Commentary: A Review of Proposed Changes To Mandatory Data Collection

A Review of Proposed Changes to the Annual Mandatory Collection of Elementary and Secondary Education Data through EDFacts

By: Jennifer Searcy

Founder/Director of Public Policy & Affairs

The Coalition for Positive Behavioral Interventions & Supports

October 11, 2009

The Department of Education makes it mandatory that schools and local education agencies (LEAs) submit certain civil rights data to the Department twice a year during each school year. The Department notifies schools and LEAs in writing of what information (data sets) they must submit. Schools may report information through an electronic system known as the Eden Survey Tool (ESS), by mainframe submissions, or by paper surveys.

Because data was not collected for the 2008-2009 school year reportedly as a result of a delay in the approval of the 2009 budget, this year, a request for a new data set to be collected has been proposed beginning with the 2009-2010 school year.

New data reporting is to include, but is not limited to: “Restraints and Seclusion Incidence Table” by School, “Restraints or Seclusion IDEA Students Subjected Table” by School, “Restraints or Seclusion Non-IDEA Students Subjected Table” by School, “Harassment or Bullying Policy Table” by LEA, “Harassment or Bullying Incidence Table” by School, and “Harassment or Bullying Students Subjected Table” by School.

A request has also been made to discontinue collecting certain data. Among the data that previously was collected but has been proposed to be omitted includes, but is not limited to: “Children Evaluated for Special Education but Not Receiving Services Table” by School and “Children without Disabilities Cessation Table” by School.

It is unclear why the request to discontinue data collection regarding children who are eligible for but not yet receiving special education services and children who have been expelled but not offered other educational services has been made. However, data for “Children Awaiting Evaluation for IDEA”, “Children Receiving Services Solely under Section 504”, and “Discipline of Students with Disabilities (IDEA and Section 504)” will continue to be collected.

Data that was collected by the Eden Survey Tool (ESS) only that had been previously approved and which has been requested to be merged in with data collected by the Civil Rights includes but is not limited to: “Children with Disabilities (IDEA) School Age Table – Disability Category and Education Environment” by School, Teacher Quality in Elementary and Secondary Classes Tables by School, and Student Performance in Language Arts, Mathematics, and Science Tables by School.

Data that was collected by both the Eden Survey Tool (ESS) and the Civil Rights Data Collection (CRDC), which is proposed to only be collected by ESS includes “Disability Category and Educational Environment in the data group: Children with Disabilities (IDEA) School Age Table by School” and LEA-level Totals in the Data Group: Children with Disabilities (IDEA) School Age Table by LEA.

The Department is also proposing the CRDC “[c]ollect data from a sample of approximately 7,000 LEAs and all schools in those LEAs. The sample will include all LEAs with enrollment of 3,000 or more, about 300 other LEAs specified by OCR, and about 3,000 LEAs statistically selected by random stratified sampling. This sample size and composition will ensure that the Office for Civil Rights has data on a widely representative group LEAs and adequate coverage for statistically reliable national and state projections.”

What this means is that data from every school in every district in every local education agency (LEA) in every state of this nation will not be collected, analyzed, or made publicly available.

The ability to collect this data already exists; data was collected from all schools in all LEAs in every district in every state in 2000.

Additionally, “[t]he last two CRDCs, the 2004 CRDC and the 2006 CRDC, were conducted primarily on-line via the EDEN Survey Tool as part of the EDFacts family of data. Mainframe submissions and paper surveys were allowed; one state provided all the data on behalf of its LEAs and another state provided some data on behalf of its LEAs. All data from these alternate methods were merged with data collected via the EDEN Survey Tool and the entire dataset was transferred into EDFacts.”

To read the document in its entirety, go to http://edicsweb.ed.gov, click on ‘browse pending collections’ and then click on ‘info collection 04127 at http://edicsweb.ed.gov/browse/browsecoll.cfm?pkg_serial_num=4127. Scroll down this page and then click “Att_EDFacts CRDC 2009 B-4 changes v23-cb.doc” for the list of data to be collected.

The public may submit comments on these proposed revisions to ICDocketMgr@ed.gov until November 10, 2009.