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From: Carey, Sheila [
[email protected]]
Sent: Thursday,
November 16, 2006 8:16 AM
To: Potter, Rachel F.
Subject: FW:
OMB Comments on Report of Dispute Resolution Under IDEA Part C 1820-NEW --
responses
Importance: High
Follow Up Flag: Follow
up
Flag Status: Completed
Sheila, inserted under the respective questions in
your email below are our responses to Rachel's
questions.
lisa
-----Original Message-----
From: Carey, Sheila
Sent: Wednesday, November 15, 2006 3:07 PM
To: Brown,
Scott; Holden-Pitt, Lisa; Surprenant, Kala
Subject: FW: OMB Comments
on Report of Dispute Resolution Under IDEA Part C 1820-NEW
Please see below comments from OMB. Please
forward the response back to me and I will forward to OMB.
Thanks
-----Original
Message-----
From: Potter, Rachel F.
[mailto:[email protected]]
Sent: November 15, 2006
2:53 PM
To: Carey, Sheila
Cc: Rudolph, Kim; Liu,
Lin
Subject: OMB Comments on Report of Dispute Resolution Under
IDEA Part C 1820-NEW
Sheila,
Attached below
please find OMB's comments on the subject collection. Kala Suprenant
called today to express interest in getting these forms
cleared before Thanksgiving - we are willing to work with
you to clear these forms expeditiously but will need responses to
these questions timely to do so. Please let me know if you have
any questions. Thanks!
- 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.
- This form is
State reporting to ED. What plans does OSEP have to incorporate this
collection into EDFacts? Please provide a detailed explanation of
ED's plan; if ED does not plan to include in EDFacts, please explain why
not.
At present, there are no plans underway
to incorporate this collection into EDFacts. Even the Part B Dispute Resolution form
is currently identified by the EDFacts group as
'unEDENable. Another reason is that Part C
reporting is conducted through a variety of state lead agencies, not solely State Departments of
Education. Most of
these State Lead Agencies are under State
health programs, for example. Consequently, the EDEN/EDFacts
group would first need to establish an additional data
reporting infrastructure (including trained EDEN
coordinators) in those states, to support the report to
EDEN of Part C data. At this time, EDFacts is concentrating
its focus on continuing the transition of Part B data to
EDEN. So, the reporting of Part C data through EDEN seems still a
far ways off.
- 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.
- Please
explain the changes to this form that OSEP is anticipating making based
on the Part C regulations. No
changes (other than regulatory citation updates) are anticipated based
on the Part C-NPRM that is going through ED- Departmental
clearance.
- OSEP has provided
a glossary of terms with this form - do the Part B forms have
a similar glossary? Yes, it
does.
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