit based on how well students master the material, not just on how many hours they spend in the classroom,” he explained “So the idea would be if you’re learning the material faster, you can finish faster, which means you pay less and you save money.” This earned applause from students in the audience as well as from CBE practitioners around the country.

The Administration had already started to support CBE by allowing federal financial aid to pay for learning, rather than credit hours, using a never-before-used provision of the law called “direct assessment.” The problem was that the whole federal financial aid system is tied to time, so even direct assessment schools were running up against myriad time-based laws and regulations, making it harder for them to maximize the potential of CBE for students. President Obama’s announcement promised to try and change that by using Congressional authority to experiment with these financial aid barriers. It was an exciting day for those who saw CBE as a way to try and break to cost, quality, and access triangle of higher education.

The problem is that day was nearly two years ago and the CBE experimental sites are not yet off the ground. It’s not because institutions aren’t ready and willing. They are. But the Department of Education has been dragging its feet. It took the Department nearly a year after the President’s announcement to issue a notice describing what the experiments would look like. Perhaps this could have been done more quickly, but CBE is complicated and it’s understandable that the Department wanted to be thorough in its review of the relevant laws and regulations (they turned out much more forward-thinking than I would have imagined). But the notice did go out, schools did apply, and schools were accepted to participate. But the experiment hasn’t started, because schools haven’t received guidance on how to do their experiments.

It’s not that schools haven’t asked for guidance. They have. Repeatedly. And schools have stepped up repeatedly, over the course of months and meetings (supported by two of the biggest foundations in higher education, Lumina and Gates), to think through many of the issues the Department would likely grapple with. And the guidance still didn’t come. Finally, in the spring of this year, the Department promised to have guidance out by the beginning of June (cutting it close for programs that wanted to start in the fall, but still). Yet, here we are in mid-August and there’s no guidance to be found, so no experimental programs will be starting up this fall.

For an administration that has a limited time left in office and sees innovation as one of the key ways it is going to address college affordability, this is pretty embarrassing. In the meantime, the Department keeps announcing (or hinting at) other experiments they want to run, including dual enrollment, Pell for prisoners, setting up new quality assurance providers, and allowing non-colleges access to federal financial aid. While I am glad to see the Department finally using the authority they’ve been given to push innovations that could benefit students, some of these new experiments may be even more complicated than the CBE experiment. What faith should we have in these efforts if the Department can’t even follow through with one that it announced two years ago? Saying you’re going to do something doesn’t count. You have to actually do it. Announcements aren’t policy; implementation is.

Ideally, the Department’s experiments could have informed Higher Education Act reauthorization conversations (How do x, y, or z waivers work on the ground? What other barriers are institutions facing? What student protections are lost if you waive x, y, or z?). Indeed, that is the point of these Congressionally-authorized experiments. But as of now there is nothing new to add to the conversation, other than further fodder for those who say government can’t be innovative.

I know I sound grumpy. And I am. Perhaps I’ll feel better when I come back from vacation after labor day–but not if the guidance still isn’t out.