60 Day Comment Response

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The 60-day Federal Register notice was published on May 26, 2026, Vol. 91., No. 100 page 30621. Seven comments were received on the Consolidated State Performance Review (CSPR)  proposed data collection. Three comments supported the proposed changes, with one of the comments proposing additional changes to CSPR. Broadly this commenter was proposing to reduce potential duplication of collection and streamlining questions into other monitoring activities or collections. One comment received was not relevant to this collection. Finally, there were three commentors opposed to specific proposed changes. The Department provides responses to commentors opposing proposed changes and any additional proposed changes below. 
Transferability:
Comment: One commentor stated that removing these questions 2.7.1, 2.7.2, 2.7.3, and 2.7.4 is a significant problem and that the Department should not eliminate.  Another commentor stated "Funding Transferability for State and Local Education Agencies" should not be eliminated. The commentor notes that it is required by grant data collection and accountability laws.  The commentor further cites OCR data (https://ocrcas.ed.gov/open-investigations) with districts showing potential patterns of violation.  
Response: The commentors raised important considerations and the Department has determined it will retain these questions in the CSPR. 
Title III:
Comment: A Commentor opposes removal of Title III, Part A Allocation Timeline (Questions 1.3.8.1 and 1.3.8.2)  These questions provide critical visibility into when Title III, Part A subgrantees receive their funds.
Response: The Department appreciates the public comment and the need for visibility. The Department will move this work from the CSPR to program monitoring activities which align with current practices for other federal formula funds that flow through the SEAs to the LEAs. The intention is to reduce potential duplication of reporting requirements when specific requirements can be met through other ongoing means. 
Comment: One commentor recommends retiring CSPR Section 1.3.2, Languages of Instruction by LIEP Type. 
Response: The Department appreciates the commentors suggestion, but this data is currently reported in the Title III bi-annual Report to Congress therefore we need to continue collecting these data. The Department will continue to look for ways to streamline and reduce burden in the future.
Neglected, Delinquent and At-Risk Youth:
Comment:  A commentor opposes removal of Title I, Part D — Neglected, Delinquent, and At-Risk Youth (Questions 2.5.1.1 and 2.5.3.1)   The commentor finds the proposed removal of these questions to be especially problematic and states that this change would eliminate state reporting on Children and Youth who are Neglected, Delinquent, or At-Risk, including justice-involved youth from the CSPR.
Response: The Department appreciates the public comment and concern for the data collection related to this population. The data regarding State Agency and LEA program/Facility type will still be collected for Title I Part D Subpart 1 and 2 through EDFacts File Specs 119 and 127. Data on length of stay and number of days served has been an unreliable data collection with low confidence in the accuracy of the information provided in the CSPR. The program office will continue to monitor programs serving this population and make data publicly available for FS 119 and 127.  
Report Card Websites:
Comment: The commentor stated the question should be retained so there is a clear, authoritative record of where the public can find state report cards—the documents that house essential information on student performance on state assessments and other data generated by state accountability systems.
Response: The Department appreciates the comment. The Department is verifying State Report Card Websites through other monitoring activities and will continue to maintain a list of those websites for the public on ED’s website. Therefore, this question is no longer needed to maintain that list.  
Comment: A commentor supports removing the State Report Card URL requirement in Section 2.1, provided the URL remains available and accessible through another federal mechanism.
Response: The Department appreciate the comment and notes it will maintain a list of State Report Card URLs on ED’s website. 
Reporting Period:
Comment: The commentor noted that it is difficult to work with two different periods of time for the data collection process.  It would be helpful to have a guidance document…or combining into the time periods into the same data collection time.
Response: The Department proposes to combine the CSPR from two collection periods to one collection period to reduce burden on grantees. 
Reporting Mechanisms:
Comment: The commentor suggested the Department pursue additional burden-reducing opportunities that align with the statutory purpose of Elementary and Secondary Education Act (ESEA) Section 8303...data elements are often not comparable across states and rarely change from year to year. Rather than require annual reporting, the ED could collect this information through state plans and oversight mechanisms, such as the ESEA Consolidated State Plan, including Title I, Title II, Title III, Title IV, and McKinney-Vento program assurances and implementation descriptions where applicable.
Response: The Department appreciates the suggestion to move data elements to other forms of reporting and oversight. Other forms of reporting and oversight don’t meet statutory requirements collected and report specific data annually to congress.  The Department commits to continuously reviewing data requirements and means of collecting data to reduce burden on our grantees. 
Migrant Data Count:
Comment: One commentor noted that data reported in CSPR Sections 1.6.2.1 and 1.6.3.1 are prepopulated from the Migrant Student Information Exchange (MSIX). Requiring states to provide narrative explanations for variances exceeding 10 percent in Sections 1.6.2.2 and 1.6.3.2 creates unnecessary reporting burden. While this section is not being considered for changes, the CDE recommends eliminating Sections 1.6.2.2 and 1.6.3.2 and instead incorporating automated variance checks within MSIX.
Response: The Department appreciates the suggestion from the commentor. Unfortunately, the Migrant Student Information Exchange (MSIX) does not allow for qualitative data entry currently. The Department will continue to review new ways of collecting this information in order to reduce burden on grantees in the future.  
CSPR Collection:
Comment: One commentor recommends updating the functionality of the new CSPR Tool, Qualtrics. The commentor appreciates the ability to return and edit responses prior to final submission. However, when entering longer narrative responses, the text box does not allow for a review of the entire response at once. Improving the visibility and navigation of longer narrative responses would enhance the user experience and help ensure the accuracy of submitted information.
Response: The Department appreciates the public’s comment and will not be using Qualtrics in future CSPR data collection. The Department will be looking at survey tools that allow better functionality for longer narrative responses. 
Reducing CSPR Manual Entry Questions:
Comment: One commentor encourages the ED to continue evaluating manual-entry CSPR collections that duplicate information already available through EDFacts, MSIX, federal grant management systems, and other federal reporting processes.  Several remaining CSPR requirements, including certain Title III, Migrant Education Program, and Rural Education Achievement Program data elements, require significant manual compilation and validation even though the underlying information already exists in other federal systems.
Response: The Department continuously reviews all data collections for duplication of effort by our grantees. Although there are circumstances where data may appear to be the same, the methodology behind the collection is different. For example, funding counts are based on point in time which is a snapshot of number students served in a year. But data collected in CSPR is about total number of students served over the course of a program year.
Comment: One commentor encourages the Department to continue evaluating manual-entry CSPR collections that duplicate information already available through EDFacts, MSIX, federal grant management systems, and other federal reporting processes.  Several remaining CSPR requirements, including certain Title III, Migrant Education Program, and Rural Education Achievement Program data elements, require significant manual compilation and validation even though the underlying information already exists in other federal systems.
Response: The Department appreciates these suggestions and will take this into consideration for future modernization efforts.