Attachment F-2
Annual Mandatory Collection of Elementary and Secondary
Education Data through EDFacts
July 2019
Attachment F-2
EDFacts Data Set
for School Years 2019-20, 2020-21, and 2021-22
Response to 30-Day Public Comments
This attachment contains responses to public comments on the Annual Mandatory Collection of Elementary and Secondary Education Data through EDFacts. The 30-day comment period for the EDFacts package closed on May 8, 2019. ED received a total of 82 comment submissions, many covering multiple topics, totaling 111 individual comments (see below).
Submitters |
Submissions |
Individual Comments |
Total |
82 |
111 |
State |
13 |
37 |
Association |
13 |
18 |
Individual |
56 |
56 |
This document is organized by individual comment topics. Each section provides a summary of the public comments received, ED’s response(s) to those comments, and any resulting changes, if any, being made to the proposed data collection package. In addressing the public comments and making revisions to the package, ED focused on recommendations from the public comments that continue to move EDFacts forward in achieving the goals of consolidating collections, obtaining high quality data, and reducing burden on data submitters.
ED appreciates the time and attention the public spent on reviewing the EDFacts package and in composing thoughtful comments that shape the final data set, as evidenced in this attachment. ED reviewed, summarized and documented each statement prior to analyzing all statements. This documentation will aid in the finalization of this data clearance package and will serve to inform future policy decisions regarding EDFacts.
Over half of the individual comments received during the 30-day public comment period were in support of adding the school psychologists as a staff category. These comments came from 10 associations and 54 individuals, citing that the addition will provide valuable information to help decision makers and interested stakeholders ensure adequate and equitable access to school psychological services and develop effective recruitment and retention strategies. Submitters also suggested an alternative definition. Stating that the alternative definition more accurately captures the role of the school psychologist and will provide clarity and accuracy in data reporting.
ED Response
Based on the overwhelmingly supportive comments, the Department will revise its staff category definition for FS059/DG528 Staff FTE for school psychologists (first proposed in the 30-day package) as follows:
School Psychologists (PSYCH): Professional staff member who provides direct and indirect support, including prevention and intervention, to evaluate and address students’ intellectual development, academic success, social-emotional learning, and mental and behavioral health.
There were comments received from one association regarding charter schools asking the Department to reconsider some of the proposed changes.
ED Response
Due to the increase in reporting burden and public comments associated with these changes, the Department has decided to remove many of the proposed new charter school data groups from this collection package. However, the Department is still interested in understanding the different charter school enrollment policies and will work with states, through groups like the National Forum on Education Statistics, to develop this understanding. The Department will continue to look for ways to modernize the CSP Data Collection and the reconciliation of that data to the school level directory data submitted to EDFacts. The Charter School Program office will continue to explore ways to make data on the Charter school program more publicly available.
Eight different states, three associations, and one individual provided comments on data groups and categories supporting IDEA.
Public Comments
Eight states, two associations, and one individual provided 16 comments on the proposed change to move 5-year-old Kindergarten students to the school-age educational environment file. The majority of comments were in support of this change. However, the comments also noted that many states may not be able to make this change by SY 2019-20 and asked for this change to be put into effect in SY 2020-21.
ED Response
Though the majority of commenters supported the change to report 5-year-old children with disabilities in Kindergarten in the school-age Part B Child Count and Educational Environments data in EDFacts file 002, they recommended giving states the option to report in this way for the 2019-20 data and requiring states to report in this way for the 2020-21 data. The Department agrees with the recommendation to provide a one-year transition period for states to implement the new reporting requirement. States may report 5-year-old children with disabilities who are in Kindergarten in either EDFacts file 002 or in EDFacts file 089 for the 2019-20 Part B Child Count and Educational Environment data. We ask that states who continue to report the 5-year-old children with disabilities in Kindergarteners in EDFacts file 089 for the 2019-20 data submit a data note indicating that they are in the process of transitioning to meet the new reporting requirement and will be able to report the 5-year-old children with disabilities in Kindergarteners in EDFacts file 002 for 2020-21.
Public Comments
Two commenters asked how changing the reporting of 5-year-old children with disabilities who are in Kindergarten for the Part B Child Count and Educational Environments data will impact the IDEA Part B Annual Performance Report Indicators 5 and 6.
ED Response
The current Part B IDEA State Performance Plan/Annual Performance Report (SPP/APR) information collection package expires on August 31, 2020. Prior to that time, OSEP will review and propose necessary changes to the indicators included in the IDEA Part B SPP/APR package. OSEP will take the changes to any of the IDEA Section 618 data collections into consideration when reviewing the indicators. Any changes to the indicators will be published in the Federal Register for a 60-day and 30-day public comment period.
Public Comment
One commenter asked how changing the reporting of 5-year-old children with disabilities who are in Kindergarten for the Part B Child Count and Educational Environments data will impact the least restricted environment (LRE) piece of calculating significant disproportionality.
ED Response
The Department is reviewing and revising, as needed, guidance on the implementation of significant disproportionality at this time. OSEP will take this question into consideration while preparing these resources.
Public Comment
One commenter suggested that the Part B Child Count and Educational Environments data be collected by grade.
ED Response
The IDEA formula grant funds are distributed based on the age, not the grade, of the children with disabilities receiving special education and related services. Since the IDEA Section 618 data are associated with the IDEA formula grants, OSEP believes it is important to maintain the disaggregation of children with disabilities receiving special education and related services by age. Furthermore, OSEP does not believe it is necessary to add a requirement to have the IDEA Part B Child Count and Educational Environments data reported by grade in addition to by age. This would create an additional reporting burden for states and OSEP does not have an intended use for Part B child Count and Educational Environments data reported by grade.
Public Comment
One commenter asked whether changing the reporting of 5-year-old children with disabilities who are in Kindergarten for the Part B Child Count and Educational Environments data will impact the IDEA Section 611 funding.
ED Response
This change to the Part B Child Count and Educational Environments data collection will not impact how states are allocated IDEA Section 611 funds from the Department. Additionally, OSEP believes that this change should not impact how states and LEAs use their IDEA formula grant funds. The IDEA Section 611 funds can be used to provide services to children with disabilities ages 3-21. The IDEA Section 619 funds can be used to provide services to children with disabilities ages 3-5.
Four states and two associations provided comments on the proposed data category changes to teacher and paraprofessional FTEs. The comments supported not collecting grade span but also asked to change from age to grade levels.
ED Response
The majority of comments suggested changing the IDEA Personnel data from reporting special education teachers and paraprofessionals by age-based categories (i.e., ages 3-5, ages 6-21) to reporting by the grade levels of preschool and school age in order to better align these data with the changes to the Part B Child Count and Educational Environments data. OSEP agrees with the suggestion and will allow states to report the special education teachers and paraprofessionals who are employed or contracted to work with 5-year-old children with disabilities who are in Kindergarten in the school age (i.e., ages 6-21) reporting category. We will provide a clarification about how to report these personnel in the EDFacts file specifications for 070 - Special Education Teachers and 112 - Special Education Paraprofessionals. We will allow a one-year transition period for states to begin reporting the special education teacher and paraprofessional data for EDFacts files 070 and 112 in this way. During the transition period, we request that states provide a data note explaining where the personnel employed or contracted to work with 5-year-old children with disabilities who are in Kindergarten are reported in the IDEA Personnel data.
There were several metadata collections that received comments.
One state and one association submitted comments on the new metadata collection regarding accountability. While the state noted that the request was duplicative, the association supported the metadata collection.
ED Response
The Accountability Metadata Survey was developed to aid in the interpretation of the data submitted in the accountability indicator EDFacts files. While the EDFacts files require a certain level of standardization across the States, the metadata survey allows us to collect more information specific to each State to ensure ED does not misinterpret the data. The Department does not believe the information to be duplicative as it is specific to the EDFacts data files and this level of detail is not included in most State ESSA plans.
One state submitted comments on the assessment metadata collection regarding English Language Proficiency assessments.
ED Response
The Department would like to thank the state for their thorough review and identifying inconsistencies in the language of the metadata questions. These questions will be updated with the state’s suggested changes.
Some final corrections were made to the IDEA Metadata surveys to support changes already made in the School Year 2018-19 collection, such as deleting the minimum dropout age question.
Public Comment – Physical Location of Schools
One state provided comments on ED’s question in the 60-day package regarding the physical location of schools, noting that ED encourages states to expand data on locations. However, ED does not propose changing the reporting of address information to report on multiple addresses. The comment also noted that most states responded that their systems are not designed to collect additional address information. Since the NAEP uses the federal directory, even if states maintained additional address information, the NAEP would not have access to the information and will continue to have issues with their sampling frames and locations. It is unclear how states maintaining additional information will benefit ED if these data are not reported to ED.
ED Response
The Department encourages states to expand data on locations. The Department will retain the guidance that most schools will have a single physical location while some schools will share a single physical location. When schools have multiple physical locations, states and LEAs should examine to see if the locations individually meet the criteria for a school. If so, the different locations should be reported as different schools.
Public Comment – Perkins Career Clusters
One state shared some concerns on a few of the career cluster permitted values.
ED Response
States are encouraged, but not required, to use the National Career Clusters® Framework, to categorize their career and technical education programs for the purpose of reporting in the Consolidated Annual Report (CAR). However, states have the flexibility to elect how they wish to define their own career clusters, and to categorize their career pathways in a manner that accurately reflects the program and curricular sequences of the state.
Public Comment – REAP Alternative Funding Status
One state provided comments on the definition of this data group (DG# 614).
ED Response
The Department would like to thank the state for their thorough review and identifying inconsistencies in the language. The data group definition has been updated.
Public Comment – Comprehensive Support
One state provided comments on the revisions and allowing for more reporting choices for these schools.
ED Response
Thank you for your comment. Additional changes will be made to this data group (DG# 842) to allow for more nuanced reporting.
Public Comment – IDEA Funding
One state suggested that states are afforded a budget beyond the existing annual grant award to embark on upgrading their individual special education collection/data systems to achieve improvements in automating the collection, analyzing and compliance monitoring of special education data.
The comprehensive nature of ensuring the delivery of free and appropriate public education (FAPE) to students with disabilities requires that State's thoughtfully collect an enormous amount of data from each LEA.
Leveraging technology will provide many benefits to include: the application of rigor to reduce error; enable compliance monitoring personnel to spend more time conducting compliance monitoring and less time collecting and analyzing data, and finally to be used to compile APR data to streamline this process.
Leveraging technology to fully and efficiently carry out the tall order of the IDEA-B is a reality that I'm confident would ensure all the more that children with disabilities receive FAPE in a timely manner in the LRE.
ED Response
Under IDEA Regulations 34 CFR § 300.704(b), states may use IDEA funds set aside for state-level activities in order to make improvements to their data collection systems. Additionally, OSEP funds multiple data technical assistance centers to assist states with improving and enhancing special education and early intervention data collection systems and data management processes and procedures. These centers can provide assistance to states to achieve improvements in automating the collection, analysis and compliance monitoring of special education data.
ED Technical Changes
As with every package, ED has made a few minor technical changes that did not result in a substantive change to items. These are marked as revised in Attachment A.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Modified | 0000-00-00 |
| File Created | 0000-00-00 |