May 19, 2003

Michael W. Moyer

Executive Director

National Wrestling Coaches Association

1976 Auction Road

Manheim, PA 17545

Eric Pearson

College Sports Council

1825 I Street, NW Suite 400

Washington, DC 20006

Dear Mr. Moyer and Mr. Pearson:

This letter is in response to your February 26, 2003 Information Quality
Request (Feb. 26 letter) regarding "Open to All: Title IX at Thirty:
Report of the Secretary's Commission on Opportunity in Athletics." We
have carefully reviewed your correction request and the reasons for the
correction. For the reasons stated below, we have determined that no
correction is warranted.

In your request, you indicate that the Commission's Report does not
comply with the Department's Information Quality (IQ) Guidelines because
it (1) fails to document the shortcomings and limitations of data cited
in the report, (2) fails to use representative or complete survey
populations, and (3) fails to identify conflicting information and to
caution against inappropriate conclusions. In particular, you indicate
that the Commission's Report "relies" on General Accounting Office (GAO)
reports from December 2000 and March 2001, that do not account for
schools that have joined the NCAA or NAIA since 1981, or schools that
may have joined the NCAA or NAIA after the Association for
Intercollegiate Athletics for Women (AIAW) disbanded in 1983. Taken
together, you indicate that these inaccuracies overstate the gains in
women's sports opportunities since 1981 and understate the losses in
men's sports opportunities over the same period. You ask that the
Department either conduct or commission a demographic analysis of
changes in men's and women's sports opportunities, or at least qualify
the Commission report to note the shortcoming of this data, either
through a revised publication or

errata sheets.

The IQ Guidelines require that for third-party data, the Department
"identify the source of the information and any shortcoming or
limitations of the data if we rely upon it for decision-making
purposes." (emphasis added) Guidelines at 6. In this case, the GAO
reports are only two of the many sources of information that was
collected by the Commission as it developed recommendations for the
Secretary. The Commission's Report uses the data from the GAO reports
essentially as background information on the changes in athletic
participation by men and women since Title IX was enacted. The substance
and cumulative weight of the citations to the GAO data in the
Commission's Report is, at most, a general statement in support of Title
IX and its gains for women's sports, which is something you do not
contest in your February 26, 2003 letter. ("We dispute the foregoing
data not to deny the great gains

Page 2 -- Messrs. Moyer and Pearson

in women's sports, but to stress that women made these gains before the
Three Part Test was issued in December 1979." Feb. 26 letter at 3.)

The Commission's Report also examines and presents other data that place
the data from the GAO reports in a broader context. For example, in the
"Findings" section, the Commission's Report cites numbers on
participation provided by Jerome Kravitz, a consultant and professor at
Howard University, as well as testimony from Corey Bray of the NCAA, who
commented on overall participation of men and women in NCAA championship
sports. As explained on page 24 of the Report, "\[t\]he Commission found
that it is extremely difficult to obtain a set of data that is accepted
by all parties." Thus the Commission's Report, taken in its totality,
presents data from several perspectives on the opportunities for men and
women to participate in sports both before and after Title IX was
enacted. The data in the GAO reports were only some of the information
that was collected and reported, and do not, in and of themselves, form
the basis for the recommendations of the Commission.

In sum, no correction to the Commission Report is warranted because the
Commission did not rely on the GAO report data in making its
recommendations to the Department.

## Procedures for Appeal

If you are not satisfied with this decision, you may appeal to the
Department's Chief Information Officer within thirty (30) calendar days
of receipt of the Department's decision. This administrative appeal must
include a copy of the initial request, a copy of the Department's
decision, and a letter explaining why you believe the Department's
decision was inadequate, incomplete or in error.

This appeal information should be provided to the Department's Chief
Information Officer (OCIO) at the following address:

The Chief Information Officer

> U.S. Department of Education
>
> Re: Information Quality Appeal
>
> Room 4082, ROB-3
>
> 400 Maryland Avenue, SW
>
> Washington, DC 20202

Sincerely,

/ s /

Arthur M. Graham

Director, Information Management