**SUPPORTING STATEMENT FOR REQUEST FOR OMB APPROVAL UNDER THE**

**PAPERWORK REDUCTION ACT**

**Personnel (In Full-Time Equivalency of Assignment) Employed To Provide
Special Education**

**and Related Services for Children with Disabilities**

A. JUSTIFICATION

> 1\. [Circumstances necessitating information collection]{.underline}.
>
> P.L. 108-446 allows the Secretary of Education to obtain data on the
> number and type of highly qualified personnel that are employed to
> provide special education and related services to children with
> disabilities served in each State. The specific legislative authority
> may be found in Section 618(a)(3). The purposes of these data are to:
> (1) assess the progress, impact, and effectiveness of State and local
> efforts to implement the legislation and (2) provide Congress and
> Federal, State, and local educational agencies with relevant
> information. These data are used for monitoring activities, for
> planning purposes, for congressional reporting requirements, and for
> dissemination 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:
>
> \(3\) on any other information that may be required by the
> Secretary.\" (P.L. 108-446 Section 618)
>
> Under IDEA 2004, for any special education teacher, the term 'highly
> qualified" has the meaning given the term in section 9101 of the
> Elementary and Secondary Education Act of 1965 (ESEA) except that such
> term also includes the requirements described in Section 602(10)(B),
> and includes the option for teachers to meet the requirements of
> Section 602(10)(C) or (D). In addition, Section 612(a)(14)(A)
> describes qualifications for related services personnel and
> paraprofessionals.
>
> States must establish and maintain qualifications "to ensure that
> personnel necessary to carry out the Act are appropriately and
> adequately prepared and trained, including that those personnel have
> the content knowledge and skills to serve children with disabilities."
> (P.L. 108-446 Section 612(a)(14)(A)) States must also "adopt a policy
> that includes a requirement that LEAs in the State take measurable
> steps to recruit, hire, train, and retain highly qualified personnel
> to provide special education and related services under this part to
> children with disabilities." (P.L. 108-446 Section 612(a)(14)(D)).
>
> This data collection will be used by States in developing State
> Personnel Development Plans required under Section 653(b)(7) of IDEA
> 2004 to receive State Personnel Development Grants.

\"(b) ELEMENTS OF STATE PERSONNEL DEVELOPMENT PLAN. -- Each State
personnel development plan under subsection (a)(2) shall --

> \(7\) describe how the State educational agency will recruit and
> retain highly qualified teachers and other qualified personnel in
> geographic areas of greatest need;..."

This data collection form provides instructions and information for
States when submitting their counts of the number of personnel employed,
the number and type of highly qualified personnel, and the number and
type of personnel not highly qualified for their position.

This collection recently has been identified as 'EDENable,' and the EDEN
data system is now able to receive submissions associated with this
collection. The upcoming school year will be the first of state data
submissions for this collection through EDEN for the purpose of
comparing with that submitted through the OSEP data collection system,
DANS.

> 2\. [Use for which the information is gathered]{.underline}.
>
> The Office of Special Education Programs (OSEP) uses the information
> collected on this form to assist in establishing programmatic
> priorities, to monitor States to ensure compliance with Federal
> statute and regulations, and to disseminate data to Congress and the
> public.
>
> These data will also be 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.
>
> 3\. [Use for 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 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 PBDMI
> is efficacious.
>
> 4\. [Efforts to identify duplication]{.underline}.
>
> The information requested does not represent any duplication in
> content, reporting, or performance requirements beyond those imposed
> under the statute. This information is available only from State
> educational agencies (SEAs) that collect it from local educational
> agencies (LEAs) and intermediate educational units.
>
> 5\. [Small businesses]{.underline}.
>
> The information requested does not involve the collection of
> information from entities classified as small organizations.
>
> 6\. [Consequence 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 and the public on
> the following...\"
>
> 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 changes needed
> to: 1) collect data on highly qualified personnel; 2) eliminate some
> data elements no longer needed by OSEP; 3) align the related services
> categories with those of IDEA 2004 (see Section 602(26) for a list of
> these related service categories); and 4) respond to comments received
> from States through several vehicles on this collection. OSEP holds an
> annual conference of State Part B data managers that is routinely
> attended by data managers and other staff involved in the data
> collection from the States and the Outlying Areas. The conference is
> also attended by ED staff and staff from the Federal and Regional
> Resource Centers and National Association of State Directors of
> Special Education. Where practical and consistent with programmatic
> needs and legislative reporting requirements, OSEP incorporates their
> suggestions for modifications to the data collection form. OSEP
> receives continuous feedback on data issues through this meeting, as
> well as through twice yearly meetings with the Special Education
> Subcommittee of the Education Information Management Advisory
> Consortium (EIMAC) of the Chief State School Officers.

**OSEP's Responses Comments**

1.  *Why does OSEP collect the personnel data? There is no statutory
    basis for this collection and the data are reported under NCLB.
    (Comment 1082)*

> Section 618(a)(3) of IDEA gives OSEP the authority to collect the
> personnel data. OSEP uses the data about special education teachers
> for two of it Government Performance and Results Act (GPRA)
> indicators. Currently, these indicators are:

-   The number of states with at least 90 percent of special education
    teachers of children ages 6 through 21 with disabilities fully
    certified the areas in which they are teaching

-   The number of special education teachers who teach core academic
    subjects that are highly qualified, consistent with NCLB.

-   The number of states with at least 90 percent of preschool special
    education teachers fully certified in the areas in which they are
    teaching

> It is expected that this data collection will be used by States in
> developing State Personnel Development Plans required under Section
> 653(b)(7) of to receive State Personnel Development Grants. The
> related services personnel data are used by professional organizations
> and institutions of higher education.

2.  *Why are teachers reported according to the age of children (3-5,
    6-21) rather than whether they teach preschool or regular school?
    (Comment 1082)*

> The age groupings (3-5 and 6-21) used by OSEP reflect the age
> groupings in IDEA. Section 619 of IDEA provides services to children
> ages 3 through 5 years of age.

3.  *Why is OSEP collecting information about highly qualified preschool
    teachers? (Comment 1082)*

> OSEP is collecting data about the highly qualified status of teachers
> of children ages 3 through 5 with disabilities because, according to
> the definition of highly qualified in Section 602 of IDEA, for any
> special education teacher the term highly qualified has the meaning
> given the term in section 9101 of the Elementary and Secondary
> Education Act of 1965. Therefore, where that definition applies to
> teachers of children ages 3 through 5 with disabilities it applies to
> the personnel reported on this form. However, as indicated on page 3
> of the data collection instructions, if teachers and paraprofessionals
> who work with children ages 3 through 5 are not included in the
> State's definition of highly qualified, states should report these
> personnel as highly qualified if they meet the definition of fully
> certified provided in the instructions for Section C.

4.  *What are the specific criteria that pre-school teachers must meet
    for highly qualified status? The form should include specific
    language defining these requirements. (Comment 2994)*

> Where a state's definition of highly qualified includes teachers of
> children ages 3 through 5, the requirements are the same as for
> teachers of older children. Where a state's definition of highly
> qualified does not include teachers of children ages 3 through 5,
> states should use the definition of fully-certified provided in the
> instructions for Section C.

5.  *How should states report personnel who are highly qualified to
    teach some subjects but not others? The forms should include
    specific language defining these requirements (Comment 1082)*

> Special education teachers must meet highly qualified requirements in
> every core academic subject teach. See the definition of highly
> qualified in Section 602(10)(D) of IDEA. If the teacher is not highly
> qualified to teach all of the subjects he or she teaches, then that
> teacher should be reported as not highly qualified.

6.  *Rather than highly qualified v. non highly qualified, why doesn't
    OSEP collect teacher data according to whether the teacher met the
    special ed endorsement requirements or whether they met the core
    content area requirements? (Comment 2984)*

> Collection of additional categories regarding endorsement and core
> content requirements would place more burden on states. OSEP is
> collecting the teacher data required for GPRA.

7.  *Why doesn't OSEP delay implementation of the revised data
    collection until final regulations on highly qualified are
    available? Delay would also give states time to revise their data
    collection systems (Comments 2984, 2987, and 3046)*

> OSEP collects teacher qualification data to meet one of its GPRA
> requirements. The 2004 amendments to IDEA are now in effect.
> Therefore, OSEP will begin reporting on highly qualified status
> accordingly. Note: under IDEA, for any special education teacher, the
> term 'highly qualified' has the meaning given the term in Section
> 9101(23) of the Elementary and Secondary Education Act of 1965 (ESEA)
> except that such term also includes the requirements described in
> Section 602(10)(B), and includes the option for teachers to meet the
> requirements of Section 602(10)(C) or (D).

8.  *Do the highly qualified requirements apply to all paraprofessionals
    or only to those in Title 1 schools? If only Title 1, how should
    paraprofessionals not in Title 1 schools be reported? The form
    should include specific language addressing these questions.
    (Comment 2984)*

Section 612(a)(14)(A) of IDEA includes qualifications for
paraprofessionals that allow paraprofessionals and assistants who are
appropriately trained and supervised under state law, regulation or
written policy to be used to provide special education and related
services to children with disabilities. There is also no mention of
Title 1 in Section 612 of IDEA.

9.  *Why doesn't OSEP's definition of interpreter include cued speech
    interpreters and oral interpreters? (Comment 3052)*

> As appropriate, the definitions on this form will be updated to match
> the regulations when they are finalized. Assuming the definitions in
> §300.34 of the draft regulations become final, cued language and oral
> transliteration will be included in the definition of interpreters.

10. *Which paraprofessionals should be reported on this table? That is,
    what work types of work assignments are relevant? The form should
    include specific language addressing this question. (Comment 3052)*

> As defined on page 4 of the instructions, the term paraprofessional
> includes employees who provide instructional support, including those
> who: (1) provide one-on-one tutoring if such tutoring is scheduled at
> a time when a student would not otherwise receive instruction from a
> teacher, (2) assist with classroom management, such as organizing
> instructional and other materials, (3) provide instructional
> assistance in a computer laboratory, (4) conduct parental involvement
> activities, (5) provide support in a library or media center, (6) act
> as a translator, or (7) provide instructional support services under
> the direct supervision of a teacher. This definition comes from
> Section 1119(g)(2) of the Elementary and Secondary Education Act of
> 1965.

11. *Why isn't the category speech pathologist labeled speech-language
    pathologist? (Comment 3052)*

> OSEP will revise the category label to speech-language pathologist to
> match the term as it appears in the definition of related services in
> IDEA (Section 602(26)).

12. *Why isn't the psychologist category labeled school psychologist?
    (Comment 3052)*

> The personnel category labels come from the definition of related
> services in IDEA. That definition refers to psychological services,
> not just those provided by a school psychologist. Therefore, the label
> will not be changed.

13. *Are the categories highly qualified and not highly qualified the
    same as employed fully certified and employed not fully certified?
    If not, how are they different? (Comment 3052)*

> No, categories highly qualified and fully certified are not the same.
> The changes to the personnel data collection form are more than a
> re-labeling of categories. Under IDEA, for any special education
> teacher, the term 'highly qualified" has the meaning given the term in
> section 9101 of the Elementary and Secondary Education Act of 1965
> (ESEA) except that such term also includes the requirements described
> in Section 602(10)(B), and includes the option for teachers to meet
> the requirements of Section 602(10)(C) or (D).

14. *Why did OSEP eliminate some of the related personnel categories?
    (Comment 3052)*

> The related services personnel categories included in the revised
> personnel data collection are those categories included in IDEA's
> definition of related services (Section 602(26)). Related services
> personnel categories not included in this definition were removed from
> the data collection form.

15. *What are the definitions for the new related services personnel
    categories? What types of work assignments fall into each? (Comment
    3052)*

> There is only one new related services personnel category (orientation
> and mobility specialists) and one expanded category (diagnostic and
> evaluation staff was expanded to include medical services for
> diagnostic and evaluation purposes and school nursing services). We
> expect the definitions of both of these categories to be based on the
> definitions in §300.34 of the regulations.

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

### SEC. 602. DEFINITIONS.

> Except as otherwise provided, in this title:
>
> \(10\) HIGHLY QUALIFIED-
>
> \(A\) IN GENERAL- For any special education teacher, the term highly
> qualified\' has the meaning given the term in section 9101 of the
> Elementary and Secondary Education Act of 1965, except that such term
> also\--
>
> \(i\) includes the requirements described in subparagraph (B); and
>
> \(ii\) includes the option for teachers to meet the requirements of
> section 9101 of such Act by meeting the requirements of subparagraph
> (C) or (D).
>
> \(B\) REQUIREMENTS FOR SPECIAL EDUCATION TEACHERS- When used with
> respect to any public elementary school or secondary school special
> education teacher teaching in a State, such term means that\--
>
> \(i\) the teacher has obtained full State certification as a special
> education teacher (including certification obtained through
> alternative routes to certification), or passed the State special
> education teacher licensing examination, and holds a license to teach
> in the State as a special education teacher, except that when used
> with respect to any teacher teaching in a public charter school, the
> term means that the teacher meets the requirements set forth in the
> State\'s public charter school law;
>
> \(ii\) the teacher has not had special education certification or
> licensure requirements waived on an emergency, temporary, or
> provisional basis; and
>
> \(iii\) the teacher holds at least a bachelor\'s degree.
>
> \(C\) SPECIAL EDUCATION TEACHERS TEACHING TO ALTERNATE ACHIEVEMENT
> STANDARDS- When used with respect to a special education teacher who
> teaches core academic subjects exclusively to children who are
> assessed against alternate achievement standards established under the
> regulations promulgated under section 1111(b)(1) of the Elementary and
> Secondary Education Act of 1965, such term means the teacher, whether
> new or not new to the profession, may either\--
>
> \(i\) meet the applicable requirements of section 9101 of such Act for
> any elementary, middle, or secondary school teacher who is new or not
> new to the profession; or
>
> \(ii\) meet the requirements of subparagraph (B) or (C) of section
> 9101(23) of such Act as applied to an elementary school teacher, or,
> in the case of instruction above the elementary level, has subject
> matter knowledge appropriate to the level of instruction being
> provided, as determined by the State, needed to effectively teach to
> those standards.
>
> \(D\) SPECIAL EDUCATION TEACHERS TEACHING MULTIPLE SUBJECTS- When used
> with respect to a special education teacher who teaches 2 or more core
> academic subjects exclusively to children with disabilities, such term
> means that the teacher may either\--
>
> \(i\) meet the applicable requirements of section 9101 of the
> Elementary and Secondary Education Act of 1965 for any elementary,
> middle, or secondary school teacher who is new or not new to the
> profession;
>
> \(ii\) in the case of a teacher who is not new to the profession,
> demonstrate competence in all the core academic subjects in which the
> teacher teaches in the same manner as is required for an elementary,
> middle, or secondary school teacher who is not new to the profession
> under section 9101(23)(C)(ii) of such Act, which may include a single,
> high objective uniform State standard of evaluation covering multiple
> subjects; or
>
> \(iii\) in the case of a new special education teacher who teaches
> multiple subjects and who is highly qualified in mathematics, language
> arts, or science, demonstrate competence in the other core academic
> subjects in which the teacher teaches in the same manner as is
> required for an elementary, middle, or secondary school teacher under
> section 9101(23)(C)(ii) of such Act, which may include a single, high
> objective uniform State standard of evaluation covering multiple
> subjects, not later than 2 years after the date of employment.
>
> \(E\) RULE OF CONSTRUCTION- Notwithstanding any other individual right
> of action that a parent or student may maintain under this part,
> nothing in this section or part shall be construed to create a right
> of action on behalf of an individual student or class of students for
> the failure of a particular State educational agency or local
> educational agency employee to be highly qualified.
>
> \(F\) DEFINITION FOR PURPOSES OF THE ESEA- A teacher who is highly
> qualified under this paragraph shall be considered highly qualified
> for purposes of the Elementary and Secondary Education Act of 1965.

### SEC. 602. DEFINITIONS.

> Except as otherwise provided, in this title:
>
> \(26\) RELATED SERVICES-
>
> \(A\) IN GENERAL- The term \`related services\' means transportation,
> and such developmental, corrective, and other supportive services
> (including speech-language pathology and audiology services,
> interpreting services, psychological services, physical and
> occupational therapy, recreation, including therapeutic recreation,
> social work services, school nurse services designed to enable a child
> with a disability to receive a free appropriate public education as
> described in the individualized education program of the child,
> counseling services, including rehabilitation counseling, orientation
> and mobility services, and medical services, except that such medical
> services shall be for diagnostic and evaluation purposes only) as may
> be required to assist a child with a disability to benefit from
> special education, and includes the early identification and
> assessment of disabling conditions in children.
>
> \(B\) EXCEPTION- The term does not include a medical device that is
> surgically implanted, or the replacement of such device.

### SEC. 612. STATE ELIGIBILITY.

> \(a\) IN GENERAL- A State is eligible for assistance under this part
> for a fiscal year if the State submits a plan that provides assurances
> to the Secretary that the State has in effect policies and procedures
> to ensure that the State meets each of the following conditions:
>
> \(14\) PERSONNEL QUALIFICATIONS-
>
> \(A\) IN GENERAL- The State educational agency has established and
> maintains qualifications to ensure that personnel necessary to carry
> out this part are appropriately and adequately prepared and trained,
> including that those personnel have the content knowledge and skills
> to serve children with disabilities.

### 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:
>
> \(3\) Any other information that may be required by the Secretary.

SEC. 653. APPLICATIONS.

> \(b\) ELEMENTS OF STATE PERSONNEL DEVELOPMENT PLAN- Each State
> personnel development plan under subsection (a)(2) shall---
>
> \(7\) describe how the State educational agency will recruit and
> retain highly qualified teachers and other qualified personnel in
> geographic areas of greatest need;

**ESEA Citations Referenced in OSEP's Responses**

SEC. 1119. QUALIFICATIONS FOR TEACHERS AND PARAPROFESSIONALS.

> \(g\) DUTIES OF PARAPROFESSIONALS.---
>
> \(2\) RESPONSIBILITIES PARAPROFESSIONALS MAY BE
>
> ASSIGNED.---A paraprofessional described in paragraph (1) may
>
> be assigned---
>
> \(A\) to provide one-on-one tutoring for eligible students,
>
> if the tutoring is scheduled at a time when a student
>
> would not otherwise receive instruction from a teacher;
>
> \(B\) to assist with classroom management, such as
>
> organizing instructional and other materials;
>
> \(C\) to provide assistance in a computer laboratory;
>
> \(D\) to conduct parental involvement activities;
>
> \(E\) to provide support in a library or media center;
>
> \(F\) to act as a translator; or
>
> \(G\) to provide instructional services to students in
>
> accordance with paragraph (3).

SEC. 9101. DEFINITIONS.

> \(23\) HIGHLY QUALIFIED.---The term 'highly qualified'---
>
> \(A\) when used with respect to any public elementary
>
> school or secondary school teacher teaching in a State,
>
> means that---
>
> \(i\) the teacher has obtained full State certification
>
> as a teacher (including certification obtained through
>
> alternative routes to certification) or passed the State
>
> teacher licensing examination, and holds a license to
>
> teach in such State, except that when used with respect
>
> to any teacher teaching in a public charter school,
>
> the term means that the teacher meets the requirements
>
> set forth in the State's public charter school
>
> law; and
>
> \(ii\) the teacher has not had certification or licensure
>
> requirements waived on an emergency, temporary,
>
> or provisional basis;
>
> \(B\) when used with respect to---
>
> \(i\) an elementary school teacher who is new to
>
> the profession, means that the teacher---
>
> \(I\) holds at least a bachelor's degree; and
>
> \(II\) has demonstrated, by passing a rigorous
>
> State test, subject knowledge and teaching skills
>
> in reading, writing, mathematics, and other areas
>
> of the basic elementary school curriculum (which
>
> may consist of passing a State-required certification
>
> or licensing test or tests in reading, writing,
>
> mathematics, and other areas of the basic
>
> elementary school curriculum); or
>
> \(ii\) a middle or secondary school teacher who is
>
> new to the profession, means that the teacher holds
>
> at least a bachelor's degree and has demonstrated a
>
> high level of competency in each of the academic subjects
>
> in which the teacher teaches by---
>
> \(I\) passing a rigorous State academic subject
>
> test in each of the academic subjects in which
>
> the teacher teaches (which may consist of a passing
>
> level of performance on a State-required certification
>
> or licensing test or tests in each of the
>
> academic subjects in which the teacher teaches);
>
> or
>
> \(II\) successful completion, in each of the academic
>
> subjects in which the teacher teaches, of
>
> an academic major, a graduate degree, coursework
>
> equivalent to an undergraduate academic major,
>
> or advanced certification or credentialing; and
>
> \(C\) when used with respect to an elementary, middle,
>
> or secondary school teacher who is not new to the profession,
>
> means that the teacher holds at least a bachelor's
>
> degree and---
>
> \(i\) has met the applicable standard in clause (i)
>
> or (ii) of subparagraph (B), which includes an option
>
> for a test; or
>
> \(ii\) demonstrates competence in all the academic
>
> subjects in which the teacher teaches based on a high
>
> objective uniform State standard of evaluation that---
>
> \(I\) is set by the State for both grade appropriate
>
> academic subject matter knowledge and
>
> teaching skills;
>
> \(II\) is aligned with challenging State academic
>
> content and student academic achievement
>
> standards and developed in consultation with core
>
> content specialists, teachers, principals, and school
>
> administrators;
>
> \(III\) provides objective, coherent information
>
> about the teacher's attainment of core content
>
> knowledge in the academic subjects in which a
>
> teacher teaches;
>
> \(IV\) is applied uniformly to all teachers in
>
> the same academic subject and the same grade
>
> level throughout the State;
>
> \(V\) takes into consideration, but not be based
>
> primarily on, the time the teacher has been
>
> teaching in the academic subject;
>
> \(VI\) is made available to the public upon
>
> request; and
>
> \(VII\) may involve multiple, objective measures
>
> of teacher competency.
>
> 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. However,
> no individually identifiable information is requested.
>
> 11\. [Questions of a sensitive nature]{.underline}.
>
> There are no questions or requirements 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, the available information about State data collection
systems, and consultation with representatives of several State
agencies. Note that it is not possible to estimate an exact burden
amount for each State because a variety of factors influence the
collection of these data, such as the variation in the number of LEAs in
each State, the number of personnel in the system, and the
sophistication of the personnel data system. In making the following
estimates, we used different burdens based on whether SEAs use
computerized personnel data systems to collect these data. Fewer States
use computerized data systems to collect the personnel data than use
individualized record data systems to collect the student data they
report to OSEP.

> In order to calculate burden, OSEP first estimated the number of hours
> required per State and per LEA for computerized and non-computerized
> systems. 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 State burden). OSEP then 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 2.5 hours per State agency or
150 hours total. The estimated average LEA burden is 0.5 hours or 130
hours of LEA burden per State. The total burden estimate is 7,950 hours.

+-----------------------------+------------+------------+------------+
| **Number of\                | **SEA      | **LEA      | **Total\   |
| Respondents**               | Burden     | Burden     | Bu         |
|                             | Hours**    | Hours**    | rden**[^1] |
+-----------------------------+------------+------------+------------+
| 32 States with Individual   | 2          | .4         |            |
| Record\                     |            |            |            |
| Systems                     |            |            |            |
+-----------------------------+------------+------------+------------+
| 28. States without          | 3          | .6         |            |
|     Individual Record       |            |            |            |
|     Systems                 |            |            |            |
+-----------------------------+------------+------------+------------+
| 60 States[^2]               | 2.5\       | .5\        | 7,950      |
|                             | (Avg.)     | (Avg.)     |            |
+-----------------------------+------------+------------+------------+

> OSEP estimated respondent costs as \$20 per hour. As indicated above,
> the estimated total number of burden hours is 7,950. Therefore, the
> total estimated cost to the respondents is \$159,000.
>
> 13\. [Estimate of costs to respondent]{.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 form.

+---------------------------------------------+------------------------+
| Copying:                                    | 50                     |
|                                             |                        |
| Mailing:                                    | 300                    |
|                                             |                        |
| Staff:                                      | 2,500                  |
|                                             |                        |
| Contractor Data Services:                   | [16,000]{.underline}   |
|                                             |                        |
|                                             | \$18,850               |
+---------------------------------------------+------------------------+

> 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 are no changes or adjustments to the annual reporting and record
> keeping hour burden.
>
> 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 for distribution are the
> Secretary\'s Annual Report to Congress\
> (P.L. 108-446, Section 664(c)(2) and through publication of these data
> on the Internet (IDEAdata.org). OSEP will use these data to measure
> progress under the performance indicators established by OSEP under
> the Government Performance and Results Act for special education
> grants to States and preschool grants. Occasionally, the data are
> summarized and presented at conferences and in ad hoc reports or
> articles submitted for publication. This information will also be used
> by OSEP for purposes of monitoring and focusing discretionary
> activities.
>
> 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 the number and type of personnel
> employed and contracted. 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.