60 Day Comment Response Summary

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Directed Question
Indicator 4: Family Outcomes 
This indicator measures the percent of families participating in Part C who report that early intervention services have helped the family:
(A) know their rights; 
(B) effectively communicate their children’s needs; and 
(C) help their children develop and learn. 
The Department believes that the information families provide is critical to helping States evaluate the effectiveness of their systems. It is this parent and State partnership that will ensure raised expectations and improved outcomes for each child with a disability and their families. As such, the Department is interested in ways to make the data more meaningful and ensure it drives improvement of State systems. 
Questions 
    a) How can the collection and reporting of family outcomes data be improved to ensure that States are receiving and addressing feedback from parents who have pursued, or may pursue, dispute resolution options under the IDEA? 
    b) How can the collection and reporting of family outcomes data be improved to make the data more meaningful for all stakeholders? 
    c) How can the collection and reporting of family outcomes data be improved to ensure States are receiving data that can be used to strengthen program implementation and improve the outcomes of children with disabilities? 
    d) What challenges exist in collecting and reporting these data?
Comments: Several commenters provided responses to the directed question. Two commenters stated that their suggestions represented general strategies they have known to be useful at the State level but acknowledged that each State is unique and recommended that their suggestions for improving data quality and usability be used to guide considerations for States as they improve their data systems and analysis processes, rather than to guide requirements for data collection and use across States. The commenters suggested that OSEP consider providing sample surveys and related communications that have been demonstrated to be effective within their local contexts. These commenters also shared that altering the data collection to ensure that States are receiving and addressing feedback from parents who have pursued, or may pursue, dispute resolution options would be challenging because most family outcomes survey systems are anonymous, making it difficult to know whether respondents have pursued or considered pursuing dispute resolution options and limiting the ability to meaningfully triangulate survey responses with dispute resolution activities. Further, the commenters expressed that extant family outcomes measures include items related to families understanding of their rights, confidence communicating their child’s needs, and access to services, and argued these items are closely tied to dispute resolution. Finally, the commenters expressed that families who pursue dispute resolution already have the opportunity to share feedback with States directly, which they believed to be more actionable than potential information gleaned from anonymous survey data. One commenter suggested that triangulating data with additional sources, such as child outcomes, service delivery, and family engagement data may make data more meaningful. The commenter also suggested data collected be shared in a timely, accessible and meaningful way for several audiences. The commenter recommended establishing feedback loops by sharing survey data with families, providers, and local programs to demonstrate that the data are used to improve programs, and in turn collect more meaningful data. One commentor suggested that placing greater emphasis on how data are used to support decision-making and program improvement, rather than on collection requirements, may strengthen data collection and reporting toward improved program implementation and outcomes. Challenges in collecting and reporting this data identified by the commenters included family buy-in; identifying and addressing non-response bias; outdated data systems and established practices that limit efficiency and flexibility in how data are collected, analyzed, and reported; limited funding to modernize systems or implement innovative approaches to improve data quality and usability; time and effort of both Part C coordinators and families, and; survey fatigue.
Discussion: OSEP appreciates the commenters’ responses to the directed questions, including the acknowledgement that States needs around data differ, and will take them into consideration as work continues to provide guidance and assistance to States aimed at improving the quality and usability of Part C data.