ED Response to OMB Qs 2

From: Brown, Scott [[email protected]]
Sent: Monday, November 20, 2006 4:49 PM
To: Potter, Rachel F.; Carey, Sheila
Cc: Holden-Pitt, Lisa; Ryder, Ruth
Subject: RE: OMB Comments on Report of Dispute Resolution Under IDEA Part C 1820-NEW -- responses

Follow Up Flag: Follow up
Flag Status: Red

1.  Yes, as I said in the previous email, we are required to collect these data under Section 618 of the statute.  As this requirement is implemented, the SPP reporting reqirement will be dropped.  States analyze child count, service setting and exit data for their SPPs as well.  Thus, proposed 618 requirement for dispute resolution with SPP analysis is no different than these other requirements.

 

We will try to get back to you with an answer for #3.

-----Original Message-----
From: Potter, Rachel F. [mailto:[email protected]]
Sent: Monday, November 20, 2006 4:39 PM
To: Carey, Sheila
Cc: Holden-Pitt, Lisa; Brown, Scott
Subject: RE: OMB Comments on Report of Dispute Resolution Under IDEA Part C 1820-NEW -- responses

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?