Att E-ED's Response to Public Comments

Paperwork Reduction Act Submission Supporting Statement

Annual Mandatory Collection of Elementary and Secondary Education Data through EDFacts

August 2007

Attachment E

EDFacts Response to

Public Comments

a)Table of Contents

Chapter Section Page

Attachment E. EDFacts Response to Public Comments E 1

Summary E 1

Policy E 2

Directed Questions E 8

Directed Question 1 – Data Group E 8

Directed Question 2 – Categories E 8

Directed Question 3 – Status Files E 11

Directed Question 4 – Migrant E 13

Directed Question 5 – School Operational Status E 15

Directed Question 6 – GEPA E 17

Directed Question 7 – Reading NCLB State Assessments E 21

Technical E 23

Changes Resulting from Public Comments E 54

EDFacts Response to Public Comments

Summary

This attachment summarizes the public comments ED received during the 60-day public comment period for the proposed EDFacts SY 2007-08 Data Collection Notice, which was published in the Federal Register on May 11, 2007 (26801-26803). ED received approximately 300 public comments from 12 states, 2 organizations, and several individuals.

ED appreciates the time and substantial effort that state agencies, national education organizations, and individuals devoted to reviewing the OMB package. Many of the comments led to changes in the EDFacts data set. These changes are reflected in Attachments B and C.

The remaining pages of Attachment E are presented in the following four sections:

1. Policy – This section contains in question format a summary of the comments raising overall policy issues along with ED’s response.

2. Directed Questions – This section contains the seven (7) questions directed to the public in the Federal Register notice published on May 11, 2007. In this section, ED provides (1) the question, (2) a summary of the comments and ED’s response, and, where useful, (3) the detailed comments for each question.

3. Technical – This section contains ED’s response to technical comments. These comments are organized by topic area and provide the original question and ED’s response.

4. Changes – This section contains a summary of the significant changes made to the EDFacts data set in Attachment B as a result of the public comments.

In addition, ED received comments on the availability or lack thereof of information about specific data groups. These comments were shared with the program offices and will be used as ED works with SEAs on their transition plans.

Policy

This section provides ED’s response to comments raising overall policy questions. After each policy question, there is a summary of the comments and then ED’s response.

1. Will states be allowed to submit EDFacts data on a different reporting schedule?

Some commenters pointed out that the EDFacts collection schedule does not correspond to states’ data collection schedules that have been established to meet the data reporting schedules of the individual federal program offices.

The EDFacts team has noted the specific suggestions for improving the data submission schedules and will work with the states as a group to make the collection schedule more realistic for all of the states. The EDFacts team will also work with those states whose circumstances prevent them from submitting some of their data as early as other states are able to submit their data. The final decision about when the data are required rests with the federal program office that uses the data to make funding and policy decisions.

2. Will ED provide federal support to states to help them provide data?

Most commenters indicated that the mandatory collection creates significant additional paperwork burden and requested a federally funded position to help support this work. One commenter suggested the burden was 50% greater than estimated by ED, and another said ED underestimated the total burden on states and districts without providing an estimate of what the real burden is. A few commenters suggested that IES grants were not a solution since almost half of the states have not been awarded a grant, and those that have are not required by the terms of those grants to provide support to EDFacts. The consensus of the commenters is that ED should provide long-term federal funding to support the states in providing these data similar to the funding provided for a NAEP Coordinator in each state.

ED recognizes that many states will find it challenging to make the changes needed to complete the transition to full EDFacts participation. Although ED is providing significant grant funding to help states modernize their education data systems, the ongoing operation, maintenance, and enhancement of state information systems is not a federal responsibility. States must ensure that data are available to guide education improvement as part of the business of effectively providing education services in the schools and districts. ED will continue to help support the states through these grants, as well as through additional technical assistance by the EDFacts Partner Support Center and other expert support contractors working with the states and the EDFacts team. Together we will work to share “best practices” and “lessons learned” to mitigate the challenges each state faces.

ED continues to work with other policymakers in the Administration and in the Congress to explore the feasibility of establishing a federally funded position within the states to coordinate the collection and reporting of elementary and secondary education information. The establishment, definition, and funding of this position is not definite. Any progress toward this goal will be reported to the states when known.

We note that Title VI, Part A (Section 6111)(H) permits the use of state assessment grant funds for improving the dissemination of information on student achievement and school performance, including the development of information and reporting systems. The development of data systems is listed in Section 6111 as a permitted use of those funds. The EDFacts team will be sharing information with the states about some of the ways individual states have used these funds to develop their data systems.

3. Will ED provide an EDFacts reports development schedule?

One commenter asked ED to provide a development schedule of proposed EDFacts reports so that SEAs could allocate the resources to provide a thorough, quality review.

The EDFacts team will work with those states that are interested in improving communication about the development of these reports. The continued expert review and evaluation of data and reports by the states is considered essential to the success of EDFacts.

4. Will ED publish a consolidated package of all data collections related to EDFacts?

One commenter asked for the publication of a consolidated package of all the data collected by EDFacts to be pre-populated in other ED data collections.

ED continues to work toward this goal. Attachment D provides some detail on the progress that has been made in this area. There continues to be a concentrated effort among the many ED program offices to ensure that the shortest route possible will be taken to secure quality data through EDFacts and revisit the current data collection activities of the separate program offices. Over the past 12 months, the EDFacts team has used technological improvements to facilitate further leveraging of EDFacts data by some offices to meet their program needs. ED continues to use its portion of the clearance process under the Paperwork Reduction Act (PRA), prior to submission of the proposed collections to the Office of Management and Budget (OMB), to promote state observation and participation in the development of EDFacts policies and decisions.

5. Will ED use MSIX instead of asking states for migrant data?

One commenter recommended that the new MSIX application for migrant student data become the master file and that EDFacts collect nothing that is collected in MSIX.

The purpose of the Migrant Student Record Exchange Initiative (MSIX) is to establish standards for minimum education and health data that each state must collect and maintain in its existing electronic state migrant student record system; to develop an “electronic exchange” that will link all states’ migrant student record systems to facilitate the consolidation of migrant students’ education and health information; and create a web-based consolidated migrant student record that can be used by authorized school personnel to facilitate school enrollment, grade/course placement, and the accrual of secondary course credits. The primary purpose of MSIX as defined by Congress is to facilitate the transfer of records of migrant students so that their education is not interrupted.

Given that the MSIX will initially be available in October 2007, and that there are a limited number of data elements common to both MSIX and EDFacts, MSIX data will not be immediately used to pre-populate EDFacts. The EDFacts and MSIX Teams will consult with states and evaluate the feasibility of leveraging MSIX data to pre-populate EDFacts in future years as the MSIX application matures.

6. What is the ED priority to develop standard public reports of EDFacts data?

One commenter wanted to know the priority that will be given to the development of standard reports of EDFacts data shared with the public.

As resources allow, work continues to develop standard reports on EDFacts data, some of which will be eventually provided to the public. The schedule for having publicly available data through EDFacts has not been finalized.

7. Will ED require districts to supply data to states electronically?

Some commenters expressed concern that EDFacts does not require local school districts to submit data to states electronically.

As explained when ED published amended regulations governing state reporting requirements, a state may require local school districts to submit reports in a particular manner or format “if that State has the requisite authority to do so under its State laws and regulations.” Therefore, it is up to each state to determine the appropriate manner and format that local school districts should use in reporting data that will be transmitted to EDFacts.

8. Will ED freeze the EDFacts data definitions and file specifications?

Most commenters requested a moratorium (“freeze”) on the current EDFacts data elements for 3 years, although the range varied from 2 to 5 years. As part of this “freeze,” most also wanted a clear statement that any new data elements would be accorded a full 2-year transition period from the year they are introduced. Commenters indicated they require this lead time to make the system changes at the state and district levels needed to properly collect and process the new data. They asked that data groups required for the first time in the EDFacts 2007-08 collection package not be required until the 2009-10 collection cycle, just as the 2006-07 data have a transition period until the 2008-09 collection cycle. Some commenters also noted that data cannot be provided because the data that are not collected in the current year cannot be retroactively reported in later years.

The EDFacts team is seeking a 3-year approval from OMB to assure states that the core EDFacts data elements will be stable into the future. ED has established a limited change policy for core EDFacts data elements and will continue to work to ensure that any changes focus on improvements and remain minimal.

The EDFacts team has established a phase-in transition schedule for the EDFacts data elements. They will continue to work to customize the implementation of the mandatory data submission requirements with each individual state through that state’s submission plan. Data groups that were not in the mandatory 2006-07 collection but have been added to the 2007-08 collection will enjoy the same transition option of 2 years if the state meets the requirements of the regulations for justifying the delay.

9. Will ED eliminate inconsistencies and stabilize the data definitions? Will ED expand EDFacts to include more federal program data collections? Will ED reconcile federal program definitions with EDFacts definitions?

Most commenters mentioned that the changing data definitions and inconsistencies between federal program office definitions and the EDFacts requirements create problems for them. A number of commenters expressed support for the EDFacts effort to consolidate federal education data collections, and some even suggested additional collections that should be included in EDFacts in the future. Many commenters suggested that work still needs to be done to reconcile traditional program data definitions and data reporting requirements with the mandatory EDFacts collection requirements. One commenter noted that it made a lot of suggestions and saw comparatively little change last year. Many noted that continuing changes to the EDFacts data definitions increase state burden.

These questions have been joined together because they reflect the constant tension that exists in the development of the EDFacts data groups. On one hand there is the need to freeze all data definitions and file specifications because stability is essential for systems development work. On the other hand, adding program collections requires changes (improvements and expansions) to the current group of EDFacts data elements. In order to include more current program collections within EDFacts and to reconcile continuing data definition differences, the EDFacts team must make changes.

The EDFacts team will continue to work closely with state data providers and the federal program office experts to clarify data definitions and incorporate data requirements of existing program collections into the EDFacts collection while minimizing the burden and maximizing the stability of the EDFacts system.

12. Will states be allowed to extend their transition period into EDFacts?

One commenter claims that the current “phase-in periods are still too aggressive” and asked for 2 additional years “for states showing measured progress.” That commenter also asked for a prioritized list of data files “from the single highest priority file to the single lowest priority file.”

Through EDFacts, ED seeks to collaborate with states to strengthen their own state data systems and the use of those data to improve education within their states. A necessary condition for local, state, or federal educators to be able to fully use any data is the completeness of that data. The EDFacts team will work with each state to establish reasonable expectations for what a complete submission entails.

EDFacts established the requirement of an individual state data submission plan in order to address the unique data submission challenges of each state data provider. Working together with states, the EDFacts team provides tools to help states assess their state-specific challenges and develop a plan and schedule to submit their EDFacts data. In all cases, the EDFacts team is committed to providing the support that is needed to help individual states that are making reasonable, concerted efforts to comply in good faith with the EDFacts data submission requirements.

The EDFacts regulations at 34 C.F.R. Part 76 proscribe the conditions under which the Secretary may grant an extension for up to 2 years on an electronic data collection.

13. Will EDFacts collect data from the states for the Civil Rights Data Collection?

Several public comments addressed the proposed plan and schedule to incorporate the biennial Civil Rights Data Collection (CRDC) data from the districts into the annual EDFacts collection of data from the states. The commenters identified areas where the CRDC collects data from school districts that are currently not collected by the state education agencies. Commenters stated that the proposed change would create additional burden on the state agencies. Commenters requested that EDFacts reconsider the CRDC implementation schedule and timing of the collection, and recommended that the current process—i.e., collection by ED from each school district—continue to be used, with the possible enhancement of the pre-population of EDFacts data into the district and school data collection forms.

The proposed plan furthers ED’s larger vision of a consolidated data system for all K-12 data regularly collected by ED. Historically the CRDC, unlike other ED data collections, was collected directly from school districts. ED is aware that the proposed plan is a significant change and will increase burden on state education agencies, which have not previously provided CRDC data. However, where school districts have been reporting the same or similar data items both to the state and separately to the CRDC, the proposed plan will reduce the burden on such school districts. ED remains committed to consolidating K-12 data collection—including the CRDC—into EDFacts in a way that reduces overall burden, improves data quality and usability, and provides flexibility to the extent possible.

Accordingly, ED will focus on implementing an appropriate transitional model for the 2008 CRDC. ED is encouraged by the 2006 CRDC, which collected responses from 100 percent of the surveyed districts in half the time it took to complete the 2004 collection. ED will work with states to identify the appropriate set of data that states can report to EDFacts on behalf of their districts and schools. ED will engage states in a collaborative discussion about the proposed plan and about how best to structure or revise data collection models to ensure that the civil rights-related data are accurate, complete, and timely. As outlined in Attachment B-4 of this package for the EDFacts data set for SY 2007-08, ED anticipates that all data elements for the CRDC will be collected via the EDEN Submission System by SY 2010–11.

14. What is the requirement to report all data including “small cell size” data?

One commenter suggested that some states’ policies on not reporting student data when fewer than 10 students were in a group would prevent those states from reporting data to EDFacts.

The Secretary is responsible for the stewardship of the programs administered by the Department. To fulfill that responsibility, the Secretary needs complete, accurate, and reliable data regarding the programs entrusted to her, including the data contained in small data cells. The data contained in small data cells are essential to ensure that the funds made available to the states and subgrantees are obligated and expended consistent with statutory and regulatory requirements applicable to the programs.

The issue of small numbers in data cells was raised in the clearance of the 2006-07 EDFacts data collection instrument. As we said at that time, “ED appreciates the concern about protecting the privacy of personally identifiable information and is fully committed to meeting all legal requirements to protect information submitted to EDFacts, both in how it uses the data within ED, and, in the future, how it may disseminate that information to states, LEAs, and others. In addition, ED will apply a uniform standard to protect personally identifiable information it may disseminate to the public.” We are fully committed to meet all legal requirements to protect individual privacy.

In light of this concern, ED added a sentence to the Introduction of this collection package in Attachment B-1, under EDFacts Data Notes, to clarify that in submitting EDFacts data files, states cannot suppress the data in small data cells except as specifically authorized by federal statute.

Directed Questions

This section provides consolidated responses to the seven questions directed to the public that ED included in the Federal Register notice published on May 10, 2007. In this section, ED provides (1) the original text of the question, (2) a summary of the comments as well as the ED response, and where useful (3) the detailed comments for each question.

Directed Question 1 – Data Groups

Question Text: An underlying purpose of the EDFacts Data Set is to inventory the data collected by ED. That inventory is organized into data groups and categories. In general, each table data group is its own file. Three data groups (Title I SWP/TAS Participation Tables ID 548, N or D Academic Outcomes Table (LEAs) ID 629, and N or D Academic Outcomes Table (State agencies) ID 628) were split so that the data groups would meet the definition of “a specific aggregation (i.e., group) of related data that is stored in EDFacts to satisfy the specific information need of one or more ED program office.” Are there any other data groups that should be split? Are there any data groups that should be combined?

Summary of Comment and ED Response:

One commenter suggested combining student performance. 

Initially, student performance was a single data group.  It was a single data group because it was viewed as a single type of data.  As such, there was a single file that contained all the student performance data.  With data on both reading and mathematics, that file was very large.  Many SEAs indicated they had problems processing that file.  While we agree that student performance is a single type of data, because of the amount of data submitted we have decided to leave it as more than one data group, each with its own file.

Directed Question 2 – Categories

Question Text: Data on students are collected by categories (characterizations used to aggregate data, e.g., race/ethnicity, sex, grade level). In some cases, the data by these characterizations is not required on all students. For example, data on the results of NCLB assessments are required to be aggregated by students with a disability status (IDEA) and by students who have been assessed as limited English proficient. Data are not required by statute to be aggregated by either students without a disability status or students who have not been assessed as limited English proficient. However, that data are useful to the Department for both data quality and analysis. There are times when data are required to be aggregated for all students. For example, data on provision of educational services during expulsion are required by statute to be aggregated for both students with a disability status (IDEA) and without a disability status (IDEA). What is the burden for the SEA when aggregating data for only those students with the characteristics compared to aggregating for both students with the characteristic and without it for the following characteristics: Disability status (IDEA), assessed for limited English proficiency, homeless status, homeless served under McKinney-Vento status, economically disadvantaged status, and migrant status?

Clarification of the question: Some commenters questioned the Department’s collecting any data not required by statute.  The phrase “required by statute” was used to refer to data specifically mentioned in the statute.  The Department also collects data not specifically mentioned in statutes but necessary to meet the Department’s oversight responsibilities under statutes.  The Department has responsibilities to ensure data quality and to analyze data to make decisions about technical assistance and monitoring activities as well as report on the performance of programs.  In collecting data to assist the Department in meeting its responsibilities under statutes, the Department carefully considers the approach to minimize burden on the states.

Summary of Comments and ED Response:

Commenters explained that aggregations for with and without characteristics depend on whether the data were collected for the entire population or only the population with the characteristics.  The collection of with and without could vary for different types of data.  It was also pointed out that aggregations that combine characteristics are more burdensome than single characteristic aggregations.  A student records system might not include all characteristics.

Based on the above explanation, the use of categories that collect both with and without and multiple aggregations will be carefully examined.

Directed Question 2 – Categories

When USED has the data on the total student headcount and the aggregate counts for students with certain characteristics, they should make the calculations for students without those characteristics.

We would experience a significant burden if required to disaggregate by the following categories: homeless status, homeless served under McKinney-Vento status, economically disadvantaged status, and migrant status. The data collected under the above data elements do not include these status categories. We can disaggregate by disability status and LEP status.

It is impossible for this state this year and possibly next year to provide aggregate data on students without the characteristics because we don’t collect data on the entire student population. This state only collects aggregate data for populations with the characteristics. This state is in the process of creating a statewide student-level data repository, but it has not been developed to the point of doing federal reporting until 2008-09 at the earliest.

The burden to the SEA in this case involves the processing time to distinguish those with and those without and the additional time to handle the larger files in the event that this means additional records vs. additional columns within a single record. In the event that the “with and without” needs to be processed as a different row in combination with other aggregations then the burden is much more time consuming. For example, a row of students with disabilities and a row of students without disabilities is less burdensome that asking for these rows at all breakouts such as these counts with homeless, these counts with LEP, these counts with migrant, etc. This additional reporting requirement would be burdensome but not impossible.

Concern for how much of a burden and time it would take to design and collect aggregations for the “with and without characteristics.” If the state does not have an individual student data system, this is a particular burden.

EDEN/EDFacts should ONLY collect data elements that are required by statute. Useful, but not required, data elements should not be collected until states have already provided all of the required data elements, in all of the required files. In the majority of the files submitted to date, aggregating with vs. without a specific characteristic has not been a significant problem. However, there are several factors that could increase burden, such as the nature of the data, the relationship of the characteristic to the data, and whether the total population in question is known and fixed. For most assessment-related data, the characteristics are known for each assessed student and the total population is known and fixed, so there is no issue. This cannot be done with summer migrant data, however.

Given that ED admits these data are not required in law, we are dismayed that collecting the data would even be considered. The answer to this question depends on several factors and without knowing the specific data elements EDEN has in mind, it would be folly to try to estimate the burden. However, to the extent that the data are available (e.g., assessment results for students with and without disabilities), given the magnitude of these files, it would be a significant effort to derive and report students that are not in those subgroups. In addition, the following aspects of the data would have to be in place in order to ensure that the data are complete, accurate, and consistent: • The state would have to collect data for all students statewide, not just the subgroup. • The data would need to be collected at the same point in time. • The non-subgroup would have to be well defined.

The burden level is dependent upon the characteristic. For us, there is relatively little burden to aggreagate for both students with and without the following characteristics because these are captured in our student record collection: Disability status (IDEA), assessed for limited English proficiency, homeless status, economically disadvantaged status, and migrant status. A third-party collects information pertaining to McKinney-Vento status so those data are more burdensome for us to categorize.

Need to be clear about what assessments you are referring to: i.e., language proficiency assessments, content assessments. How do you count the monitored ELL students – where do they fit into the count? We cannot determine which students are served with McKinney-Vento funds compared to other funds for homeless services at the student level. The big picture question relates to what type of data are you using these aggregations for: i.e., assessments, graduation, headcounts, etc. Data not required by statute should not be required just because it may be useful. This puts undue burden on the states.

Directed Question 3 – Status Files

Question Text: The status files contain the non-table data groups. The non-table data groups included in the NCLB Start of School Year File (N/X101) are:

• District Totals, ID 460

• Improvement Status—LEA, ID 662

• Improvement Status—School, ID 34

• Integrated Technology Status, ID 524

• Persistently Dangerous Status, ID 36

• School Poverty Percentage, ID 31

• School Totals, ID 454

• Shared Time Status, ID 573

• Title I School Status, ID 22

• Magnet Status, ID 665

• Classroom Teachers (FTE), ID 644

The non-table groups included in the NCLB End of School Year File (N/X102) are:

• Economically Disadvantaged Students, ID 56

• Combined MEP Funds Status Table, ID 514

• GFSA Reporting Status, ID 603

• REAP Alternative Funding Indicator, ID 614

• Average Daily Attendance, ID 595

• Supplemental Services—Applied to Receive Services, ID 575

• Supplemental Services—Eligible to Receive Services, ID 578

• Supplemental Services—Received Services, ID 546

• Supplemental Services—Funds Spent, ID 651

• School Choice—Funds Spent, ID 652

• Truants, ID 664

• MEP Students Eligible Regular School Year, ID 110

Are these status files properly organized to ensure the timely submission of data and reduce burden? If not, how should the non-table data groups be organized?

Summary of Comments and ED Response:

Commenters indicated that both the NCLB Start of School Year and End of School Year Files were not properly organized and needed to be broken apart.

At a minimum, ED will break the Start of School Year file into two files: one with the four CCD data groups (Shared Time Status ID 573, Title I School Status ID 22, Magnet Status ID 655, and Classroom Teachers ID 664) and one with the remaining data groups. ED will also break the End of School Year file into two files: one with the Supplemental Education Services data groups and one with the remaining data groups.

Directed Question 3 – Status Files

Detailed Comments

In almost all cases DPI can comply with the early submission due dates. However in the past, DPI had difficulty finalizing the data on classroom teachers by the due date. In 2008, DPI will make staff files due by March 1 to report by end of March.

These status files are not properly organized to ensure the timely submission of data and reduce burden. They should be organized by content area first then timing. Currently these files are a hodgepodge of elements from different areas. It is easier and more efficient to have files organized by content than by submission dates. Increasing the number of files is less burdensome than having to create a single file that draws data from different sources. Further, the collections used to gather the data occur at different times so the file submission is being held up because one element in the file is not ready. Take out all the items that are not specific to Title 1 and put them in a file of similar content or create a new file for that element (i.e., take out persistently dangerous and integrated technology from N101).

In general, ED and EDEN should work together to align reporting timelines. For example, ED permits SEAs until June of the following school year to report ID 603, which seems to be an excessive amount of time.

The status files are organized in the same manner as they are exported.

There are items in file specification N101 that seem better suited in other file specifications.

With regards to N101, this file has continually been difficult to generate due to the variety of information requested. For example, this state does not complete our data collection on Instructional Personnel until Spring, which prevents us from submitting N101 by the end of the Early Submission Period. Therefore, it is suggested that the Classroom Teachers data element (ID 644) be moved from N101 to the StaffFTE file (N059). Furthermore, Title I School Status could be moved to the Title I Participation file(s) by adding “TGELGBNOPROG” and “SWELIGTGNOPROG” as valid values to the Title I Program Type Field. With regards to N102, our data collection on Supplemental Services is not complete by the close of the End Submission Period. We respectfully request this file be moved to the Close-out Submission Period.

No, the N/X101 and N/X102 files appear to be a collection of items organized for receipt efficiency, not for submission efficiency. Each of the files has data that come from different sources with different timing considerations. N/X101 for example - The Improvement Status data are known and fixed before the first day of school. The Title I school status and associated school poverty percentage are determined in a different application and, although in most cases the data are reasonably stable by the end of September, they can sometimes change for months thereafter, as LEAs are making adjustments to their applications. The teacher data, for example, are unrelated to the above and are collected in a different application. Similar barriers exist for the N/X102 files. For example, the supplemental services student counts are currently collected in a web application made available in the fall of the following school year. The school choice and supplemental services funds spent data and other funding data are collected in a financial application, one that can have updates extending well into the next fiscal year. The truancy data, attendance data, and economically disadvantaged student counts are collected in our standard system, where updates are not possible after July. From a submission viewpoint, it would be beneficial to states for these data elements to be split into smaller files containing related items. Currently, we rush to submit the data available at the time, only to re-submit the whole data set later, as needed, to correct the latest retrievable and/or changing data.

No. Classroom teachers should be collected with N059.

The data contained in N101 are collected by several offices across our department and at different times. Perhaps the best way to respond to this question is to provide you with the time frames when the data in N101 are available for reporting. If ED wants the data in this file early, our state would have to submit the file early, but with missing data. Below is a list of all elements required in N101 along with the estimated timeframe they become available. Data Group: When Its Available 22―Title 1 Status: Available August of the current calendar year 31 - Available but only for grades 2 - 11*:First iteration available in September of previous calendar year * 33 - Distinguished School Status: Mid- April of the current calendar year 34 - Improvement Status - *: First iteration available in September of previous calendar year * 36 - Persistently Dangerous Status: Available - August of the current calendar year 454 - School Totals: First iteration available in September of previous calendar year * 460 - District Totals: First iteration available in September of previous calendar year in * 524 - Integrated Technology Status: Not Collected 573 - Shared Time Status: Not Collected 604 - Operational Change: Not Collected 644 - Classroom Teachers (FTE) - Available: Late June of the current calendar year 662 - Improvement Status LEA - *: First iteration available in September of previous calendar year * 665 - Magnet Status – Available: Mid- to Late-May of the current calendar year.

101 - Teacher data – do not have until June so will not be reported until end cycle. The classroom teacher FTE data element should be included with other teacher files rather than in this 101 file. 101 - Shared time status – we have no way of tracking the post-secondary data for shared time students in our student-level information system.

102 – Migrant data should be included with other migrant data files and not in 102. 102- SES & choice data should be their own files.

There are collection timing issues with some non-table data groups for N102 files because the data groups will still be in an active collection or in a cleanup period. It is unclear how to get the non-table data groups organized, but it definitely seems scattered, with a variety of information requested in a single file.

Shared Time Status (573), Title I School Status (22), Classroom Teachers FTE (644), and any Magnet item: Can we take these out of N101 and put in the directory like Title I District Status and Charter School Status? I know you have a question on this in the register notice but states are already clearly telling you that some of the NCLB items on N101 will not be ready by March 31st, which is the deadline for this file, and it holds up important CCD items.

Directed Question 4 – Migrant

Question Text: The EDFacts data set did not completely align with the collection of data for the Migrant Education Program (MEP), Title I, Part C through the Consolidated State Performance Report (CSPR) and Migrant Child Count Form. The data groups collecting data on the MEP Program have been revised accordingly. The chart below displays the relationship among the data groups for students. Are the revised definitions and comments sufficient to describe the data that should be collected?

Summary of Comments and ED Response:

Commenters identified areas where the EDFacts data set did not completely align with the collection of data for the MEP, Title I Part C through the CSPR and Migrant Child Count Form.  Organized below are the areas that commenters identified with ED’s responses.

Commenters had concerns that the migrant data groups do not clearly define the population to be included. 

The definitions have been revised.  The phrase “eligible migrant students” is used for children who meet the statutory definition of migratory children.  Those children are counted for funding if they are ages 3 through 21 years old.  The phrase “participating migrant students” is used for children who are receiving services, including those receiving services under continuation of services provisions. 

In addition, the names of the data groups have been changed to reflect the population to be included.  MEP is used in the name only when the data group collects data on children receiving services.  Migrant is used in the name when the data group collects data on students who meet the statutory definition of migratory children.

Collection of migrant students in enrolled in public schools

Commenters questioned whether data group 110 Migrant Students Eligible Regular School Year included children ages 0 to 3.

This data group collects the number of students by school identified as migrant.  This data group corresponds to questions in the CSPR on the number of eligible migrant students in public schools and the number of eligible migrant students in school-wide programs.  The definition has been clarified.

Collection of data on alternative sites

Commenters had concerns about whether the data on participation included only students served at school sites or at all sites, including alternative sites.  State totals in data groups for participation should include students served at all sites.

Collection of data on GED

Commenters questioned the states’ ability to provide data group 628 Migrant Students Eligible GED because the state may not know that a student received the GED certificate in another state.  This data group corresponds to questions in the CSPR on the number of migrant students who have received their GED Certificate.  Students are counted in the state where the students received their GED Certificates.

Collection of LEP data

Commenters mentioned that LEP data collected by EDEN are broken into multiple categories.  For SY 2006-07, the data collected in EDEN for LEP is by whether the student had a LEP status or not.

FTE calculations

Commenters mentioned that the FTE calculations for EDEN were different than from those for the CSPR.  For SY 2006-07, the directions for FTE calculations are the same for EDEN and the CSPR.

Session Types

Commenters mentioned that data in EDEN were broken into session types different from the CSPR.  For SY 2006-07, the data collected in EDEN are broken into the same session types as used in the CSPR.

Children with disabilities

Commenters mentioned that the CSPR collected the subgroup of migrant children who were also children enrolled in special education, while EDEN collected the subgroup of children with disabilities (IDEA). For SY 2006-07, both CSPR and EDEN use the phrase “children with disabilities (IDEA)” to refer to this subgroup.  While previously the terminology was different, the definitions and meaning were the same.

Collection of data on services

Commenters mentioned that edit checks on the EDEN files were incorrect.  For SY 2006-07, the edit checks have been revised.

Continuation

Commenters mentioned that the comment for the category “continuation (only)” contained a double negative.  The comment has been reworded.

Directed Question 5 – School Operational Status

Question Text: The data group School Operational Status (ID 531) has the following permitted values: open, closed, new, added, changed agency, inactive, future school, reopened. Is a new permitted value needed for restructured under NCLB? Do SEAs create new schools when a school is restructured under NCLB? Are new state school identification numbers assigned when a school is restructured under NCLB? Do schools that are restructured under NCLB met the definition of open which is “no significant change in instructional levels and programs”?

Summary of Comments and ED Response:

Overall, there is substantial consensus that a new value was not needed for schools being restructured under NCLB. Of those that responded, the majority also agreed that restructured schools met the definition for an open status and that schools being restructured were not considered new by them or their SEAs. Those commenters who indicated that they created new schools when a school was restructured under NCLB did assign new state school identification numbers to each. Based on the comments provided, we will not be adding a permitted value for restructured under NCLB to School Operational Status.

Directed Question 5 – School Operational Status

Detailed Comments

The only operational status’ currently collected by the state are Open, Closed, and Planned. We have no plans to add an additional operational status or to create a new school when a school is restructured.

Restructured should be a separate item. It means the staff, maybe the school board, has been changed. It is possible for the CCD to work around it but you are talking about changing one of the fundamental status items of schools and LEAs. What if restructuring goes away? It might be better served as a separate item.

In this state, the question of restructured schools under NCLB is under discussion and will likely need legislation and regulations. Currently, we do not need a new element or code, because at this point we do not call them new schools. There is a good chance we would need it in the future, if ED requires us to report it.

No, a new permitted valued is not needed.

This state does not use Restructured as an Operational Status. If recording of such a status in EDEN is desired, it would have to be much more clearly defined, because restructuring can take many forms, from major to minor, both as a range of options spelled out by NCLB for schools in School Improvement Year 4 and above, and as a range of options that school districts otherwise use to describe various reconfiguration actions.

This state identifies schools by state school IDs and limits the introduction of new school IDs to schools that are substantially new in terms of student body and/or grade configurations. Simply changing the building and/or physical location of an existing school would not require a new state school ID if the student body was essentially the same. Most restructuring actions under NCLB would not require a new state school ID, since in most cases the conceptual student body would remain substantially the same. Keeping the same state school ID allows continuity of accountability information over time and verification that improvements are indeed being made.

Using a new state school ID for NCLB restructuring would give the school an artificially fresh start by moving the school out of School Improvement status. It should also be noted that districts and schools periodically undergo restructuring or reconfiguration for non-NCLB reasons, e.g., expanding or contracting student populations, for financial limitations, to meet consolidation goals, etc. We use the same state school ID rules for these changes that we use for NCLB restructuring changes. That is, we would introduce a new state school ID only if the school was substantially different in terms of conceptual student body.

In summary, an operational status of Restructured would be difficult to define and monitor; it could also be confusing, since many types of restructuring can occur for either NCLB or non-NCLB reasons.

Status of Open is sufficient. Additional categories are confusing and are not clearly defined.

It would not be wise from a longitudinal perspective to create a “new school” when a school is restructured under NCLB. If you were to make this change, those states that have statewide data systems would lose the history on the students who attend that school. There should be a choice that identifies this specific situation, which is a different situation from creating a new school. Further, restructuring can vary widely across as well as within states, so while some restructuring can resemble a new school, other changes as a result of restructuring may not come close to resembling a new school.

No, currently new state school identification numbers are not assigned when a school is restructured under NCLB.

NCLB school restructuring does not require creation of a new school. This state recommends that a school that undergoes NCLB restructuring should be reported as ‘Open’ because schools that undergo restructuring per NCLB requirements are reported in data group ID 604 (Operational Change), Code R, in EDEN file N101.

DPI creates new schools when a school is restructured under NCLB. New state school identification numbers are assigned. Schools that are restructured meet the definition of open.

• Is a new status needed for restructured school under NCLB ? No.

• Do SEAs create new schools when a school is restructured under NCLB? Yes.

• Are new state school identification numbers assigned when a school is restructured under NCLB? Yes.

• Do schools that are restructured under NCLB meet the definition of open which is “no significant change in instructional levels and programs?” No.

EDEN needs to create a new school status for those entities that close and reopen within the same LEA utilizing the same school name; however, the school has been assigned a new school number.

Directed Question 6 – GEPA

Question Text: As discussed in Attachment B-4, the General Education Provisions Act (GEPA), Section 424 mandates reporting on the distribution of federal education funds to school districts and other entities, such as libraries, colleges and universities, state agencies, individual schools, and private recipients. In the past, the data for the GEPA report have been collected through a separate collection. For the GEPA report on FYs 2006 and 2007, the data will be obtained for state-administered grants to LEAs through EDFacts. How will this change affect SEAs? What must ED do to make this transition successful? How should ED collect data on state-administered grants that do not go to SEAs or LEAs?

Summary of Comments and ED Response:

Several of the respondents were concerned about reporting GEPA data for entities other than LEAs. A few respondents suggested that the federal government already has the required data and, therefore, considered this report duplicative and burdensome. One respondent stated that so long as the data collected through EDFacts are the same as those previously reported for GEPA, the transition to EDFacts reporting should not be a problem. Another respondent indicated that reporting through EDFacts would make reporting easier. A few respondents made suggestions for making reporting easier for states. These suggestions included identifying for individual states the person who previously submitted GEPA data for each program and a report of the funding each state received for each federal program.

Based on the comments, EDFacts will proceed with caution with the plan to use data group 547 federal program funding allocation tables to collect data for the GEPA report. Data about directed funded programs will continue to be collected directly within the U.S. Department of Education. Data on funds allocated by SEAs to LEAs will be collected through EDFacts. For the small portion of state-administered funds that are administered by agencies other than SEAs or go to recipients other than school districts, data will be collected either through the on-line survey tool or through the current process.

EDFacts will discontinue data group ID470 Federal Programs Offered Status Table.

Directed Question 6 – GEPA

Detailed Comments

In attachment B-4 included in the EDFacts Paperwork Reducation Clearance Package, page seven states “ED uses data from its own system on grants to obtain the information on the federal education funds ED distributes directly to school districts and other entities.” Since USED already has the ability to capture these data from its own system, it would be unduly burdensome to ask SEAs to provide these data to USED. It is our recommendation that USED continue to collect data on state-administered grants that do not go to SEAs or LEAs directly from their existing system.

The Federal Programs file, N35, is extremely difficult to load and submit. The report we receive from our accounting office does not include our county-district-school codes. Our accounting office uses vendor identifier numbers to uniquely identify all vendors that receive payments (e.g., private agencies, libraries). Our county-district-school codes are maintained in a directory of education institutions, in which we do not currently include private agencies, libraries, etc. We will need to work with ED to resolve this issue.

In the meantime, we have the following question for ED: How do you anticipate states will uniquely identify entities that are not local educational agencies or schools and reconcile this with what we have been asked to report under the Common Core of Data?

Aside from the identifier issue, reporting the data through EDFacts has actually made the reporting easier for our department. One thing that the ED could do to make the transition easier is to make sure states know who, in the SEA, has submitted the GEPA report in the past. (It took us a while to track this person down in our department.) We assume that the letter from Westat confirming receipt of the data will be discontinued. For data that do not flow through our department, it would be impossible for us to report them. However, we can (and have) reported data that we allocate to libraries, colleges and universities, state agencies, individual schools and private recipients.

This sounds like an intended expansion of grant reporting plus an expansion of the EDEN/EDFacts directory. It is a bit difficult to understand without knowing the specific grants in question and the specific EDEN reporting requirements. The meaning of “state-administered” becomes important.

This change will negatively affect SEAs. The EDEN/EDFacts submission reports show that most states are not ready for ED to continue to expand the scope of EDEN/EDFacts. States are clearly unable to submit the required non-financial files, thus another expansion of EDEN/EDFacts reporting would continue to overwhelm states.

The transition cannot be successful until more states have the capacity to participate. The majority of states have been unable to submit most of the existing files.

What is the impact or burden on reporting GEPA through EDFacts? The SEAs cannot collect these data on behalf of all of the non-LEA entities in the state. This would be an additional burden without resources.

The GEPA (General Education Provisions Act) report is burdensome, particularly for states that do not have electronic grants information systems. It is our understanding based on Michigan and Ohio that the cost of building a system from scratch can go over $1 million. Last year’s GEPA 424 report took nearly 10,000 rows of data in order for Wisconsin Department of Public Instruction to comply. This is a time-consuming report at the SEA level, and it is our understanding that the data are available at the U.S. Department of Education.

If the data elements collected through GEPA are not different from categories collected through EDEN, it should not be a difficult transition. If there is a significant change, EDEN should make the reporting optional for the first 1 or 2 years.

13.DG 547 – Federal Programs Funding Allocation Table.

(a)The reporting period is shown as the federal fiscal year. Is this correct? State grant awards are effective on July 1st, the beginning of the state fiscal year and allocated in that manner.

(b)The comments state: “Include the distribution of all federal dollars from the FY 2006 federal appropriation.” This is not possible through EDEN since only data for school districts are reported.

Are EDEN data groups 470, 547, and 663 reported in N035 and N120 intended to replace the GEPA report? If so, these EDEN data contain only a small amount of the data that are included in the GEPA report, and the EDEN totals will not match to the total state allocation by CFDA number in the GEPA report. This past year the data for the GEPA report were submitted through EDEN (i.e., school districts) in December 2006 for the state fiscal period 05-06. It was later requested from GEPA to resubmit this report to Westat in its entirety but with an extended reporting period.

What are the future plans for reporting the entire GEPA data?

How will reporting just school districts data comply with the GEPA requirements?

Will this continue to be a duplicated report? Or, are we to conclude that the GEPA report will no longer be required?

Duplicative reporting of GEPA data creates an added burden to states in compiling and reporting two separate reports.

What must ED do to make this transition successful? Supply the SEA with an electronic report of the federal program codes and the funding.

DG 470 – Federal Program Offered Status Table.

(a)This definition has also changed from last year’s data collection, dropping the ability to use dollars allocated. Within a CFDA number, a district may have an allocation that would have both a program offered and an allocation that did not offer a program. With the permitted values of either yes or no, would using yes distort the intent of the data being collected?

(b)This information is not currently being collected and would certainly be a burden at this point to develop a tool to collect the data for ‘07-’08.

Directed Question 7 – Reading NCLB State Assessments

Question Text: EDFacts collects data on participation and results of NCLB state assessments. Data are collected on mathematics, reading, and science. The data on participation is collected in one file (N/X081) using permitted values to differentiate between the academic subjects. The data on the results of NCLB state assessments are collected in separate files. For mathematics and science, the participation file has one permitted value for each and both have one file to collect the results of state assessments. For reading, the participation file has three permitted values, and the results of state assessments are collected using three files. The three values and files are entitled reading, reading/language arts, and language arts. Can the reading participation and results of state assessments be collected using only one permitted value (reading) and one file (reading)?

Summary of Comments and ED Response:

Several of the commenters indicated that one permitted value and one file would be acceptable for submission. There was concern expressed, however, by those who use “language arts” about separating the reading assessment from the language arts assessment. There was also concern about the analyses of the data and that the outcome would not be indicative of the definition of the element.

EDFacts will proceed with using only one permitted value for the NCLB requirement of reading. As discussed in attachment B-4 under “meta data,” EDFacts will collect sufficient meta data to accurately present data on NCLB assessments, including for those states that have language arts assessments.

Directed Question 7 – Reading NCLB State Assessments

Detailed Comments

Currently, the state submits the Reading file (N077) modifying EDFacts to collect only the reading permitted value should not affect our ability to provide this data.

The state cannot report reading as a separate assessment. Our assessment is English Language Arts, and we cannot disaggregate reading.

Yes, we only use reading. We do not submit reading/language arts files or language arts files.

Assessments data question: Performance data are aggregated by grade span in our state for AYP as opposed to other state data reporting systems.

One permitted value would create extensive burden; however, the value would have different meaning in different states. Our state uses language arts. We could easily crosswalk the element but the analyses of data would not be indicative of the definition of the element.

For the state yes, because our only permitted value is reading.

Currently the U.S. Department of Education collects three values and files entitled reading, reading/language arts, and language arts for NCLB assessments. The state does not need reading/language arts or language arts. The state only uses reading for NCLB.

Can the reading participation and result of state assessments be collected using only one permitted values (reading) and one file (reading)? Yes.

Technical

This section provides a listing of the public comments ED received beyond policy-related, data availability responses, and responses to the seven directed questions. These are organized by topic area in the following pages and provide the original question as well as ED’s response. The comment number is a unique identifier assigned to the comments as they came in. The following table provides a complete list of the topic areas, the number of comments in that area and the page on which that topic area starts.

Summary of Public Comments by Topic Area
Topic Area	Number of Comments	Page Number
Common Core of Data	4	24
Charter Schools	1	25
Choice/Supplemental Educational Services	11	26
Directory	9	29
ESEA Title V	1	30
General	6	31
Homeless	11	33
Limited English Proficiency	14	36
Migrant	6	40
Neglected or Delinquent	3	41
NCLB	5	42
Office of Safe and Drug-Free Schools	8	43
Process Improvement	5	45
Special Education	6	47
Technology	2	49
Title I	9	50
Vocational Education	6	52

Topic: Common Core of Data

Comment Number	Comment	Response
32	Dropouts (page C-1, page 21) reporting period change from “School Year” to “Full Calendar Year Defined by the State.” This does not align with NCES dropout instructions.	Agree. Reporting period is in error. Changed to “12 month period (10/1 to 9/30) including summer following the regular school year.”
33	Diploma/Credential. Is the High School Equivalency Credential category needed?	Deleted High School Equivalency Credential as a permitted value.
41	Shared Time Status (573): Definition is not clear with reference to reporting to CCD.	Agree. Definition changed to align w/ NCES’s definition of a shared time school.
64	(326) Dropouts Tables. We suspect that category set B should be included in the parenthesis of the comment field.	Agree. We will correct the category set.

Topic: Charter Schools

Comment Number	Comment	Response
100	(653) Charter School LEA Status. We are concerned there may be situations where, for purposes of IDEA, a charter is considered an LEA, but under other federal funded programs, the charter is not considered an LEA. If so, an indicator is not sufficient. We acknowledge that ED responded to our comment on E Page 68. However, it didn’t answer our question above. We recommend that the definition be revised to “An indication of whether the state considers the charter school an LEA 1) for the purpose of distribution of IDEA funding or 2) for the purpose of distribution of other Federal funding. Another recommendation could be four categories: 1) LEA for purpose of IDEA only 2) LEA for IDEA and all other Federal programs 3) LEA for all other Federal programs, but not IDEA 4) not LEA for IDEA, or any other Federal programs.”	Agree. Definition and permitted values changed to reflect the variations of when charters can be considered separate LEAs.

Topic: Choice/Supplemental Educational Services

Comment Number	Comment	Response
1	Data group 679 - Choice/SES set aside. We recommend changing the definition to “the 20 percent reservation for supplemental educational services and choice-related transportation.” Data Group 680 - SES Funds Available. We recommend changing the definition to “the maximum per child expenditure for supplemental educational services.”	Agree.
85	(574) School Choice - Applied for Transfer. This is not a data element we think would be of value, especially given the cost to compile, store and maintain. What purpose does USDE see in gathering these data? If it is unmet demand, we can understand that, but the funds used to gather these data could be spent to provide services. In addition, this would constitute a burden on LEAs as many of them do not have automated systems to compile this information.	The Department is requesting this information to understand participation patterns for school choice. Data on eligibility and participation in school choice only tell part of the story. The missing piece is who actually applied for choice. School choice is a key provision of NCLB and as such the Department expects LEAs to maintain adequate records and data to properly administer and manage school choice. Those records and data would include those who applied for school choice.
86	(575) Supplemental Services - Applied to Receive Services. Same as comment on previous data element 574 (see comment number 85).	The Department is requesting this information to understand participation patterns for supplemental education services. Data on eligibility and participation in supplemental education services only tell part of the story. The missing piece is who actually applied for supplemental education services. Supplemental education services are a key provision of NCLB and as such the Department expects LEAs to maintain adequate records and data to properly administer and manage supplemental education services. Those records and data would include those who applied for supplemental education services.
87	(578) Supplemental Services – Eligible to Receive Services. We believe this data element is the same as the Free and Reduced-Price Lunch count and as such, question why we are being asked to report duplicate data.	The data may be similar but they are not necessarily the same. The free and reduced-price lunch is a count of those students who have been approved to participate in the free and reduced-price lunch program under the National School Lunch Act. Students are eligible to receive supplemental education services if they come from a low-income family. While eligibility for free and reduced-price lunch program can be used as the criterion, other criteria can also be used. In addition, the free and reduced-price lunch data are a count as of October 1 whereas the eligibility for receiving SES is at any time during the year. In its submission plan, an SEA may propose providing the free and reduced-price lunch data to meet the information need of the eligible to receive supplemental education services.
181	ID 546, Supplemental Services, - Received Services: There are hundreds of students who sign up but don’t show up for services or attend partially. These “no shows” muddle the numbers and put the districts in a bad light when they are compared to the students who request services. How can this be addressed?	The Department asks states and districts to determine an appropriate and reasonable minimum number of hours of service a student must attend to be considered a “recipient of SES.” If a student signs up for SES but does not attend any sessions, then the student should not be counted as receiving services. However, the determination of whether to count a student who attends partially or only intermittently is a state decision. Information on the minimum number of hours of service will be requested as metadata.
198	DG 679 – Choice/SES Set Aside. Will this datum be reported as a total for both SES and School Choice or separated?	A total for both the Choice and SES set-aside should be reported. This amount is equal to 20 percent of a district’s Title I, Part A allocation.
285	DG 579 – School Choice Offered. Proposed for Elimination. A new data element has been created to gather this information. The Department (the SEA) plans to collect the data just in case the proposal changes. We would prefer not to collect this information since all eligible students are offered the opportunity to transfer.	The Department agrees to eliminate this data group.
286	DG 612 – Supplemental Services Offered. Proposed Elimination. A new data element has been created to gather this information. The Department (the SEA) plans to collect the data just in case the proposal changes. We would prefer not to collect this information since all eligible students are offered the opportunity to participate in SES.	The Department agrees to eliminate this data group.
287	DG 543 – School Choice Transfer Received. Please provide guidance on how many prior years need to be considered for reporting. For example, do we limit reporting any student that a school received under the provisions of School Choice option to the current year, current year and prior year, all years, etc.?	States and districts should report all students that a school receives who: (1) transferred to that school for the first time this school year under the provisions of Public School Choice (Section 1116), or (2) previously transferred under Section 1116 and continue to exercise their choice under that provision of the law.
288	DG 542 – School Choice Transfer Used Status. Please provide guidance on how many prior years need to be considered for reporting. For example, do we limit reporting any student who transferred from the school under the provisions for public school choice in the current year, current year and prior year, all years, etc.?	States and districts should report as transfers all students who are currently attending a transfer school under the provisions of Public School Choice (Section 1116), including those students who transferred for the first time this school year and those students who have previously transferred under the provisions of Section 1116 and continue to exercise their choice.
289	DG 545 – Supplemental Services Provided Status. Define ‘School Year’, e.g., does ‘school year’ mean the ‘180 days excluding summer’ or does it mean ‘180 days including summer’. This state does serve students during the summer session and thus prefers to include these students served during the summer session in EDEN reporting.	“School Year” is defined according to the state’s definition. If a state’s definition of “school year” includes summer months, the state can count the School Year plus the following summer, if a summer SES session is offered.

Topic: Directory

Comment Number	Comment	Response
35	FIPS County Code and Name: They are both noted as being derived. Aren’t you actually collecting the code, you can’t derive both?	Agree. Code is collected. Name is derived.
37	Supervisory Union Numbers: These are not assigned by NCES; these are state-assigned numbers. Please change the definition.	Agree.
38	LEAID and SCHID: Please take out “and the US Census Bureau” in the definition.	Agree.
39	Need to change “agency” to “school” in all of the definitions on B-1, page 25.	Agree
40	Locale (#17). Need to change to the new Urban-Centric Locale Codes.	Agree
43	Directory File: There is currently no school year header. Is one needed.	The school year header will be added as part of the revision of the directory approach to school year-based instead of effective date-based. The school year doesn’t need to be a data group.
57	(12) FIPS County Code. We noticed that the comment “This will not be collected from the SEA” has been removed. This concerns us given we do not maintain this…is this not maintained at the federal level?	We have revised the package to reflect working with SEAs so that the FIPS county codes are maintained in EDFacts and SEAs update only when it changes.
171	FIPS County Code (ID 12): Schools are attached to the district’s headquarters county code rather than school geographic code.	The assigning of schools to the district’s headquarters county code is consistent with previous practice by the Common Core of Data.
178	School Type (ID 21): Now includes “reportable programs.” SEA does not have students who are not already assigned to another school type. Therefore DPI does not have students who are not reported within schools.	The permitted value “reportable programs” is available for states that need it to report data. ED is not expecting that every state will use “reportable programs.”

Topic: ESEA Title V

Comment Number	Comment	Response
206	Program - Title V Strategic Priority - The definition includes the following: “Funds beyond Federal funds should be included.” This state has concerns with reporting funds beyond federal funds. We do not collect this. It would cause undue burden for the state to collect and report these data. We may not be able to report this at all. If we were able to get the data from districts, there would have to be application development at the state and possibly the local level.	This category has been removed.

Topic: General

Comment Number	Comment	Response
2	Data group 306 - graduate/completers table. Need to add a subtotal by diploma/credential for data quality because the primary category set A includes collecting by race/ethnicity	Agree.
8	Categories not being used are listed. It is unclear which might be used in the future. An accurate list of categories is needed to make decisions about the design of the state’s reporting system. Examples include the pages that define “N or D Services Received,” and “N or D Status,” both in Attachment B-5, on pages 97 and 98, respectively. Both have definitions, but at the bottom of the definition, the space is left blank where the EDEN Data Group(s) that are broken down by that Disaggregation Category are supposed to be listed. Is it safe to conclude that these disaggregation categories have effectively been “dropped,” at least for the next few years? I’m not just asking this as a theoretical question. We are trying to decide if we should keep our existing N or D facility reporting mechanism, which meets all current EDEN N or D reporting requirements, and all of the specialized N or D facilities know how to report into it. But if “N or D” status is going to be added as a break down category for lots of other student data only collected by our Student Repository, we would have to look at how the Repository could collect the N or D data, which may not be possible anyway because of FERPA (privacy laws) concerns. So it would be very useful to know for sure that “N or D Status” is not going to be used as a Disaggregation Category for at least a few more years.	It is safe to conclude that categories not included in this package are not intended to be collected in future years. However, legislation or regulation could change which would result in reinstituting these categories.
102	Although the documentation has improved in terms of being able to see where changes are being proposed, we noticed a few places where things appeared to have changed, but were not flagged as such. We also noticed that some data group and category set names seemed to be editorial, but because the documentation did not explicitly reflect the change as such, we have concerns we may have missed what may be significant changes.	We made a number of editorial changes. We did not flag these changes because we did not want to distract from the substantive changes by including editorial changes.
118	Also, if ED wants an unduplicated count, ED will need to provide business rules that help us understand how to count a student who falls into more than one category.	Previous versions of the EDFacts data set occasionally included the word “unduplicated” in the definition in error. We have reviewed the use of the word throughout the data set. The word should only be used now when each category set can be submitted as unduplicated data.
136	Does the data collection referenced in the Register refer to data collected from LEAs during the 2007-08 school year that would be reportable in 2008-09 or data collected in 2006-07 to be reported in 2007-08?	The data described refer to data collected about what occurred during school year 2007-08. The data will be reported by the SEA to ED as they becomes available in the SEA. Starting in January 2008 with directory and membership data and continuing to the following January with graduate and dropout data.
263	Comments relating to Data Group “Unduplicated” language. Many data groups utilize language that states, “The unduplicated number of.” Please provide greater clarification regarding which reporting levels (SEA, LEA, SCH) must truly contain “unduplicated” counts. The blanket use of this language leads to confusion from program areas who feel it may be acceptable to report students multiple times at the SCH or LEA level, but interpret the “unduplicated” language to mean that only the SEA-level reporting has to be unduplicated. Data Groups 74 and 123 are examples, however, there are other data groups also using this language.	Agreed, when the word “unduplicated” is used in the definition, we will include in the guidance section of the file specification an explanation of how to report the data at each level.

Topic: Homeless

Comment Number	Comment	Response
15	We have one concern regarding the definition of Homeless Served that appears in the EDFacts Data Set for EDEN for 2007‑08: The definition for Homeless Served (McKinney-Vento) Tables states: “The unduplicated number of homeless children/youth enrolled in public schools who receive services under the McKinney-Vento Program.” There is a concern that the language in this definition may be unclear. For example, in an LEA without a MV subgrant, a homeless liaison might provide special services to homeless students using a combination of local funds and Title I set-aside funds. It is possible that this could be construed as receiving services under the McKinney-Vento Program―the homeless liaison is mandated by the MV act as is the identification of the students as homeless. For clarity, we’d like to suggest that the definition to refer explicitly to homeless students who receive services from a McKinney-Vento subgrant program. Therefore, the definition might read something like: “The unduplicated number of homeless children/youth enrolled in public schools who receive services under a McKinney-Vento subgrant program.” This should eliminate any confusion that might occur regarding the term “McKinney-Vento program.” We realize this terminology has been around for years, but as the data collection becomes more sophisticated, with many more people involved who may not understand the nuances of MV, the more precise the terminology, the more accurate the data.	Agree, definition changed.
17	The McKinney-Vento section in CSPR Part 1 - Section 1.9 asks for data by age/grade, but then the rows are all labeled by grade. This state has moved these MDE reports to be based on grade, but actually age is easier to track because many homeless students are not in the grade level that corresponds to their age. If we chose to go by age, how would we do that when the rows are labeled by grade?	The reporting for homeless students is by age for those students who are not yet in school. Once students enter school the reporting is by grade. For purposes of labeling the permitted values or code set, we refer to it as an “age/grade” category. It is not meant to imply that either age or grades can be used to submit the data.
56	(548) Homeless Status (Only). Wording needs to include: “implement the Act” as well as designate a local liaison.	Agree.
89	(585) Student Performance in Science tables. Our current statewide assessment does not include data that would allow us to identify which students are homeless – nor do we collect “Science” on the collection we administer to LEAs that receive McKinney-Vento grants.	The data collected are on students served by McKinney-Vento subgrants, not on all homeless students. Starting with SY 2007-08, science assessments are required under NCLB. Therefore, data on those assessments will be collected in the same way they are currently collected for reading and mathematics.
90	(590) Students Tested in Science Tables. Our current statewide assessment does not include data that would allow us to identify which students are homeless – nor do we collect “Science” on the collection we administer to LEAs that receive McKinney-Vento grants.	The data collected are on students served by McKinney-Vento subgrants, not on all homeless students. Starting with SY 2007-08, science assessments are required under NCLB. Therefore, data on those assessments will be collected in the same way they are currently collected for reading and mathematics.
103	In the 07-08 data package, the appropriate category is defined as: An indication of whether homeless children and youth were served by McKinney-Vento program in the state. The state is confused by the 2007-08 definition. In this state, they have 10 districts that received McKinney-Vento grants. All of their districts have McKinney-Vento Required programs, but do not receive funding. For the files in question, would this state report the children in McKinney-Vento Required programs, or only the ones served by a McKinney-Vento Grant? In 2005-06 it seems fairly clear that data from only those 10 districts would be required, but the 07-08 definition could be interpreted several ways. Any clarification that you could provide on this would be appreciated.	Agree, definition changed.
144	Data Group Comments Homeless - 516 & 655 - Changes are fine.	No response necessary.
148	Data Category Set Comments Homeless Primary Nighttime Residence Why is “An indication of whether homeless children and youth were served by McKinney-Vento program in state” in the definition? The data group 655 seems to apply to all homeless students enrolled, not just those served by McKinney-Vento grants.	Agree.
184	Homeless Served Tables - 560 - This data group is marked to use category set Age/Grade(K-12). Shouldn’t it use Age/Grade(3-5/K-12)?	Yes. The age category has been changed.
192	Homeless Students - This category seems to count the same information as category Homeless Status Only. Why two categories?	Agree it is in error. Homeless Students DC dropped.
210	Student - Homeless Primary Night Time Residence - Need clarification of definition. It appears that there may be two separate definitions. (1 – The primary nighttime residence of the student at the time the student is identified as homeless. 2 – An indication of whether homeless children and youth were served by McKinney-Vento program in the state.) Do we report all homeless students or only those served with McKinney-Vento funds?	Definition was in error. Removed reference to McKinney-Vento since reporting of nighttime residence is for all students.

Topic: Limited English Proficiency

Comment Number	Comment	Response
51	Are there plans to align the EDEN data collection with the Office of English Language Arts (OELA) guidance on Title III accountability? EDEN is asking for AMAO data by state, LEA and school level. These levels of reporting are not consistent with the guidance we have received from the ED’s OELA office. In the past, OELA allowed states to report AMAO’s at the LEA level. However, in March 2006, OELA modified the reporting requirements (see attached OELA letter on Title III requirements). As required by OELA, this state will only determine if Title III subgrantees (consortia as a whole) and direct-funded LEAs (those receiving grants of more than $10,000) have met the AMAOs. In response to OELA’s letter, we sent a memo to our LEAs that reflected the reporting change letting the LEAs know that the SEA will no longer determine if each LEA has met the AMAOs as we did in the past. This state will be aggregating over 300 LEAs into 60 consortia-level reports as is required. Basically, EDEN will have no interpretable data for the 357 LEAs because the consortia aggregations don’t exist for anything but Title III and are not stable over time. As the numbers of LEP students in LEAs change and new charter schools or other LEAs join consortia, the membership changes. Because of the changing make-up, we would prefer that ED require states only report at the LEA-level and not by consortia. Doing so will ensure that valuable information about LEAs will not be lost in the averages of consortia. We are concerned that ED is requesting that states maintain two accountability systems for Title III – one at the LEA level for EDEN and one at the Title III subgrantees level for OELA. The accountability system required by OELA should be reflected in the federal CSPR and biennial reporting, and this will not be the case if data are reported at the LEA level instead of consortia aggregations as required. Regarding school-level data, it is our understanding that this level of data is required only from those states where the state’s accountability system includes school-level accountability. This state’s system does not include school-level accountability. We cannot provide unduplicated counts. As we have stated in the past, all ELs should be getting English language development and access to the core curriculum through strategies such as SDAIE, SEI, etc.	When districts organize into a consortia for the purposes of Title III (or any federal program), one of those LEAs is identified as the fiscal lead for the purpose of distributing funding. When reporting data for a consortia, please submit the information in a record identified for the LEA that serves as a consortia lead. Any LEAs which are part of that consortia should have no records for the items related to that consortia’s activities. If reporting consortia results within a lead LEA record triggers a warning or violates an established ESS business rule, please explain that the district serves as a consortia lead for X districts under Title III when submitting your explanations in the system.
59	(116) Unduplicated number of limited English proficient (LEP) students enrolled in an elementary or secondary school. We are pleased to see that ED is dropping the Immigrant Status category as we cannot provide disaggregate these data by Immigrant Status.	No response.
68	(494) LEP Programs Terminated Table. This state has no plans to terminate any LEP programs.	Under Section 3123(b)(7) of ESEA, SEAs are to terminate programs and activities that are not able to reach program goals. Each year, SEAs are to report to the Department the number of programs terminated because the program was not able to reach program goals.
145	Immigrant tables - 519 - This data set requests an immigrant student count as of October 1. We have traditionally collected this information at the end of the school year. It also asks for program participation under the immigrant grants in Title III. These data would be most appropriate to collect after the school year is over.	Agree. Changed the reporting period to school year.
146	LEP Tables - 116 - This data group counts LEP students as of October 1. We currently count this at end of school year.	For Title III program monitoring purposes, both an October 1 count and a cumulative school year count are needed. Both counts are needed because of the mobility of this population.
158	Time in Program for LEP students - This data category is not linked to any data groups. We do not currently collect this information.	Deleted category.
168	Data Group 569 [AMAO (Annual Measurable Achievement Objectives)] Making Progress Status for LEP Students) and C1 Page 13 Data Group 518 (AMAO Proficiency Attainment Status for LEP Students) requests that the data be collected by LEA level. In this state, the data are collected by individual student level but “for accountability purposes AMAOs will be determined at the district/consortia level.” Small districts often join together in consortia so they have a large enough cohort for funding. This complicates reporting at the LEA level.	When districts organize into a consortia for the purposes of Title III (or any federal program), one of those LEAs is identified as the fiscal lead for the purpose of distributing funding. When reporting data for a consortia please submit the information in a record identified for the LEA that serves as a consortia lead. Any LEAs which are part of that consortia should have no records for the items related to that consortia’s activities. If reporting consortia results within a lead LEA record triggers a warning or violates an established ESS business rule, please explain that the district serves as a consortia lead for X districts under Title III when submitting your explanations in the system.
186	LEP Enrolled Tables - 678 - This is a new data group that counts LEP students at the end of this school year. This is preferable. Would prefer to use this data group and not data group 116.	For Title III program monitoring purposes, both an October 1 count and a cumulative school year count are needed. Both counts are needed because of the mobility of this population.
187	LEP Program Instruction - 622 - Changes fine.	No response.
188	LEP Recent Arrivals - 677 - We currently only collect these data in our state for students who are excluded from the testing for AYP, not for all students in all grades.	The reporting needs of Title III, as described in Section 200.6(b)(4)(i)(iv) require that this information be collected in all grades, not just those grades used to compute AYP. No change.
189	LEP Placement Table - 621 - Why is this data group being deleted? Are the data on the number of students at each proficiency level on the ELP assessment not going to be collected? The data category “English Proficiency Level” is still on the list for 2007-08.	Data Group 621 (LEP Placement Tables) is being proposed for removal because the information, collected by English Proficiency Level, has been integrated into the DG 678 cumulative school year count. The addition of that category within DG 678 was accidentally left out of the package posted for public comment. It has been added back in as Category Set C within Data Group 678.
212	DG 677 – LEP Recent Arrivals Table. Currently this state does not collect data on LEP students who have attended schools in the U.S. other than this state for less than 12 months. Prima facie, collecting data on LEP students who have attended schools in any state in the U.S. other than this state for less than 12 months would require inter-state transfer of student records which currently is unavailable. This state does, however, collect data on the date that LEP students entered the U.S. Please indicate whether it would suffice for the state to report data on (1) LEP recent arrivals to the state only; or (2) the date that LEP students entered the U.S.	ED recognizes the limitations of state data systems not including data on whether recently arrived students were previously enrolled in other states. Data Group 677 (LEP Recent Arrivals Table) seeks to collect information on the number of recently arrived students who have been enrolled in schools within the reporting state for less than 12 months.
213	DC – One Data Point. First, this state only has the means to identify students taking an assessment for the first time in this state. Second, please provide further clarification regarding the differences and relations between the set of students captured by DGs 674 and 675, e.g., is one DG a subset of the other, etc.?	Both data groups seek to collect information on the English language testing results of LEP students. Yes, DG 675, which collects data on the results of LEP students who are served through Title III, is a subset of DG 674, which collects data on all students who are assessed for English language proficiency. The relationship of these data groups will be further explained and supported in the EDFacts Workbook (Section 4.4) for the 2007-08 school year.
309	DG 678 (LEP Enrolled Tables) uses the DC English Proficiency Level. The allowable answers to the English Proficiency Level question in Specification 085 are 6 levels or Missing or Not Collect. How do I answer this question if a test is somehow invalid or not able to be scored. If I use Missing, you will not roll the data up and it is not really missing. I cannot correctly say it was Not Collected because we did collect the scores. I suggest we adopt a new value to allow the reporting of a test that cannot be scored as “L0” (L zero). Your answer will affect 15 states that abide by the WIDA consortia decision. Thank you.	Agreed. Changed permitted values.

Topic: Migrant

Comment Number	Comment	Response
11	The comments section of the definition of the category “Continuation (Only)” reads “This doesn’t not include children served under Section 1304(e)(1), which is children whose eligibility expired during the school term.” This appears to be a typographical error, leaving the meaning ambiguous. Should I just assume the word “not” should be omitted?	The proposed revised wording is “Children served under Section 1304(e)(1), that is children served whose eligibility expired during the school term, are NOT included.” The category set in both data groups that uses this category (category set C) will be the equalivent of section 2.3.3.3.3 “Continuation” in the CSPR.
104	Discrepancy in the collection and reporting of Grade Level: EDEN: Prekindergarten, [MISSING, NOT COLLECT]; MVReport: Age 3-5 in the reporting of migrant children.	Agree.
120	Combined MEP funds status - DG # 514 - Our state has not collected information about whether all schools receive migrant funds. This would be an extra data collection burden. Suggest restricting this data collection only to Title I Schoolwide schools. A Yes indicates the school does combine MEP funds into the schoolwide program. A No indicates the school does not combine MEP funds. An N/A indicates the school does not receive MEP funds.	Agree, NA has been changed to indicate not a Title I SWP school or doesn’t have migrant funds.
167	Under Migrant Service Type Definitions, the definition of “Any Referred Service (or Coordination)” states “Support Services during the reporting period from other non-MEP funded programs to the coordination and identification of those services by MEP personnel.” DPI has a question about referred services. Is it necessary to document that children received the services such as pre-college or high school equivalency service in order to be counted? Is it only reported when there is documentation that the service was received? This makes a difference in the appearance of the districts’ referrals.	Yes. The count of migrant students receiving referred service includes only those migrant students who were referred and received an educational or educationally related service funded by another non-MEP program/organization that the migrant students would have not otherwise received without efforts supported by MEP funds. Thus, the state must confirm and have appropriate documentation that the migrant student received the service to which he/she was referred.
169	Combined MEP (Migrant Education Program) Funds Status (ID 514) DPI would like clarification on what is considered “combined funds.” Is it exercising the autonomy in the law and using one fiscal pool of state, local, and federal funds or is it combined services?	The term refers to when a Title I school-wide program in which migrant education program (MEP) funds are consolidated properly and used to improve the entire educational program of the school as authorized under 34 CFR Section 200.29. The term has been changed to “consolidate” to be more precise.
179	Student - NCLB School Improvement Options - In the definition it says “Options provided to migrant students under NCLB….” Why only migrant students?	It is an old data category that should have been deleted.

Topic: Neglected or Delinquent

Comment Number	Comment	Response
19	Delete the permitted value “multiple purpose facilities” from data category “N or D Program (Subpart 1)” and “N or D Program (Subpart 2)”.	Agree.
53	We continue to have concerns about the N or D Outcome Data groups (DGs 628 and 629). Specifically, the ED is looking to collect information on pre- and post-test results, with a category set (named Progress Level) that contains the following categories: - The students tested below grade level upon entry to the program or facility - The students showed a negative grade level change from the pre- to posttest - The students showed no change from the pre- to posttest - The students showed improvement of up to 1/2 grade level from the pre- to posttest exams. - The students showed improvement of up to one full grade level from the pre- to posttest. - The students showed improvement of more than one full grade level from the pre- to posttest. Given that local assessments are not standardized, the comparison of local assessment results provides very little information. In addition, the categories provided are not all inclusive. For example, how should a student who has progressed less than 1/2 grade or a student who has progressed 3/4 grade be categorized? The state Department of Education requests that these data groups and categories be vetted with those at ED who have expertise in analyzing, aggregating, and disaggregating data for accountability purposes.	We understand the difficulties and significant statistical and inferential problems with the measure as currently drafted. However, this measure is the least common denominator. The measure was developed with extensive feedback from states and experts in the field. We hope to move away from the measure, but cannot yet due to the diverse testing and understanding of test scores that exist in the field. We are reviewing formalizing another option that would allow states to provide level changes aligned with the current methods used in the National Reporting System for Adult Education. This system uses test cut-off scores for our most commonly used tests (e.g., TABE) and would address the concerns raised about this measure. We are strongly encouraging states to move to a uniform testing model throughout their Part D programs to improve the ability to assess student academic progress more accurately.
195	Category Name N or D Program (Subpart 2) DPI suggests adding “Delinquent Programs” to permitted values. Currently DPI has been advised to put them under Juvenile Detention.	Thank you for taking the time to comment. Based on feedback received from the field over the past few years, the Department of Education has elected to provide subcategories for the delinquent programs (juvenile corrections and juvenile detention) rather than a general delinquent category. Definitions regarding categorization of N or D programs under Subpart 2 are provided in Attachment B-1.

Topic: NCLB

Comment Number	Comment	Response
10	For the data group AYP Status (ID32), add another permitted value/code for yes by growth model. For 06-07, 10 to 12 states will be allowed to use growth models to determine AYP status.	Agree.
76	(552) Proficiency Target Status Reading/Language Arts Tables. Given our state has a Reading and Language Art Assessment, and there does not appear to be a separate data group for RLA assessment Participation and Target Status, does ED want us to use these data groups to report on RLA?	Yes. The Proficiency Target Status Reading/Language Arts Tables are used for whatever assessment a state uses to meet the reading assessment requirement in NCLB.
77	(553) Participation Status Reading/Language Arts Tables. Given our state has a Reading and Language Art Assessment, and there does not appear to be a separate data group for RLA assessment Participation and Target Status, does ED want us to use these data groups to report on RLA?	Yes. The Participation Status Reading/Language Arts Tables are used for whatever assessment a state uses to meet the reading assessment requirement in NCLB.
88	(584) Student Performance in Reading (Language Arts). We can only provide these data (not sure this is right) for students in McKinney-Vento subgrantees.	For the Student Tested and Student Performance data groups, category set G is homeless served status, which is homeless students served by McKinney-Vento subgrantees.
175	Education Unit - 101 -Improvement Status-School – Need clarification. What is the difference between the following two permitted values: Improvement Improvement Year 1	The permitted value “improvement” is being deleted. It was used in SY 2005-06 for SEAs who had difficulty submitting data by improvement year.

Topic: Office of Safe and Drug-Free Schools

Comment Number	Comment	Response
92	(601) Firearm Incidents Table. What is the benefit of adding LEA reporting levels?	LEA reporting allows the Department to analyze firearms incident data with other data.
101	(664) Truants. Section 4112 (c)(3): Requirements for data under NCLB require that through UMIRS, information be collected and reported to the public in four categories. Truancy rates at the school building level is one of the four categories. EDEN proposes to discontinue school-level reporting – has the UMIRS requirement been modified? If not, we question whether school-level reporting should be removed.	The UMIRS requirement has not been modified. The school-level reporting was removed during a review of the data set to remove all school-level reporting that was not related to a Department priority.
119	(601) Firearm Incidents Table. Does the number of incidents include or exclude adults that brought a weapon to school or other events?	The number includes only incidents that involve students (excludes adults that bring a weapon to school). Definition revised to clarify.
170	Discipline Incidents Table (ID 523) The definition asks for “The cumulative number of times that students were removed from their regular education program for at least an entire school day.” Should this number include in-school suspensions? Does regular education refer to a student’s everyday education or does it refer to regular versus special education? Does it refer to all students or only those that are not in special education?	This number includes in-school suspensions if those suspensions result in students being removed from the students’ regular education program. The phrase “regular education program” in the definition is the program of instruction established for a student regardless of whether that program is designed to meet special needs of the students such as a disability or the lack of English proficiency. The term “student” in the definition includes all students.
182	Student - 102 - Truants 664 - Need clarification of term “threshold” used in the definition: “The unduplicated number of truants as defined by state, using threshold definition.”	The term “threshold” means the number of unexcused absences that the state determines make a student a truant. In the Uniform Data Set, the number is 16 per year.
243	DG 673 Discipline Table - Student Section - The unduplicated number of students removed from their regular education program for at least an entire school day. - Not Available (for 07-08) - This data is only available for special education students. This state only collects expulsion removals on general education students, not all removals (e.g., suspensions)	The Uniform Management Information and Reporting System (UMIRS) requires states to report suspension and expulsion data related to drug use and violence at the school level. For purposes of federal reporting, based on numerous discussions with the states, the definition was purposefully written to not include the terms expulsions and suspensions and instead allow states to crosswalk their own terms to the definition. To report on the Safe and Drug Free School Act, the Department needs the number of all students who were removed from their regular education program and the reasons for those removals.
270	For file N030 Students Disciplined, is the universe of records limited to those disciplinary actions taken in response to one of the enumerated discipline reasons?	Yes, the data that are provided are limited to disciplinary actions in response to one of the enumerated discipline reasons. The permitted value “other” has been changed to “other removals related to drug use and violence.”
271	This state has over 60,000 students with disabilities who are not assigned a grade. Should these be reported as “missing”? We recommend the addition of a category, “non-graded;” to report these students as “missing” would be misleading.	Add “ungraded” as a permitted value to N/X030.

Topic: Process Improvement

Comment Number	Comment	Response
29	We have been very appreciative of the opportunity to review reports generated from the EDFacts system prior to their release. This has proven to be a very beneficial exercise in understanding the many ways in which EDFacts data can be used to fullfill data requests. We do however request that to the extent possible, USED provide EDFacts coordinators with a schedule of proposed reporting efforts that may require our attention. This will assist us in allocating the necessary resources in order to provide a thorough quality review of reports generated from EDFacts data.	We appreciate the feedback that SEAs provide on reports generated from EDFacts and will work to improve the notification we provide.
218	Is this collection necessary to the proper functions of the Department; - while much of the information is being collected for compliance and monitoring purposes, it would be nice to have the ED Dept be the conduit for educational reform and assistance. Looking at what works and what doesn’t work and identifying “best practice” SEAs, LEAs and even Schools would help improve education more than anything else. This will also help those struggling to meet AYP with a resource for assistance. And you may want to go as far as saying that Schools and Districts in need of improvement should be required to “buddy-up” with a “best practices” School or Districts. This would change the dynamic of how Schools or Districts work to improve instruction within their organization.	We agree with the importance of sharing best practices and have provided this comment to the program offices within the Department.
231	This state requests that file specs be issued by EDEN in a timely manner.	We agree that EDFacts needs to improve the timeliness of issuing file specifications and will be concentrating on that this year.
277	File specifications are not always consistent when using “yes” or “no” answers. For example, in some cases “Y” means yes and “N” means no. However in Specification number 029, the charter status field, ID 27 requires “YES” for yes and “NO” for no. DPI suggests that EDEN be consistent in the specifications.	We agree that EDFacts has not been consistent in permitted codes. EDFacts has been developing standards for data and will be transitioning all files to those standards.
280	How might the Department enhance the quality, utility, and clarity of the information to be collected? Comment: •Detailed guidance with multiple scenario-based examples •Detailed information including report name and timeframe if similar or identical data are collected by USDOE from states on a different platform in order for states to communicate internally •Table definitions and definition under guidance should match •(E.g., N063- Teacher Quality in Elementary Schools mentions the word ‘CORE’ on Guidance but not in table definition) •E.g., In order to understand the LEP reporting requirements, table definitions, guidance and workbook need to be referenced because the complete requirements are not on a single location •Reporting guidance to when and where to reference the EDEN workbook	We have been working to improve the guidance for submitting data. We appreciate the specific ideas on how to improve the guidance and will be working to implement as many as possible.

Topic: Special Education

Comment Number	Comment	Response
54	Educational Services Table. Is there any further definition/guidance for this proposed table?	The file specification will contain additional guidance. This data group will be eventually used as the EDEN only option to section E of Table 5 of the IDEA reports. The only additional guidance that form currently includes is a reminder that children with disabilities must be provided educational services for any removal of more than 10 days.
67	(486) Special Education Teachers table. The Notes section refers to “Incidence level”. 1. What are permitted values for this category set? 2. Is this term referring to specifically “Teachers of low incidence” as a permitted value? (Note: the EDFacts slide presentation handout page 6, 1st row 2nd slide, the new category set mentioned specifically, “Teachers of low-incidence students” whereas, in the attachment said it is broadly defined).	This is no longer relevant as category set B is being deleted as the burden was deemed too high.
202	DG 609 – Special Education Personnel (FTE) Table. The state staff database does not currently require school districts to report contracted personnel. Therefore, we would have to use an alternative method, e.g., the web, etc., to collect information about contracted personnel for the Special Education Personnel (FTE) Table. For this reason, we will need to know prior to the start of the school year all of (a) the data groups, (b) data categories and (c) relevant disaggregations thereof in order to include the contracted ESE staff who are reported through some alternative method with the non-contracted ESE staff who are reported on the staff database. Otherwise the contracted ESE staff can only be reported in the relevant EDEN file totals.	We are working to release the file specifications earlier than in previous years.
290	DG 647 – Special Education Paraprofessionals (FTE) Table. The state staff database does not currently require school districts to report contracted paraprofessionals. Therefore, we would have to use an alternative method, e.g., the web, etc., to collect information about contracted paraprofessionals for the Special Education Paraprofessional (FTE) Table. For this reason, we will need to know prior to the start of the school year all of (a) the data groups, (b) data categories and (c) relevant disaggregations thereof in order to include the contracted ESE staff who are reported through some alternative method with the non-contracted ESE staff who are reported on the staff database. Otherwise the contracted ESE staff can only be reported in the relevant EDEN file totals.	We are working to release the file specifications earlier than in previous years.
291	DG 486 – Special Education Teachers (FTE) Tables. Neither the 0607 EDEN files nor the 0607 DANS tables collect these data at the “incidence level” (Category Set B) shown in the 0708 Proposed Data Set Document, B-2. Please confirm that this reporting discrepancy between EDEN and DANS will be obviated in the 0708 reporting period. And please provide a definition of “low rate of incidence” so that these data can be reported accurately.	ED agrees to drop the proposed “incidence level” (Category Set B).
311	DG 486 – Special Education Teachers (FTE) Tables. The state staff database does not currently require school districts to report contracted teachers. Therefore, we would have to use an alternative method, e.g., the web, etc., to collect information about contracted personnel for the Special Education Teachers (FTE) Tables. For this reason, we will need to know prior to the start of the school year all of (a) the data groups, (b) data categories and (c) relevant disaggregations thereof in order to include the contracted ESE staff who are reported through some alternative method with the non-contracted ESE staff who are reported on the staff database. Otherwise the contracted ESE staff can only be reported in the relevant EDEN file totals.	No response needed.

Topic: Technology

Comment Number	Comment	Response
13	The permitted values for the Internet Access Type category are insufficient. This data category is used with data group 525 (Computer Table) The only response a district can give is “DIAL UP”, “HSPEED” or “NONE.” I take issue with the fact that all Internet access other than dial up will be classified as high speed access according to the allowed parameters of this survey. A T-1 line at 1.5 mb may be the only Internet access an entire district has, with the bandwidth getting split between a number of buildings and many users. The effective bandwidth to the individual desktop computer may be less than a dial up access bandwidth rate. Yet, the way this EDEN data element is structured, it will report nevertheless that the type of bandwidth available is high speed when, in fact, it is not.	Agree. Permitted values changed to reflect the focus on high speed or not high speed.
203	Student - Technology Literacy Status - There is no definition. What is required to report? Is this different than 8th grade technology literacy table and/or 8th grade technology literacy status.	Agree, error.

Topic: Title I

Comment Number	Comment	Response
79	(557) High School Graduation Rate Indicator Status. This data group’s disaggregation categories show that student level data is needed. Our indicator is for the school.	The disaggregation categories have been removed.
82	(563) Graduation Rate Tables. This state collects count of graduates and dropouts by gender and race/ethnicity only. We cannot provide this data by: LEP Status, Disability Status, Economic Disadvantaged Status, Migrant Status, or Homeless Status. Because our data collection is at the school level, adding any new aggregation categories to this collection would be virtually impossible.	Section 1111(h)4 requires data on the graduation rates of student subpopulations. Homeless served status has been removed.
185	Title I School Status (ID 22): There is a question about the interpretation of “eligibility”. It is up to the individual school district to determine if a school is eligible. The criteria include factors other than poverty. The schools within the district that are eligible can vary based on the district’s decisions and own criteria. Districts make the designation of Title I schools. The state agency does not make that designation.	No change. The definition of “Title I Schools Status” in the EdFacts system is “An indication that school is designated under state and federal regulations as being eligible for participation in programs authorized by Title I and whether it has a Title I program.” Section 1113 of ESEA and Section 200.78 of the Title I Regulations set the criteria for which schools are eligible for Title I (a poverty rate of at least 35 percent or at least the districtwide average, whichever is lower). A school that is eligible for Title I is not guaranteed to receive Title I funding, i.e., operate a Title I program. Districts have the responsibility of determining in accordance with the statute and regulations which of the eligible Title I schools actually receive Title I funds.
190	Title I SWP/TAS Participation Table (ID 548) It appears that age/grade was deleted from EDFacts but is still required by the CSPR. (2.1.3.2. in CSPR). These should be consistent.	Age/grade was moved to another data group. For SY 2007-08, data group 548 (Title I SWP/TAS Participation Table) collects the subpopulation data on participants in SWP and TAS programs which is not collected by age/grade in the CSPR. Data group 670 (Title I Participation) collects the age/grade data required on all 4 types of Title I programs.
191	Title I TAS Services Table (ID 549) Uses “participating in and served by”. This phrase seems redundant. The SEA would use “served by.”	No change. The Department believes that the use of both terms are needed to more clearly communicate which students are to be reported. The language in the CSPR has also been changed so both documents will be consistent.
197	A column of information is missing from the 2007-2008 Data Category “Title I Program Type”	Agree. We will fix that page.
204	DG 22 – Title I School Status – This state collects and therefore can report all of these data. The list of data categories are: --Title I Targeted Assistance Eligible School– No Program --Title I Targeted Assistance School --Title I School wide eligible–Title I Targeted Assistance Program --Title I School wide Eligible School– No Program --Title I School wide School -- Not a Title I School Data from some of these EDEN data categories are used to pre-populate the CSPR. Moreover, these EDEN data are expected to match the same data reported by the Title I office. An exact match of Title I School Status data requires an explicit mapping of the set of EDEN categories for DG 22 to the general CSPR reporting codes shown in CSPR, Part II, Sections: (A) 2.1.2.2 – Total Number of Title I Targeted Assistance Schools in the State (B) 2.1.2.3 – Total Number of School Wide Schools in the State.	For purposes of responding to CSPR questions 2.1.2.2. & 2.1.2.3, the following permitted values in EDFacts map to the CSPR: Total Number of Title I Targeted Assistance Schools in the State should include the following: --Title I Targeted Assistance School --Title I School Wide Eligible – Title I Assistance Program Total Number of School Wide Schools in the State should include the following: --Title I School Wide School
248	DG 670 Title I Participation Tables - Student Section - The cumulative unduplicated number of students participating in and served by Title I, Part A programs. - Anticipated (for 07-08) - The Title I Status (Targeted Assistance, Schoolwide, Non-Title) is currently being collected through the Title I School Selection application and 196 districts have submitted so far. The application is only collecting Title I status and not the number of students receiving services.	No change. The Department will refer to state’s EDFacts Transition Plan to verify when (over the next 2 years) the state will be able to submit these data via EDFacts in lieu of manual entry into the online CSPR collection tool.
292	DG 670 – Title I Participation Tables. None of the Title I Participation data is collected on the state Student Database; rather, all of the Title I Participation data is collected via web surveys. The data for ‘Local Part A Neglected’ and ‘Private’ is collected in an online survey for the CSPR wherein the data is disaggregated by grade and program type, and reported at the SEA and LEA levels. Please confirm that the EDEN disaggregations and reporting levels will be the same as required in the CSPR. If the EDEN disaggregations of these data are different than the CSPR data, we will need to know prior to the start of the school year all of (a) the data groups, (b) data categories and (c) relevant disaggregations thereof in order to report the Title I Participation data to EDEN as required.	The EDFacts data set data groups for Title I (548, 549, and 670) match to the questions in the SY 2006-07 CSPR.

Topic: Vocational Education

Comment Number	Comment	Response
3	Is Vocational Education Status a required disaggregation category? The definition of that Category states it is used in only one EDEN data group, and that EDEN data group does not list it among its disaggregation categories. So there is a mistake somewhere, and it would help to know as soon as possible if this particular breakdown category is, or is not, required.	Vocational Education status was a disaggregation category for homeless for SY 2006-07; however, the data was determined to be more burden than could be justified by the need and it was dropped.
63	(320) Vocational Concentrator Graduates Tables. We do collect, at the district level, the number of vocational COMPLETER graduates.	No response needed.
207	The definition of “a vocational concentrator” is changing for Perkins IV. Please confirm that the new definition will be adopted by EDEN in 2007-08.	Beginning with SY 2007-08, EDFacts has adopted the definition and term “Career and Technical Education (CTE) concentrator from Perkins IV.
264	Comments relating to EDEN and Vocational Concentrator(s) Tables (IDs 320, 681, 521): Group Name of Vocational Concentrator(s) – Suggest DELETING Vocational and ADDING Career and Technical Education (CTE).	Agree.
265	Vocational Concentrators Academic Attainment Table (ID681) – The definition is “The number of CTE concentrators who took the NCLB state assessment and who left secondary education during the school year.” The definition is much too vague, and does not match with the Perkins 2006 core indicators of performance. Perkins requires reporting passage rates on state NCLB reading/language arts and mathematics assessments. Passage rates could not be calculated since the number of students who pass the state NCLB reading/language arts and mathematics assessments would not be reported. It should be changed to two parts, such as the following: -”The number of CTE concentrators who passed the state NCLB reading/language arts assessment and who left secondary education during the school year.” -”The number of CTE concentrators who passed the state NCLB mathematics assessment and who left secondary education during the school year.”	The category “proficiency level” is used to differentiate between those who passed and those who didn’t pass. Thus, the data group collects both the numerators and denominators needed to report the passage rate.
267	LEA Level Data (Tables IDs 320, 681, 521) – What is the intent of USDE regarding the requirement of states to report LEA CTE data? Is the intent to track data only on regular school districts (as EDEN is currently set up), or to track data on LEAs who are recipients of the federal Perkins grants? In this state, LEAs who are recipients of the federal Perkins grants are not a school district entity. Local recipients are the Career-Technical Planning District (CTPD) entity (with a CTPD IRN). A CTPD is usually (but not always) a consortium of school districts. Local CTE enrollment and performance results are calculated for each CTPD, not for school districts. It would place an additional burden on this state to additionally create district level CTE reports. This state requests to report local Perkins grant recipient data in EDEN instead of school district. Therefore, this state requests that EDEN add IRNs of CTE-type entities (known in Ohio as CTPDs) to enable this reporting. If USDE decides to require the reporting of school district CTE data, much of this state’s local CTE data will not be reportable in EDEN as it is currently set up. Approximately 40% of this state’s CTE programs are operated by Joint Vocational School Districts (JVSDs), which are LEAs with their own tax base. JVSDs operate CTE programs in their own Joint Vocational Schools (JVSs). JVSDs also operate CTE programs in buildings of their associate school districts. There are no provisions in EDEN to report data on JVSD and JVS entities.	As described, the Career-Technical Planning Districts could be LEAs in EDEN and NCES’s Common Core of Data (CCD). These Districts would be reported as type 4s, regional education service agencies. The Joint Vocational Schools would be reported in the CCD and EDEN as shared time schools.

Changes Resulting from Public Comments

This section summarizes the proposed changes to data groups and data categories that directly result from public comments. Additional changes, not described below, result from extensive cleaning of the material presented in the OMB package. For example, all age, grade, and age/grade categories were reviewed and revised as needed so that each data group collects the correct range of age, grade, or age/grade. As another example, the references to data groups using particular categories were reviewed and corrected where necessary.

The first table below summarizes the changes made to data groups. Most commonly these changes included changing the name of the data group and adjusting the definition. The second table summarizes the changes made to data categories. Most changes to data categories were adjustments of the permitted values. Many data categories were also dropped.

Table 1 – Changes to Data Groups Resulting From Public Comments

Data Group ID	Data Group Name Description of Change
1	LEA Identifier (NCES) Delete “and the U.S. Census Bureau” from the definition.
12	FIPS County Code Change section - subject to “Directory” from “Directory-derived”. Changed “Summary of directory data by tier” (B-1) by deleting the “*” by ID12 in both LEA and school column. Added comment “Directory data derived from sources other than SEAs”
17	Locale In Attachment B-1, replace the current code set with revised code set.
24	Magnet Status Drop the “not collected by the state” permitted value. Reorder the remaining permitted values. New order will be: “Yes, No magnet program, magnet school/program - all students, magnet school/program - not all students participate.”
24	Magnet Status Delete current comment and replace with “This data group is part of both the CCD and CRDC. For schools selected in the CRDC, magnet programs are differentiate by whether or not all students participate.” Change NA in file specification # to “to be assigned.”
32	AYP Status Add new permitted value “Yes (by growth models)” and relabel original “Yes” value to “Yes (by regular determination).”
34	Improvement Status - School Delete the permitted value “improvement.”
288	Promotion Decisions Tables Relabel data group name to Promotion Testing Tables.
298	Graduation Decisions Tables Relabel data group name to Graduation Testing Tables.
306	Graduates/Completers Table Add Subtotal 1 “Diploma/Credential.”
320	Vocational Concentrator Graduates Tables. Relabel data group to use the term “CTE Concentrators” in place of the term “Vocational Concentrator.”
326	Dropout Tables Change reporting period to “October 1 through September 30”. Change category set B to Disability Status (Only) from Disability Status (IDEA).
486	Special Education Teachers (FTE) Remove Incidence Level from category set B.
514	Combined MEP Funds Status Relabel data group to Consolidated MEP Funds Status. Change comment to “Use ‘NA’ when a school does not have a schoolwide program and/or does not receive federal migrant education funds under Title I, Part C.” Revise definition to use “consolidated” instead of “combined.”
519	Immigrant Tables Change the reporting period from 10/1 to school year.
521	Vocational Concentrator Tables. Relabel data group to use the term “CTE Concentrators” in place of the term “Vocational Concentrator.”
529	School Identifier (NCES) Delete “and the U.S. Census Bureau” from the definition.
531	School Operational Status In Attachment B, change “agency” to “school” the code set.
551	Supervisory Union Identifier (NCES) Relabel data group to delete “(NCES)” from name. Change definition to “the three-digit unique identifier assigned to the supervisory union by the state.”
560	Homeless Served (McKinney-Vento) Tables Change definition from “program” to “program subgrant.”
563	Graduation Rate Tables Delete category set G “Homeless served status.”
573	Shared Time Status Change definition to “An indication that a school offers vocational/technical education or other education services, in which some or all students are enrolled at a separate school of record and attend the shared-time school on a part-time basis.”
601	Firearm Incident Table Change the definition to “the number of incidents involving students who brought or possessed firearms at school.”
634	MEP Students Eligible 12-Month Tables Relabel data group to Migrant Students Eligible 12-Month Tables. Category set B (Migrant Priority …) and C (LEP Status) should be Age/Grade (W/o Under 3). Add Subtotal 1 with Age/Grade (All).
636	MEP Students Served Regular School Year Tables Category sets B (migrant priority …) and C (continuation …) should be Age/Grade (W/o Under 3).
637	MEP Students Served Summer/Intersession Tables Category sets B (Migrant Priority …) and C (Continuation …) should be Age/Grade (W/o Under 3).
653	Charter School LEA Status Change definition to “The status of a charter school as an LEA for purposes of federal programs.” Change permitted values to “Not an LEA for any federal program, An LEA for programs authorized under IDEA but not under ESEA and Perkins, An LEA or programs authorized under ESEA and Perkins but not under IDEA, An LEA for programs authorized under IDEA, ESEA, and Perkins.”
661	Graduation Test Passing Tables Relabel data group to Graduation Test Passing Tables.
664	Truants Add a comment “Threshold means the number of unexcused absences that the state determines make a student a truant.”
674	LEP English Language Testing Tables In category set B, add “(Assessment)” after “Testing Status.”
675	Title III LEP English Language Testing Tables Correct Section. It should be Student not Program.
678	LEP Enrolled Tables Add category set C for “English Language Proficiency Level.”
679	Choice/SES Set Aside Change definition to “The dollar amount of the 20 percent reservation for supplemental educational services and choice-related transportation.”
680	SES Funds Available Change definition to “The maximum per child dollar amount for expenditures related to supplemental educational services.”
681	Vocational Concentrator Academic Attainment Table Relabel the data group to use the term “CTE Concentrators” in place of the term “Vocational Concentrator”.

Table 2 – Changes to Data Categories Resulting from Public Comments

Data Category Name

Description of Change

8th Grade Technology Literacy Status
Relabel data category to Technology Literacy Status and use with data group 650.

Attainment Status
Drop data category.

Continuation (Only)
Revise comment to read: “Children served under ESEA Title III section 1304(e)(1), that is children served whose eligibility expired during the school term, are NOT included.”

Country of Origin
Drop data category.

Diploma/Credential
Delete “high school equivalency credential” from the permitted values.

Discipline Reason (Safe and Drug-Free)
Change permitted value from “Other” to “Other removals related to drug use and violence.”
Add “Incident” to Violent permitted values … Violent Incident (With Physical Injury) and Violent Incident (Without Physical Injury).

English Language Proficiency Level
This data category was deleted for 2006-07. Reinstate for 2007-08.

Grade Level (Basic)
Add “Ungraded” to permitted values.

Highest Level of Education Completed
Drop data category.

Homeless Primary Nighttime Residence
In the definition, delete the sentence “An indication of whether…”

Homeless Status (only)
In the comment, change “…subgrant, to designate a local liaison ….” to “… subgrant, to implement the Act including designating a local liaison….”

Homeless Students.
Drop data category.

Homeless Unaccompanied Youth Status
Modify definition of data category by changing the ending to “by parents or legal gaurdians” instead of “by parents, legal guardians, or other adults.”

Internet Access
Change permitted codes to “No Connectivity, High Speed Connectivity, and Less Than High Speed Connectivity.”

N or D Programs (Subpart 1)
Delete permitted value “multiple purpose facilities.”

N or D Programs (Subpart 2)
Delete permitted value “multiple purpose facilities.”

NCLB School Improvement Options
Drop data category.

Progress Level
Fixed the cut off permitted values.

Staff-Technology Professional Development Hours
Drop data category.

Technology Literacy Status
Drop data category.

Testing Status (Assessment)
Add DG 674 LEP Eng Lang. Testing Tables and 675 Title III LEP Eng Lang. Testing Tables to list of EDEN data groups.

Title V strategic priority
Drop data category.

Vocational Education Status
Drop data category.