60D Comment Response

ESSER Annual Data Collection: 60-day Comment Responses
Public Comment	Applicable Section	Commentator(s)	ED Response
The Activities in the annual reporting template should have corresponded to the Focus Areas that were provided in the ESSER FAQs. SEA and LEA staff budgeted by Focus Area. Update the dates of the annual report reopen period so that respondents can update all report years at the same time. Updating one year impacts data in other years so it would be helpful to be able to make all changes at the same time. Provide option for respondents to enter all information through the webpage rather than requiring spreadsheet uploads. It is difficult to balance all figures when they are being entered in different areas using different methods. Providing demographic information by program is a burdensome process for LEA staff. This information is not readily available by program and requires significant manpower to obtain the information. Providing FTE counts by school is a burdensome process for LEA staff. This information is not readily available by program and requires significant manpower to obtain the information. The public reporting burden figures of 140 hours for SEA responses and 140 hours per LEA response is not accurate. Estimated time for SEA response is at least 250 hours.	Whole form	State Educational Agency	The expenditure and activity information collected in the ESSER Annual Performance Report are aligned with the allowed and expected uses of ESSER funds. While the Department understands the desire to update multiple report years at the same time, the ESSER Annual Performance Report (APR) system is designed to maintain data consistency by comparing current year entries with previous submissions. Allowing updates across multiple years simultaneously could compromise these data quality checks and lead to inconsistencies. Each year’s data needs to be reviewed in isolation to ensure accurate reporting and maintain the integrity of the information across years. The Department acknowledges the commentator’s preference for entering all ESSER APR data through the online reporting website. However, additional changes to the reporting system could cause additional burden for States that have set up systems to report data in the currently required formats. The Department aims to balance flexibility with minimizing disruption to existing collection processes, while also ensuring that states with substantial data can continue reporting accurately and efficiently. The Department believes that collecting the demographic information of students that participated in ESSER-funded activities and collecting counts of FTEs at LEAs that received ESSER funds is important to understand the impact of ESSER funds on student groups and staffing at LEAs. The Department appreciates this feedback. The burden estimates for the ESSER APR were determined through Departmental review of the collection instrument and were informed by public comments.