The Supporting Statement does a good job of outlining the rationale for replacing the existing priority with a postsecondary/career (without remediation) goal. Grantees would still be required to report on postsecondary outcomes, but the career (wages) outcome no longer has a corresponding performance measure. I understand the difficulty in collecting wage information, but has ED considered other proxies for determining SLC's impact on career outcomes? Or what about a measure focusing on remediation?

Response: We did consider other options, but concluded that enrollment in postsecondary education should remain our focus because attaining a postsecondary credential will have the greatest impact on employment and earnings outcomes. Nearly all high school graduates who do not pursue further learning after high school find some type of employment simply out of necessity. It is not clear that high schools should be given credit for this outcome. Moreover, one of the studies financed by the 2004 National Assessment of Vocational Education found that the only career and technical education (CTE) "concentrators" who experienced earnings gains as a result of their participation in CTE were those who enrolled in postsecondary education after high school.

In response to public comments, however, we are proposing to collect data on student enrollment in advanced training and registered apprenticeships.

We agree that collecting data on the extent to which students are placed in remedial courses would be valuable. During the first 6 months of the technical assistance contract we will award in September, our contractor will be researching the availability of postsecondary outcome data in each state, including postsecondary enrollment, placement in remedial courses, second semester retention, and second-year retention. Depending upon what we find, we are interested in establishing an additional postsecondary indicator, probably on a pilot basis with a subset of grantees, in the second or third year of the grant period. We will submit a revision to the collection once we have a better sense of our plans.

The application includes a placeholder for the due date. What will the due date be? How long will ED give applicants to respond?

Response: Our goal is to give applicants 60 days to respond, but we may have to reduce the time period to 45 days depending upon when the notice is cleared and published. At a minimum, applicants will have 45 days to respond.

1. Revising the proposed performance indicator to include, in addition to student enrollment in postsecondary education, enrollment in advanced training or registered apprenticeships;

2. require applicants to set aside funds within their proposed budgets to attend Department meetings in each year of the project period, rather than in the first and second years only;

3. revised requirement for applicants to set aside funds to support participation of at least two individuals from each high school included in an application in technical assistance meetings hosted by the Department, instead of the original requirement of five key staff attending;

4. revised original requirement "to allow an LEA to apply only on behalf of a school or schools that will not receive funds through an SLC implementation grant that has a performance period that extends beyond the current fiscal year" by deleting the "will not receive funds" as that reference to school's receipt of funds was ambiguous and could be interpreted in ways inconsistent with ED intent; and

5. Reduced the maximum number of schools an LEA may include in its application from ten to eight, as ED agrees that managing as many as ten schools may be difficult.