**Comprehensive Cover Memo**

  ---------- -------------------------------- ----------------------------
  TO:        Bridget Dooling, OMB Desk        
             Officer                          

  THRU:      Sheila Carey, RIMS/ED            

  FROM:      Lisa Holden-Pitt, OSEP/OSERS/ED  

                                              September 12, 2008

  SUBJECT:   Blanket OMB 83C Request          
  ---------- -------------------------------- ----------------------------

**Under this cover, OSEP requests OMB approval for two types of
adjustment to data collection forms currently cleared for a three-year
period. The forms are currently cleared for use through either August
(for some) or November (for others), 2009.**

**Justification for the request:**

The Change Worksheets and associated data collection forms that
accompany this blanket memo are in follow up to the advance notice of
this request conveyed to OMB via email exchange through Sheila Carey a
few months ago. At that time, you okayed this approach to obtaining the
necessary approvals.

The adjustments found among this set of collection forms are of two
basic types:

1.  Instruction edits toward clarifying instructions or term
    definitions, or (in one instance, #1820-0659\*) isolating a data
    element reported in the currently-approved forms.

\*On the proposed Table 6, 1820-0659, for SY 2008-09, the report of
'Medical Emergencies' is

entered as a numeric data element, rather than as a comment associated
with 'other reasons' for

not being assessed, on the data submission. The numeric entry allows for
more accurate and

more easily tabulated data. And this adjustment is consistent with
parallel actions being taken by

EDFacts and OESE (NCLB) for assessment data reporting.

2.  Form adjustments to accommodate data intake and reporting of State
    data in accordance with the Department's Final Guidance on
    Maintaining, Collecting and Reporting Racial and Ethnic Data to the
    US Department of Education in the Federal Register (October 2007),
    which we reference as the '*new guidance*.' States have been
    informed that they may, as early as for the SY 2008-09 data report
    (but no later than for SY 2010-11 data), convert from the
    traditional five (5) to the new seven (7) aggregate categories of
    race/ethnicity data reporting, **[if they are collecting and
    aggregating their data as specified in the new
    guidance]{.underline}.** Therefore, we must modify the data
    collection forms that collect race and ethnicity data, to permit the
    new levels of reporting. As an umbrella package associated with this
    change already has been cleared at the Department level, we now are
    simply providing for your review the forms displaying the necessary
    adjustments. Since we anticipate that States will vary with respect
    to the year in which they convert to application of the *new
    guidance*, we must continue to make available the traditional form
    (which now carries the suffix 'RE5') while adding the alternate form
    (which we have labeled with the same table name and number, but with
    'RE7' as the suffix. You will note that text pertaining to the new
    guidance has been added to each of the two companion forms
    associated with the tables affected -- though the insert language
    differs between RE5 and RE7.

To the best of my knowledge, the proposed adjustments to the IDEA data
collection forms in this set are consistent with existing or requested
State data reporting requirements under NCLB and for companion data
submitted to ED*Facts.* The proposed changes to the forms are not in
response to regulations, but instead to improve submitted data quality
by better specifying the instructions. Refer to the chart below to see
which of the two types of form changes pertain to each of the IDEA
Section 618 data collections listed. None of the adjustments to data
reporting forms is expected to result in any appreciable increase in
reporting burden. Over time, it is possible that the clarifications will
result in a slight reduction in the reporting burden. However, that it
unlikely to occur during this final year of OMB clearance for these
forms.

OMB response to this request for approval of indicated (bold print)
changes in the accompanying collection forms would be much appreciated
by September 19, 2008, as OSEP would like to distribute the approved
forms to States by the end of this month. As I will be out of the office
until September 15^th^, please contact Kelly.Worthington@ed.gov (OSEP --
phone 202-245-7581), who may consult with Carol Bruce (data contractor),
or clarification for further information regarding this package.

# Part B forms

1820-0043 -- Report of Children with Disabilities Receiving Special
Education Under Part B of the Individuals with Disabilities Education
Act

1820-0518 -- Personnel Employed to Provide Special Education and Related
Services for Children with Disabilities.

1820-0517 -- Part B, Individuals with Disabilities Education Act

Implementation of FAPE Requirements

1820-0521 -- Report of Children with Disabilities Exiting Special
Education During the School Year.

1820-0621 -- Report of Children with Disabilities Subject to
Disciplinary Removal.

1820-0659 -- Report of the Participation and Performance of Students
with Disabilities on State Assessments by Content Area, Grade, and Type
of Assessment.

1820-0677 -- Report of Dispute Resolution Under Part B of the
Individuals with Disabilities Education Act.

# Part C Section 618 collection forms

1820-0557 (Tables 1, 2, and 3) -- Report of Infants and Toddlers
Receiving Early Intervention Services and of Program Settings Where
Services are Provided in Accordance with Part C, and Report on Infants
and Toddlers Exiting Part C.

1820-0678 -- Report of Dispute Resolution Under Part C of the
Individuals with Disabilities Education Act: Complaints, Mediations, and
Due Process Hearings.

*Chart indicating the type(s) of change made to the data collection
forms under this cover.*

+------+--------+----------------------------+----------+-------------+
|      |        |                            |          |             |
+------+--------+----------------------------+----------+-------------+
| *    | *      | **Form Name**              | **Instr  | **          |
| *OMB | *Table |                            | uctional | Alterations |
| Form | Numbe  |                            | Clarific | re new R/E  |
| \#** | r(s)** |                            | ations** | guidance**  |
+------+--------+----------------------------+----------+-------------+
| 1    | *Part  | Report of Children with    | X        | X           |
| 820- | B*     | Disabilities Receiving     |          |             |
| 0043 |        | Special Education Under    |          |             |
|      | T1-RE5 | Part B of the Individuals  |          |             |
|      |        | with Disabilities          |          |             |
|      | T1-RE7 | Education Act              |          |             |
+------+--------+----------------------------+----------+-------------+
| 1    | *Part  | Personnel Employed to      | X        |             |
| 820- | B*     | Provide Special Education  |          |             |
| 0518 |        | and Related Services for   |          |             |
|      | T2     | Children with              |          |             |
|      |        | Disabilities.              |          |             |
+------+--------+----------------------------+----------+-------------+
| 1    | *Part  | Part B, Individuals with   |          | X           |
| 820- | B*     | Disabilities Education Act |          |             |
| 0517 |        | Implementation of FAPE     |          |             |
|      | T3-RE5 | Requirements               |          |             |
|      |        |                            |          |             |
|      | T3-RE7 |                            |          |             |
+------+--------+----------------------------+----------+-------------+
| 1    | *Part  | Report of Children with    |          | X           |
| 820- | B*     | Disabilities Exiting       |          |             |
| 0521 |        | Special Education During   |          |             |
|      | T4-RE5 | the School Year.           |          |             |
|      |        |                            |          |             |
|      | T4-RE7 |                            |          |             |
+------+--------+----------------------------+----------+-------------+
| 1    | *Part  | Report of Children with    |          | X           |
| 820- | B*     | Disabilities Subject to    |          |             |
| 0621 |        | Disciplinary Removal.      |          |             |
|      | T5-RE5 |                            |          |             |
|      |        |                            |          |             |
|      | T5-RE7 |                            |          |             |
+------+--------+----------------------------+----------+-------------+
| 1    | *Part  | Report of the              | X        |             |
| 820- | B*     | Participation and          |          |             |
| 0659 |        | Performance of Students    |          |             |
|      | T6     | with Disabilities on State |          |             |
|      |        | Assessments by Content     |          |             |
|      |        | Area, Grade, and Type of   |          |             |
|      |        | Assessment.                |          |             |
+------+--------+----------------------------+----------+-------------+
| 1    | *Part  | Report of Dispute          | X        |             |
| 820- | B*     | Resolution Under Part B of |          |             |
| 0677 |        | the Individuals with       |          |             |
|      | T7     | Disabilities Education     |          |             |
|      |        | Act.                       |          |             |
+------+--------+----------------------------+----------+-------------+
| 1    | *Part  | Report of Infants and      | X        | X           |
| 820- | C*     | Toddlers Receiving Early   |          |             |
| 0557 |        | Intervention Services and  |          | X           |
|      | T1-RE5 | of Program Settings Where  |          |             |
|      |        | Services are Provided in   |          | X           |
|      | T1-RE7 | Accordance with Part C,    |          |             |
|      |        | and Report on Infants and  |          |             |
|      | T2-RE5 | Toddlers Exiting Part C.   |          |             |
|      |        |                            |          |             |
|      | T2-RE7 |                            |          |             |
|      |        |                            |          |             |
|      | T3-RE5 |                            |          |             |
|      |        |                            |          |             |
|      | T3-RE7 |                            |          |             |
+------+--------+----------------------------+----------+-------------+
| 1    | *Part  | Report of Dispute          | X        |             |
| 820- | C*     | Resolution Under Part C of |          |             |
| 0678 |        | the Individuals with       |          |             |
|      | T4     | Disabilities Education     |          |             |
|      |        | Act: Complaints,           |          |             |
|      |        | Mediations, and Due        |          |             |
|      |        | Process Hearings.          |          |             |
+------+--------+----------------------------+----------+-------------+