ED Response to OMB Qs 3

 From: Brown, Scott [[email protected]]
Sent: Tuesday, November 21, 2006 5:24 PM
To: Potter, Rachel F.; Carey, Sheila
Cc: Holden-Pitt, Lisa
Subject: RE: OMB Comments on Report of Dispute Resolution Under IDEA Part C 1820-NEW -- responses

Follow Up Flag: Follow up
Flag Status: Red

Hi Rachel.  This is my best try at a response to your question # 3.  We believe the sentence was added to the form in the hopes that OMB would not decide to remove the information about other calculations from the form.  Those other calculations were added because, during our internal discussions, we surmised that states should be made aware of the assumptions of (other calculations that can be made from) the data collection.  Some of those items were originally data
collection items (some where part of the old APR data collection) which we removed to reduce data burden.  If OMB wishes to remove the sentence, the sentence is probably critical so long as the other calculations stay on the form.

 

If this form is approved, we would hope it would be assigned the same number as the other Part C forms or the same number as the Part D Dispute Resolution form, whatever OMB thinks is most appropriate.

 

Thank you for your consideration off our request and have a Happy Thanksgiving, Rachel.

 

Scott

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?