1. What is the rationale for having
States report this data via this form and then analyze it separately in
their SPPs?
The child
count, service setting and exit aggregated and disaggregated (by gender
and race) data are required by IDEA Section 618 for all children served
in the State. However, IDEA Sections 616 amd 642 require States to
report data on the State's targets under the performance indicators
established by the Secretary and also report to the public this
performance data disaggregated by EIS program.
Why is ED requesting the data in one place and asking the State
to analyze it in another? Wouldn't it make more sense to
do collect and analyze the data in one
place?
3. Why did the commenter
recommend removing the sentence "This is noted for States because OSEP
may use this calculation in focused monitoring"? No explanation is
given for the commenter's reason and it is therefore difficult
to assess OSEP's response. The
sentence is not fully accurate or appropriate in the reporting form
which is not a monitoring document. OSEP has not
yet determined which performance indicators it will use in
identifying States for focused monitoring. While OSEP must
consider the State's data on compliance indicators under Part C
under IDEA Section 616, it is not clear whether the data on performance
indicators such as child count and service settings will continue to be
primary areas.
OSEP's response in the supporting statement is that the Part
B forms contain this sentence and the Part B and Part C forms
should be identical. Does this sentence apply to Part
C?