Response to 30D Comments Change Memo

Memorandum United States Department of Education

Institute of Education Sciences

National Center for Education Statistics

DATE: May 18, 2023

TO: Robert Sivinski, OMB

THROUGH: Carrie Clarady, NCES

FROM: Stephen Q. Cornman, NCES

SUBJECT: Common Core of Data (CCD) School-Level Finance Survey (SLFS) 2022-2024 Responses to 30D Comments Change Request (OMB# 1850-0930 v.5)

NCES annually publishes comprehensive data on the finances of public elementary/secondary schools through the Common Core of Data (CCD). For numerous years, these data have been released at the state level through the National Public Education Financial Survey (NPEFS) (OMB#1850-0067) and at the school district level through the Local Education Agency (School District) Finance Survey (F-33). (OMB# 0607-0700). There is a significant demand for finance data at the school level. Policymakers, researchers, and the public have long voiced concerns about the equitable distribution of school funding within and across school districts. School-level finance data addresses the need for reliable and unbiased measures that can be utilized to compare how resources are distributed among schools within local districts. Education expenditure data are now available at the school level through the School-Level Finance Survey (SLFS).

The School-Level Finance Survey (SLFS) data collection is conducted annually by the National Center for Education Statistics (NCES), within the U.S. Department of Education (ED). In November of 2018, the Office of Management and Budget (OMB) approved changes to the SLFS wherein variables have been added to make the SLFS directly analogous to the F-33 Survey and to the Every Student Succeeds Act (ESSA) provisions on reporting expenditures per-pupil at the local education agency (LEA) and school-level. A previous package cleared in April 2023 approved data collection for FY 2022, 2023, and 2024 (OMB# 1850-0930 v.4). This request included considerable modifications to the previous package, most important of which was the proposal for NCES to assist the Office of Civil Rights (OCR) with collecting school level finance data as part of the Civil Right Data Collection (CRDC), resulting in the establishment of SLFS as a mandatory data collection. This package contains documentation and materials for the incremental action plan that will allow NCES to conduct in 2023 through 2025 the SLFS for fiscal years 2022 through 2024 (corresponding to school years 2021/22 through 2023/24), and to bring on board a number of states that had previously not participated in the SLFS. NCES staff members carefully considered comments and recommendations on the SLFS incremental action plan, particularly pertaining to providing sufficient “ramp-up” time for state and district level personnel to submit school-level finance data. The incremental action plan requires SEAs to report total current expenditures for each public PK-12 school within the state for school year 2021-22; and SEAs to report total current expenditures by four subfunctions and three exhibits for school years 2022-23 and 2023-24.

As part of the public comment process, NCES received a number of comments from stakeholders and members of the general public. The responses to comments that were received during the 60-day public comment period were included in the package as Appendix D. NCES received an additional batch of comments during the 30-day public comment period. This change request is to add the responses to those 30-day comments, as found in the attached document Appendix D2, to the official public record for this package.

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