60D Comment Response

Responses to 60 -Day Comments for 1840-0744.docx

Higher Education Act (HEA) Title II Report Cards on State Teacher Credentialing and Preparation

60D Comment Response

OMB: 1840-0744

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Responses to 60-day public comments received for 1840-0744



Name & email: Bianca Singhat [email protected] and

Tom Zembar



The commenters suggested that the Department make changes to the ‘Institutional and Program Report Card’ (IPRC) and the ‘State Report Card’ (SRC).

OPE response:

We thank the commenters for their involvement in efforts to improve accountability and transparency in higher education. The commentors suggested several modifications they would like implemented to the IPRC and the SRC.

The commenters asked about the proposed changes due to COVID and additional clarification on whether or not programs that waived licensure assessments as a program completion requirement check the box. If not, where would this practice be documented?

OPE response: The series of questions regarding changes due to COVID asks for changes implemented in each year since the pandemic started, beginning with 2019-20. This means that changing the series will not be a problem time-series wise. This has been added in the questionnaire document. Respondents will specify in the [Please describe] space.



The commenters asked how the Department is calculating the normal expected completion time and conveying that to institutions using the IPRC.

OPR response: Respondents will determine what normative time is for their programs and report the number of students who complete outside that time period. Programs determine what the time period is. No changes will be made.


The commenters recommended the addition of language to the “Total State Completion Rate” box, suggesting the Department revise the language to read “Total percentage of traditional (full-time) students who finish their program within the normal expected completion time or non-traditional (part-time) students who finish their program within an adjusted schedule for completion.”


OPE response: "Traditional (full-time)" and "nontraditional (part-time)" students is an inaccurate and unclear distinction. Why knowing this distinction is helpful. No changes will be made.


The commenters suggested that the Department should provide additional clarification to the last category of responses within the table related to urban and rural schools.


OPE response: The item is in its current form. No changes will be made.


The commenters suggest the Department include two additional items: adding an additional criterion about increasing the percentage (or number) of program participants of color who are successful in program completion and adding an indicator about increasing the number (or percentage) of program completers who receive compensation or a stipend while participating, at a minimum, in a full academic year (e.g. residency or apprenticeship) of clinical practice.


OPE response: These are reasonable additions and will be taken into consideration for the next round of OMB clearance.


The commenters recommended that the Department consider replacing the open text option in this section with five additional multiple-choice questions. The current list includes an extensive list of multiple-choice options. States selecting the “other” option may use it to share unique information that may guide future revisions of the existing options.



OPE response: See the proposed changes in the SRC reporting instrument.



Name & email: Tuan Nguyen – [email protected]

The commenter raised questions about teacher shortage areas and possible changes that should be made.

OPE response: The comment does not apply to the questionnaires. This questionnaire asks programs about goals to prepare teachers in subjects/specialties in which many districts experience shortages. It does not ask programs whether there are shortages of teachers in these subjects/specialties in their localities or states. This is accomplished through the Teacher Shortage Areas data collection. Teacher preparation programs can go to that data collection to determine if the state has determined a subject area as shortage to offer students TEACH Grants. No changes will be made.














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