# SUPPORTING STATEMENT FOR REQUEST FOR OMB APPROVAL UNDER THE 

**PAPERWORK REDUCTION ACT**

**Report of Children with Disabilities Exiting Special Education**

A. JUSTIFICATION

> 1\. [Circumstances necessitating information collection]{.underline}.
>
> P.L. 108-446 directs the Secretary of Education to obtain data on the
> number of children with disabilities by race/ethnicity, gender, and
> limited English proficiency (LEP) status exiting special education
> each year. The specific legislative authority may be found in Section
> 618(a)(1)(A)(iv). The purposes of such data are: (1) to assess the
> progress, impact, and effectiveness of State efforts to implement the
> legislation and (2) to provide Congress and Federal, State, and local
> education agencies with relevant information. These data will be used
> for monitoring activities, planning purposes, congressional reporting
> requirements, and dissemination of data to individuals and groups.
>
> Legislative authority requires that:
>
> "(a) IN GENERAL- Each State that receives assistance under this part,
> and the Secretary of the Interior, shall provide data each year to the
> Secretary of Education and the public on the following:
>
> (1)(A) The number and percentage of children with disabilities, by
> race, ethnicity, limited English proficiency status, gender, and
> disability category, who are in each of the following separate
> categories:
>
> \(iv\) For each year of age from age 14 through 21, stopped receiving
> special education and related services because of program completion
> (including graduation with a regular secondary school diploma), or
> other reasons, and the reasons why those children stopped receiving
> special education and related services" (P.L. 108-446, Section 618).
>
> The reporting form collects a count of the number of students, ages 14
> through 21, who exit special education during a 12-month reporting
> period, tabulated by the student's age, disability category, and basis
> of exit. At the request of States, the tabulation by age includes an
> optional count of students older than 21 years of age who exited
> special education during the data collection year. For students ages
> 14 through 21, the form also collects cross-tabulations of the
> student's race/ethnicity and basis of exit, gender and basis of exit,
> and LEP status and basis of exit.
>
> The disability categories used on the form are listed in Section
> 302(3)(A)(i) of P.L. 108-446 and are defined in the OSEP IDEA, Part B
> Data Dictionary (February 2005). The LEP status categories used on the
> form are based on the definition of limited English proficient in the
> Elementary and Secondary Education Act, 20 USC Section 7801(A)(25).
> The race/ethnicity categories are the categories defined by OMB in
> 1997. However, children can only be reported in a single racial/ethnic
> category. The Office of Special Education Programs (OSEP) is actively
> working with other offices within the Department of Education (ED) to
> determine what categories will be used for reporting aggregated data
> and anticipates that final decisions on reporting these data will be
> made soon. A draft set of categories has already been circulated. Once
> final decisions are made, the final draft categories will be
> circulated Department wide. After that, the approach will be sent to
> OMB for clearance. Until aggregate reporting categories are
> implemented, States will continue to report data using the current
> racial/ethnic categories.
>
> As indicated in the preceding paragraphs, IDEA 2004 requires each
> state to report the "percentage of children with disabilities, by
> race, ethnicity, limited English proficiency status, gender, and
> disability category, who are in" each of the reporting categories. The
> data collection grid includes cells for the required percentages;
> however, to assure cross-state comparability and minimize state
> burden, these percentages will be calculated by the data collection
> software.
>
> Through the Individuals with Disabilities Education Act, OSEP has a
> statutory requirement to collect and report this data. Some of these
> data are also used by other ED program offices. With OSEP collections
> among the longest-running collections in the Department, these
> collections were among the first to begin transitioning to EDEN, the
> centralized collection point for submission of ED data. OSEP has a
> history of involvement in the development of PBDMI/EDEN, with staff
> having participated on PBDMI review teams for several state site
> visits. Congruence analyses have been conducted over the past several
> months, as a means of confirming accuracy of state data submitted
> through EDEN with reference to the data submitted through the OSEP
> data collection system, DANS. Once sufficient congruence of the data
> is ensured, the Department approves a state's submission of the data
> through EDEN only. When the state data for this collection are
> submitted through EDEN only, the respective data then are extracted
> from the EDEN database for purposes of required annual reporting. OSEP
> anticipates that for reporting during school year 2006-07, about half
> of the states will have received approval to submit data from this
> collection through EDEN only.
>
> 2\. [Use for which the information is gathered]{.underline}.
>
> OSEP uses the information collected on this form to assist in
> establishing programmatic priorities (such as addressing the problems
> associated with high dropout rates for students with disabilities), to
> monitor States to ensure compliance with Federal statute and
> regulations, and to disseminate data to Congress and the public.
>
> These data are also used to measure progress under the performance
> indicators established by OSEP under the Government Performance and
> Results Act (P.L. 103-62) for special education grants to States and
> preschool grants. Performance objectives and indicators can be found
> in OSEP's Fiscal Year 2006 Performance Plan, and are available at
> http://www.ed.gov/about/reports/annual/2006plan/edlite-g2ideagrantstostates.html.
>
> 3\. [Use of improved information technology]{.underline}.
>
> OSEP provides States with an electronic (Excel spreadsheet) version of
> the data collection form to use when submitting data. States can
> receive and send the form via e-mail, diskette, or paper. The
> spreadsheet includes a number of data edits to improve data entry
> validity. For example, as the State enters data, the edits flag totals
> that do not equal the sum of the disaggregated counts. The use of the
> spreadsheet with built-in edits reduces the number of follow-up
> contacts with the States after the data reach Washington. The
> spreadsheet also provides space for States to comment on their data,
> such as changes in the way the State reports the data, changes in
> policy or legislation that may affect the data, or other issues the
> State believes are applicable to the data collection. At the time of
> the most recent data collection, approximately 98 percent of States
> submitted the data electronically.
>
> OSEP participated in the Performance Based Data Management Initiative
> (PBDMI) pilot to determine the feasibility of collecting these data as
> part of a department-wide consolidated data collection. However, the
> new data requirements of IDEA 2004 are not yet included in the PBDMI
> data collection system. ED expects to add all the new IDEA data
> requirements to the PBDMI system in time to collect the data for the
> 2006-07 school year. In 2008, OSEP plans to conduct a validity study
> to evaluate the completeness and accuracy of the data collected
> through PBDMI. Based on the results of these analyses, OSEP will
> decide whether collecting the 2007-08 school year data through the
> PBDMI is efficacious.
>
> 4\. [Efforts to identify duplication]{.underline}.
>
> The information collected on the form does not represent any
> duplication of paperwork, content, reporting, or performance
> requirement beyond that imposed under the statute. This information is
> available only from State educational agencies (SEAs) that in turn
> collect it from local educational agencies (LEAs).
>
> 5\. [Small businesses]{.underline}.
>
> The information requested does not involve the collection of
> information from entities classified as small businesses.
>
> 6\. [Consequences of less frequent collection]{.underline}.
>
> P.L. 108-446, Section 618(a) requires: \"Each State that receives
> assistance under this part, and the Secretary of the Interior, shall
> provide data each year to the Secretary of Education\...\"
>
> 7\. [Special circumstances]{.underline}.
>
> There are no special circumstances associated with this data
> collection.
>
> 8\. [*Federal Register* notice/consultation outside the
> agency]{.underline}.
>
> Comments will be solicited through the IDEA NPRM at the same time this
> collection is pending at OMB.
>
> Changes to this form (indicated in bold face) reflect new requirements
> under IDEA (i.e., collection of percentages) and implementation of a
> July-June reporting interval. The Special Education Subcommittee of
> the Education Information Management Advisory Consortium of the Chief
> State School Officers was consulted about these changes. Where
> practical and consistent with programmatic needs and legislative
> reporting requirements, OSEP incorporated their suggestions for
> modifications to the data collection form.

**OSEP's Responses to Comments**

1.  *Why doesn't the USDOE agree on a single definition of a graduation
    [rate]{.underline} and a single definition of a dropout rate?
    (Comment 1082)*

> This comment does not apply to this data collection form as it does
> not collect graduation or dropout rates.

2.  *Why doesn't OSEP delay implementing standard exit reporting period
    (July 1 -- June 30) to give states time to revise their data
    systems? (Comments 2984, 2987, 2994, 3052, Petska)*

> OSEP promised to standardize the reporting period as part of its
> clearance process in 2004. The plan to standardize the reporting
> period was first shared with states at the annual data meeting in
> April 2004. However, because states were not told which standard
> reporting period OSEP would use until the EIMAC meeting in the fall of
> 2004, OSEP will work with individual states on an as needed basis to
> devise plans for implementing this new requirement.

3.  *OSEP should clarify definition of dropout. Specifically, how should
    states report GED recipients? Is the student considered a dropout if
    he or she receives a GED and is still receiving services? (Comment
    3052)*

> No change was made to the exit categories or definitions currently
> approved by OMB through August 2007. These questions are covered by
> the reporting instructions. Technical assistance is also available for
> states with questions about the data collection forms. As indicated in
> the instructions, dropout is the default category for any student who
> was in special education at the start of the reporting period, is not
> in special education at the end of the reporting period, and does not
> meet the definition of any of the other exit reasons. If, at the end
> of the reporting period, the student is still receiving special
> education, then they should not be reported as an exit. In States
> where students may receive a GED without dropping out of school, that
> is they are jointly enrolled in secondary school and a GED program,
> students receiving GEDs may be reported as graduating with a diploma.
> In all other cases, GED recipients should be reported as dropouts.

4.  *Why doesn't OSEP delay implementation of the gender and LEP status
    requirements? (Comments 1975, 2987, 2994, 3037, Petska)*

> OSEP cannot delay implementation of the requirements of IDEA 2004. The
> law specifies that these requirements must be in place by July 1,
> 2005.

5.  *Why are states required to report children according to their
    gender and LEP status? (Comment 3052)*

> Reporting exiting data according to the child's gender and LEP status
> is required by Section 618(a)(1)(A) of IDEA.

**IDEA 2004 Citations Referenced in OSEP's Responses**

### SEC. 618. PROGRAM INFORMATION.

> \(a\) IN GENERAL- Each State that receives assistance under this part,
> and the Secretary of the Interior, shall provide data each year to the
> Secretary of Education and the public on the following:
>
> (1)(A) The number and percentage of children with disabilities, by
> race, ethnicity, limited English proficiency status, gender, and
> disability category, who are in each of the following separate
> categories:
>
> 9\. [Payments or gifts to respondents]{.underline}.
>
> No payments or gifts are provided to respondents for completing this
> information request.
>
> 10\. [Assurance of confidentiality]{.underline}.
>
> No assurance of confidentiality is provided to respondents.
>
> 11\. [Questions of a sensitive nature]{.underline}.
>
> There are no questions of a sensitive nature contained in the form.
>
> 12\. [Estimate of respondent burden]{.underline}.
>
> The estimate of burden is based on previous experience with the data
> collection, feedback from States during their annual meeting, the
> available information about State data collection systems, and
> consultation with representatives of several SEAs. Note that it is not
> possible to estimate an exact burden amount for each State because a
> variety of factors influence the collection, such as the variation in
> the number of LEAs in each State, the number of students served in
> each LEA, and the sophistication of the data system. In making the
> following estimates, we used different burdens based on whether SEAs
> use individual student records at the State level to collect these
> data and whether they are already using the July 1 through June 30
> reporting interval.
>
> To calculate burden, OSEP first estimated the number of hours required
> per State and per LEA for SEAs with and without individual student
> records at the State level. An average was calculated for States and
> LEAs. OSEP then calculated the total burden for all States by
> multiplying the average number of hours by 60 (60\*average SEA
> burden). Next, OSEP estimated average LEA burden. For each State, an
> average of 260 LEAs per State was used. OSEP calculated total LEA
> burden per State by multiplying 260 by the average LEA burden. They
> calculated total LEA burden by multiplying 60\*260\*average LEA
> burden.
>
> For SEAs, the estimated average burden is 11 hours per State agency or
> 660 hours total. The estimated average LEA burden is 6 hours or 1,560
> hours of LEA burden per State. The total burden estimate is 94,260
> hours. The required number of hours needed to collect and report these
> data should decline over time, however, as States put systems in place
> to collect the data according to the July-June reporting interval and
> implement individual student record systems.

+--------------------------------+-----------+-----------+-----------+
| **Number of\                   | **SEA**   | **LEA     | **Total   |
| Respondents**                  |           | Burden    | Burden    |
|                                | **Burden  | Hours**   | Ho        |
|                                | Hours**   |           | urs**[^1] |
+--------------------------------+-----------+-----------+-----------+
| Of the States with Individual  |           |           |           |
| Student Record Systems:        |           |           |           |
+--------------------------------+-----------+-----------+-----------+
| > 29 Using the July-June       | 4.5       | 3         |           |
| > Interval                     |           |           |           |
+--------------------------------+-----------+-----------+-----------+
| > 13 Not using the July-June   | 11.5      | 6         |           |
| > Interval                     |           |           |           |
+--------------------------------+-----------+-----------+-----------+
| Of the States without          |           |           |           |
| Individual Student Record      |           |           |           |
| Systems:                       |           |           |           |
+--------------------------------+-----------+-----------+-----------+
| > 10 Using the July-June       | 16        | 10        |           |
| > Interval                     |           |           |           |
+--------------------------------+-----------+-----------+-----------+
| > 8 Not using the July-June    | 26        | 15        |           |
| > Interval                     |           |           |           |
+--------------------------------+-----------+-----------+-----------+
| 60 States[^2]                  | 11        | 6         | 94,260    |
|                                |           |           |           |
|                                | (Avg.)    | (Avg.)    |           |
+--------------------------------+-----------+-----------+-----------+

> OSEP estimated respondent costs as \$20 per hour. As indicated above,
> the estimated total number of hours of burden is 94,260. Therefore,
> the estimated cost to the respondents is \$1,885,200
>
> 13\. [Estimate of cost to respondents]{.underline}.
>
> There are no additional costs other than the cost burden identified in
> 12.
>
> 14\. [Estimate of costs to the Federal Government]{.underline}.
>
> The following table represents the estimated costs to the Federal
> Government associated with the data collection.

+---------------------------------------------+------------------------+
| Copying:                                    | 50                     |
|                                             |                        |
| Mailing:                                    | 300                    |
|                                             |                        |
| Staff:                                      | 2,500                  |
|                                             |                        |
| Contractor Data Services:                   | [15,500]{.underline}   |
|                                             |                        |
|                                             | \$18,350               |
+---------------------------------------------+------------------------+

> Contractor data services include costs for updating the database and
> processing, verifying, and analyzing the data.
>
> 15\. [Reasons for program changes or adjustments]{.underline}.
>
> There is a 54,840 program change. The large increase to the annual
> reporting and record keeping hour burden is due to two factors. First,
> OSEP will implement ED Budget Service's recommendation that all States
> use the same 12-month reporting interval. Previously, each State
> defined the 12-month interval used to report these data. OSEP
> consulted with the Special Education Subcommittee of the Education
> Information Management Advisory Consortium and decided to use the
> 12-month reporting interval most commonly used by States, which is
> July 1 though June 30. Currently, 39 of the 60 States and outlying
> areas use the July-June reporting interval. The remaining 21 States
> and outlying areas that are using a different 12-month interval will
> need to put systems in place to collect the data according to the now
> required July-June reporting interval. The addition of exiting data by
> gender and LEP status, as now required under IDEA 2004 (P.L. 108-446),
> also increased the burden on States.
>
> 16\. [Plans for tabulation and publication]{.underline}.
>
> OSEP will tabulate and display the information submitted by States in
> a variety of ways. The primary vehicles of distribution are through
> the Secretary\'s Annual Report to Congress (P.L. 108-446, Section
> 664(c)(2)) and through the publication of the data on the Internet
> (IDEAdata.org). These data will be disseminated in reports prepared by
> OSEP to States and local special education personnel at regional and
> national meetings. OSEP will also use this information for purposes of
> monitoring and GPRA performance reports, focusing discretionary
> activities, and suggesting topics for model demonstration projects.
> Occasionally, the data are summarized and presented at conferences and
> in ad hoc reports or articles submitted for publication.
>
> 17\. [Display of OMB expiration date]{.underline}.
>
> The OMB expiration date will be displayed on the form.
>
> 18\. [Exceptions to the certification statement]{.underline}.
>
> There are no exceptions to the certification statement.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

> States may use sampling to obtain data for this form. If sampling is
> to be used, the State must submit its sampling plan to OSEP by
> September 1 of the collection year (the September prior to the child
> count). The State's sampling plan must be approved by OSEP prior to
> data collection.

[^1]: Total burden is based on averages rounded to the nearest hour.

[^2]: 60 States and Outlying Areas refers to: 50 States, District of
    Columbia, Puerto Rico, Virgin Islands, American Samoa, Guam,
    Marshall Islands, Micronesia, Northern Marianas, Palau, and the
    Bureau of Indian Affairs.