OMB Supporting Statement B.10 08 24

OMB Number: (XXXX) 1870-0504
RIN Number: XXXX-XXXX (if applicable)

Revised: XX/XX/XXXX

PAPERWORK REDUCTION ACT
SUBMISSION
Mandatory Civil Rights Data Collection
October 2024

SUPPORTING STATEMENT, PART B:
COLLECTION OF INFORMATION EMPLOYING
STATISTICAL METHODS

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OMB Number: (XXXX) 1870-0504
RIN Number: XXXX-XXXX (if applicable)

Revised: XX/XX/XXXX

1. Describe the potential respondent universe (including a numerical estimate) and any
sampling or other respondent selection method to be used. Data on the number of
entities (e.g., establishments, state and local government units, households, or
persons) in the universe covered by the collection and in the corresponding sample are
to be provided in tabular form for the universe as a whole and for each of the strata in
the proposed sample. Indicate expected response rates for the proposed sample.
Indicate expected response rates for the collection as a whole. If the collection had
been conducted previously, include the actual response rate achieved during the last
collection.

The 2025‒26 and 2027‒28 Civil Rights Data Collections (CRDC) will be a universe of public
schools and local educational agencies (LEA). Therefore, none of the sampling procedures (i.e.,
stratification, estimation, etc.) are proposed to be used in the 2025‒26 and 2027‒28 CRDC
administrations.
Respondent Universe
The respondent universe for the 2025‒26 and 2027‒28 CRDCs will be the most recently available
data from the Common Core of Data (CCD) National Public Education Survey of Local
Educational Agencies. The CCD is designed to be the U.S. Department of Education’s (ED)
comprehensive statistical database of all public schools and LEAs. Most of the data are obtained
from administrative reports maintained by state educational agencies (SEA). The CCD survey
data are collected annually by the National Center for Education Statistics (NCES). The frame for
the CCD survey includes LEAs and regular, non-regular (special education, alternative, career, or
technical), and public charter schools.
For the CRDC and the CCD, an eligible school is defined as an organization authorized by public
authority and financed primarily through public funds to provide public education to students.
Under this definition, schools:
•
•
•
•
•
•

Are operated by a public school district, independent charter district, or state agency on
behalf of the state
Provide instruction for students
Have, will have, or had one or more students
Have, will have, or had one or more teachers
Have an assigned administrator(s) (principal) responsible to public authority, and
Receive public funds as its primary support.

Frame Additions and Deletions
While the CRDC definition of a school matches that used by the CCD, there are a few operational
differences. In some instances, schools in the CCD are essentially administrative units that may
oversee entities that provide classroom instruction, or the school in the CCD may provide funding
or oversight only. The CRDC is primarily designed to collect data from public LEAs about
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OMB Number: (XXXX) 1870-0504
RIN Number: XXXX-XXXX (if applicable)

Revised: XX/XX/XXXX

educational entities where students receive educational services (physically and/or remotely) for
at least 50 percent of the school day, regardless of whether students are reported elsewhere for
funding, accountability, or other reporting purposes. To be eligible to participate in the CRDC,
schools must serve students at the (physical and/or remote) site for at least 50 percent of the school
day. Since the CCD and CRDC differ slightly in scope, some records are deleted, added, or
modified to provide better coverage and a more efficient frame for the CRDC. The following
types of school records are deleted from the CCD during the creation of the sampling frame:
•
•
•
•

District boundary type 2: Agency has closed with no effect on another agency’s boundaries.
School status 2: School has closed since the time of the last report.
Nonoperational school districts: School districts that do not operate a school.
Schools and school districts with a Federal Information Processing Standards (FIPS) state
code of 58 (overseas DoD), 60 (American Samoa), 66 (Guam), 69 (Northern Mariana), 78
(U.S. Virgin Islands), or 59 (Bureau of Indian Education).

Districts with no membership or missing membership at the district-level are generally excluded,
except in some special cases, such as where membership data were available for the associated
schools.
Additionally, OCR augments the CRDC frame to include justice facilities, which may not be under
the purview of the SEA or an LEA. In collaboration with the Department of Justice’s Office of
Justice Programs, OCR adds justice facilities which may not have been otherwise included in the
CCD to ensure coverage of all youth in pre- or post-adjudication facilities that receive educational
services. Also, state-operated programs for special populations of students (such as schools for
the deaf and schools for the blind) are added to the universe if they are not already included in the
CCD list.
Response Rate
The CRDC has a traditionally high response rate due to the mandatory nature of the data collection.
The last six CRDCs, which have been universe collections, have had response rates that have
ranged from 98 to 100 percent. For the 2011–12 CRDC, 98 percent of all participating LEAs and
99 percent of all schools provided data. For the 2013–14 CRDC, 2015–16 CRDC, and 2017−18
CRDC, 99 percent of all participating LEAs and 99 percent of all schools provided data. The
response rate for the 2020−21 CRDC was 100 percent for both LEAs and schools, and the response
rate for the 2021‒22 CRDC was 99 percent for both LEAs and schools. The response rate for the
2023‒24 CRDC and proposed 2025−26 and 2027‒28 CRDCs are expected to be no less than 98
percent of all participating LEAs.

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OMB Number: (XXXX) 1870-0504
RIN Number: XXXX-XXXX (if applicable)

Revised: XX/XX/XXXX

2. Describe the procedures for the collection of information, including:
▪
▪
▪
▪
▪

Statistical methodology for stratification and sample selection
Estimation procedure
Degree of accuracy needed for the purpose described in the justification
Unusual problems requiring specialized sampling procedures, and
Any use of periodic (less frequent than annual) data collection cycles to reduce
burden.

The 2025‒26 and 2027‒28 CRDCs will include a universe of all public schools and LEAs.
Therefore, none of the sampling procedures (i.e., stratification, estimation, etc.) is proposed to be
used in the 2025‒26 and 2027‒28 CRDC administrations.
Procedures for the Collection of Information
Verification and updates of school lists by LEAs: Spring 2025 - Fall 2026 (2025‒26 CRDC) and
Spring 2027 - Fall 2028 (2027‒28 CRDC)
LEAs are notified by email of their required participation in the collection and asked to verify and
update their listing of schools and provide a primary point of contact and an alternate point of
contact for the survey. Links to survey questionnaires and supporting documents are also included
in the initial email to LEAs. A Web-based system is available to LEAs to provide contact
information for a principal point of contact. LEAs may also verify their school list, add new
schools that opened at the beginning of the 2025‒26 and 2027‒28 school years, collapse schools
that have merged, or remove schools that have closed. In past surveys, OCR has encountered
discrepancies between the definitions of a school as held by the LEA itself and as reported by state
departments of education to the CCD. This issue occurs most often in rural areas or in schools
that offer grades K-12 in one building with one head principal. The schools often consider
themselves one cohesive unit while the state does not. For accounting or other administrative
purposes, the state may artificially split these schools by grade level and report them as two or
three separate schools. For the CRDC, the K-12 school with one principal can be collapsed into
one reporting entity and report all students enrolled in grades K-12.
Telephone follow-up and reminder emails are sent to LEAs that do not provide a principal point
of contact or verify their school list.
Data collection by selected data submitters: Spring 2025 - Fall 2026 (2025‒26 CRDC) and Spring
2027 - Fall 2028 (2027‒28 CRDC)
While awaiting for LEAs to identify a principal point of contact and a verified list of participating
schools, OCR provides updated training videos, frequently asked questions, technical assistance
materials, and other resources, available on the CRDC Resource Center website
(https://crdc.communities.ed.gov). A support center is also available for LEAs to call or email
questions regarding the content of the data to be collected. While LEAs are collecting and after
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OMB Number: (XXXX) 1870-0504
RIN Number: XXXX-XXXX (if applicable)

Revised: XX/XX/XXXX

they have collected their data for the CRDC, OCR provides guidance for LEAs to prepare flat files
of the required data to prepare for the survey data submission opening.
Survey Data Submission Window: Fall 2026 - Winter 2027 (2025‒26 CRDC) and Fall 2028 Winter 2029 (2027‒28 CRDC)
The survey data submission window opens with email notification to all participating LEAs. LEAs
will be given a minimum of 60 days to submit their data to OCR. In anticipation of the survey
data submission system opening, OCR continues to update technical assistance documents and
post them on the CRDC Resource Center website. OCR also increases the support center’s hours
of operation. During the survey data submission period, frequent communication occurs with
participating LEAs to offer technical assistance and, as the survey data submission due date
approaches, reminders are sent to LEAs that have not yet certified their CRDC data submission.
Accuracy
The CRDC is intended to collect information about educational equity and excellence in public
elementary and secondary education. Although respondents are experts in the educational
opportunities and participation in their LEAs, there are opportunities for potential error, either
through technical mishap or misinterpretation of the intent of a survey item. Over the course of
several CRDC administrations, OCR has developed and continues to develop a series of data
quality checks designed to flag these errors for review by the respondent and OCR. These edits
rely on internal logic checks, consistency within specific tolerances, and comparisons to similar
data collected by other program offices within ED.
Because the CRDC is a mandatory collection, respondents are required to provide data for each
applicable item. (See Attachment A-4 for more details about how directional indicators are used
to determine item applicability.) In rare cases, an LEA may not be able to respond with complete
and accurate data to a specified item. In these cases, the LEA is required to submit an action plan
for the CRDC to OCR. In an action plan, the LEA is required to describe the specific steps and
timeline that it will follow to ensure that the data are collected for future CRDCs. Once OCR
approves the plan, the LEA is allowed to certify its data submission. Later, when OCR is preparing
the CRDC data files, for an item with missing data that came from an LEA with an action plan,
OCR assigns an action plan reserve code to the missing data.
3. Describe methods to maximize response and to deal with issues of non-response.
The accuracy and reliability of information collected must be shown to be adequate
for intended uses. For collections based on sampling, a special justification must be
provided for any collection that will not yield “reliable” data that can be generalized
to the universe studied.

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OMB Number: (XXXX) 1870-0504
RIN Number: XXXX-XXXX (if applicable)

Revised: XX/XX/XXXX

Response Rate
Historically, the civil rights survey has had a very high response rate. In 2000, the predecessor
Elementary and Secondary School Civil Rights Compliance Report (E&S Survey) was sent to a
universe of all LEAs and schools in the United States. The overall response rates were 97 percent
for all LEAs and 99 percent for all schools. The overall response rates for the 2002 E&S Survey
were 98 percent for LEAs and 98 percent for schools. For the 2004 CRDC, the response rates,
including partial respondents to the data collection, were approximately 97 percent for all LEAs,
and 97 percent for all schools. The 2006 CRDC achieved an unprecedented 100 percent response
rate for LEAs and a 99.6 percent response rate for schools. The 2009–10 CRDC achieved a
response rate of 100 percent for LEAs, and 100 percent for schools. The 2011–12 CRDC achieved
a response rate of 98 percent for LEAs and 99 percent for schools. The overall response rates for
the 2013–14 CRDC, 2015–16 CRDC, and 2017−18 CRDC, were 99 percent for LEAs and 99
percent for schools. The response rate for the 2020−21 CRDC was 100 percent for both LEAs and
schools, and the response rate for the 2021‒22 CRDC was 99 percent for both LEAs and schools.
Methods to Maximize Response Rates
Frequent communications occur with participating LEAs over the course of the data collection to
ensure compliance with this statutorily mandated collection. LEAs are notified via email of their
obligation to report. In addition, frequent email correspondence occurs with the LEA’s principal
point of contact regarding technical assistance available to support the LEAs submitting the
required data, reminders of upcoming deadlines, and notifications if the CRDC data were not
submitted by the due date. If LEAs fail to respond in a timely manner, then the contractor for the
data collection, with assistance from OCR and its field offices as necessary, provides extensive
outreach and assistance to the greatest extent possible until the LEAs respond, or the final deadline
for accepting data has passed. The superintendents of non-responding LEAs are also contacted by
phone and email. This has proven to be very successful in past years.
OCR has also met with SEAs wanting to support LEAs responding to the CRDC. During the
NCES STATS-DC Conference, OCR holds a special session for SEAs to learn more about the
upcoming changes to the CRDC, important dates for the completion of the CRDC, and how to
access technical resource materials. It is in not uncommon for states to upload some of the LEAs’
data for the CRDC. The last outreach letter emailed by OCR during the CRDC submission period
is to the SEAs, asking them to encourage LEAs that have not yet certified their data to complete
the CRDC by the deadline.
4. Describe any tests of procedures or methods to be undertaken. Testing is
encouraged as an effective means of refining collections of information to minimize
burden and improve utility. Tests must be approved if they call for answers to
identical questions from 10 or more respondents. A proposed test or set of tests may
be submitted for approval separately or in combination with the main collection of
information.

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OMB Number: (XXXX) 1870-0504
RIN Number: XXXX-XXXX (if applicable)

Revised: XX/XX/XXXX

OCR plans to evaluate the data collection procedures and data items described in this submission
in a number of ways. Many of the data elements proposed for the 2025‒26 and 2027‒28 CRDCs
were collected in the previous 2011–12, 2013–14, 2015–16, 2017–18, and 2021‒22 CRDCs, and
will be collected in the upcoming 2023‒24 CRDC. Data quality is an overriding concern that OCR
continues to assess and evaluate. OCR assesses data from CRDC survey years to evaluate the
internal and external consistency and reliability of the reported data to continuously improve the
business rules and edit checks used in the survey submission system. Edit checks help to identify
potential problems and provide opportunities for LEAs to correct possible mistakes before
certifying the accuracy of their submission.
Content
The proposed data elements include items required for the 2025–26 and 2027‒28 CRDCs and new
required and optional items for the 2025−26 and 2027‒28 CRDCs. Similar to what OCR did for
the 2013‒14 CRDC, dependent on staff availability and funding resources, OCR may conduct
recordkeeping visits with LEAs for the 2025‒26 and 2027‒28 CRDCs, to determine whether and
how they presently collect data for the CRDC data groups. If conducted, then OCR would select
sites that reflect a diverse set of LEAs in terms of size, urban/city, level of sophistication of SEA
and LEA data systems, and programs offered. These visits may gather information on ways in
which the survey submission tool may assist in improving data quality through edit checks and
other analytical procedures. Additionally, OCR is exploring the possibility of conducting one-onone cognitive interviews with SEA, LEA, and/or school respondents to validate proposed item
wording, dependent on available staff and funding resources. These interviews may be conducted
by phone and in person, as appropriate.
Survey Tool
OCR and NCES collaborated to develop an enhanced survey data submission tool that was first
implemented for the 2013–14 CRDC. Testing plans for the 2025‒26 CRDC and 2027‒28 CRDC
tool closely mirror previous CRDC protocols. For the 2025−26 and 2027–28 CRDCs, OCR plans
to invite a few LEA and SEA representatives that intend to pre-populate data elements, to
participate in some initial discussions with the contractor about various features of the tool. If
funding is available, then OCR will pilot test the online survey tool for data submission with LEAs
and SEAs. Pilot participants will likely have access to the survey software for a period of no less
than 10 business days.
OCR will work with its selected contractor to compile LEA and SEA suggestions, categorized by
level of criticality and feasibility. Based on these results, OCR will identify changes, such as text
refinements, and any critical technical issues for correction and resolution prior to the opening of
the 2025‒26 CRDC and 2027‒28 CRDC survey tool for all participating LEAs.
5. Provide the name and telephone number of individuals consulted on statistical
aspects of the design and the name of the agency unit, contractor(s), grantee(s), or
other persons who will actually collect and/or analyze the information for the agency.
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OMB Number: (XXXX) 1870-0504
RIN Number: XXXX-XXXX (if applicable)

Revised: XX/XX/XXXX

OCR intends the 2025‒26 and 2027‒28 collections to be a universe of public schools and LEAs.
If budget constraints are such that a universe collection for the 2025‒26 and 2027‒28 CRDCs is
not possible, then OCR will work closely with NCES to prepare a sample selection plan and submit
it to OMB for review and approval. After OMB approves the plan, OCR will have its contractor,
Applied Enterprise Management Corporation, implement the plan for the 2025‒26 and 2027‒28
CRDCs.

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