PAPERWORK REDUCTION ACT SUBMISSION SUPPORTING STATEMENT

Mandatory Civil Rights Data Collection

November 2013

Attachment B

CRDC Data Set for School 

Years 2013–14 and 2015–16:

Response to Public Comment
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-1

TABLE OF CONTENTS

Table of Contents.............................................................................................................................1

Introduction......................................................................................................................................2

I. Overview of Proposed Significant Revisions That Respond to Recurring Comments ..........3

II. Comments about Survey Scope and Administration ..............................................................6

Civil Rights Purpose of Data Collection............................................................................. 6

Data Collection Timeline and Burden ................................................................................ 8

Collection of Data with Additional Disaggregation ......................................................... 16

III. Comments about Specific Aspects of the Collection............................................................18

School and District Characteristics................................................................................... 18

Discipline .......................................................................................................................... 23

Harassment or Bullying .................................................................................................... 26

Restraint and Seclusion..................................................................................................... 28

Single-Sex Interscholastic Athletics................................................................................. 28

Early Childhood Education............................................................................................... 29

Pathways To College And Career..................................................................................... 30

School Finance.................................................................................................................. 32

Teachers and Other Staff .................................................................................................. 34

IV. Revised Burden Estimates....................................................................................................37

V. Complete List of Items Proposed for the Civil Rights Data Collection ...............................39
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

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INTRODUCTION

This attachment contains the responses to public comments on the Mandatory Civil Rights Data 

Collection (CRDC). The Department of Education’s (ED) Office for Civil Rights (OCR) is 

responsible for administering the CRDC, a survey of local educational agencies (LEAs). The 

survey has been administered biennially since 1968. The data from the survey are used by OCR 

to aid in its enforcement efforts. The survey is also an important source of civil rights data for 

other government agencies, educators, researchers, and the general public in their efforts to 

promote equal educational opportunities for all students.

ED received 298 comments in response to the Notice of Proposed Information Collection 

Requests that was published in the Federal Register on June 21, 2013, 78 Fed. Reg. 37529. The 

comments included feedback on the two directed questions, specific areas of data collection that 

were shown in the attachments, and the information clearance process. A variety of stakeholders 

provided comments, including: Members of Congress, state educational agencies (SEAs), LEAs, 

administrators, educators, non-profit organizations, coalitions, professional organizations, 

advocates, parents, and other private citizens. 

ED received several comments that were generally positive and appreciative of the efforts made 

by ED to gather data on a variety of elements related to equal educational opportunity. One 

commenter states as follows, “[The CRDC] is an essential tool for the protection of the 

educational rights of vulnerable children and youth, including children with disabilities. We are 

pleased to support the proposed additions to the CRDC, which appear to be thoughtfully

considered and constrained in their breadth and scope.” Another commenter noted the 

following, “The CRDC makes it possible to evaluate and monitor trends in discipline, 

harassment and bullying, and restraint and seclusion, among other areas, where school policy

makers, parents and community members can play a powerful role in improving the lives of 

students—if they have the information to address the concerns... The amendments are a 

balanced, reasonable, and appropriate approach to ensure the nation’s public schools are 

complying with federal anti-discrimination law.”

ED appreciates each commenter’s time and effort in providing thoughtful commentary in 

response to this proposed data collection. ED reviewed, summarized and documented each 

comment prior to analyzing all comments. This documentation will aid in the finalization of this 

data clearance package and will serve to inform future policy decisions regarding the CRDC. 

The remainder of this document is divided into five parts:

I. Overview of proposed significant revisions that respond to recurring comments

II. Responses to comments about survey scope and administration

III. Responses to comments about specific aspects of the collection, including comments 

responding to Directed Questions

IV. Revised burden estimates

V. Complete list of items proposed for the Civil Rights Data Collection. 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

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I. OVERVIEW OF PROPOSED SIGNIFICANT REVISIONS THAT RESPOND 

TO RECURRING COMMENTS

There are three areas that ED seeks to highlight because they respond to points appearing in 

many of the comments submitted.

First, many of the commenters who raised concerns about the proposed data collection focused 

on the need for more notice and lead time to provide comprehensive and accurate data in 

response to the new CRDC items.

 ED has revised its proposal so that the mandatory collection of nearly all of the new items

will be postponed for two years—that is, until the collection for the 2015–16 school year. 

For the 2013–14 school year collection, reporting of most new items will be optional. ED

will use this time to provide intensive technical assistance to schools and school districts so 

they will be prepared to provide accurate data when required for the 2015–16 collection.

 Nine of the ten proposed mandatory new items for 2013–14 are comprised of yes/no or 

multiple choice questions that will not require school districts to report counts or 

disaggregated count data. Only one new item requires the reporting of disaggregated 

counts, but ED has determined that these data are currently collected in virtually all school 

data systems. The proposed mandatory new items or data groups (DG) for 2013–14 are: 

o DG 924--Whether LEA has any students enrolled in any distance education courses 

(Yes/No);

o DG 916--Whether LEA has civil rights coordinators for Title VI, Title IX, 504/ADA 

(Yes/No and contact information for each);

o DG 944--If offered, cost of kindergarten to participant in LEA (pick one: free; partial 

charge; or full charge);

o DG954--If offered, cost of preschool to participant in LEA (pick one: free; partial 

charge; or full charge);

o DG 953--If offered, whether school’s preschool program serves non-IDEA students age 

3, 4, 5 (Yes/No for each age);

o DG 986--If an ungraded school, age of students in school (pick one: mainly elementary 

school age students; middle school age students; high school age students; elementary

and middle school age students; middle and high school age students; elementary

middle, and high school age students);

o DG 918--Whether a school has any students who participate in a credit recovery

program (Yes/No);

o DG 925--Whether a school has any students enrolled in a dual enrollment/dual credit 

program (Yes/No);

o DG 991--Whether a sworn law enforcement officer (including a school resource 

officer) was assigned to the school (Yes/No);

o DG 978--Number of students absent 15 days or more in a school year (disaggregated by 

race, sex, disability-IDEA, disability-504 only, LEP).
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

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 In addition, ED proposes that the following new items for justice facilities only, be 

mandatory for the 2013–14 school year:

o DG 943--Type of facility (pre-adjudication/conviction; post-adjudication/conviction; or 

both);

o DG 940--Number of days that make up the regular school year;

o DG 942--Number of hours per week that the educational program is offered during the 

regular school year.

 ED continues to propose dropping two items that were collected in the 2011–12 school year

CRDC. The two items are presented below.

o DG 478--The unduplicated number of children in the LEA who are awaiting initial 

evaluation for special education programs and related services under the Individuals with 

Disabilities Education Act;

o DG 29--Whether any students in the school are ability grouped for classroom instruction 

in mathematics or English/reading/language arts (Yes/No).

 ED also proposes to drop the following two new items that were originally proposed for the 

2013–14 and 2015–16 CRDC, in response to comments:

o DG 945--Whether the LEA is required to provide full-day or part-day kindergarten by

state statute or regulation;

o DG 962--Whether the LEA has a policy that allows retention of third grade students who 

are not proficient in reading.

Second, an overlapping point raised by many commenters was that the CRDC imposed a 

duplicative reporting requirement (albeit not an additional collection burden), because much of 

the information collected by ED in the CRDC was also collected by the commenters’ state 

educational agencies (SEA). These commenters are referring to data that SEAs collect, but that 

the SEAs do not report to ED. The CRDC no longer collects the two data groups from LEAs,

where previously, both the LEA and the SEA reported the same data to ED (DG 74 and DG 

306).

 OCR is working with the National Center for Education Statistics (NCES) to develop a 

collection tool for the 2013–14 collection that will support SEAs choosing to pre-populate 

LEA-level CRDC surveys with duplicate data in their student information systems. If an

SEA elects to do so, then its LEAs will not need to reenter that data into the tool. LEAs 

will be expected to review the data before certifying to its accuracy. 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

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Third, numerous commenters raised concerns about ED’s proposal to drop two sets of items that 

were in prior collections. These items pertained to (1) harassment/bullying policies, and (2) the 

FTE of teachers meeting state certification/licensing requirements. 

 ED proposes to reinstate a mandatory yes/no item regarding harassment/bullying policies

that is consistent with the item included in the 2009–10 and 2011–12 CRDCs, and will ask

for a link to the harassment/bullying policy if it is available on the internet. (DG 988)

 ED proposes to reinstate the item regarding the FTE of teachers meeting state 

certification/licensing requirements, which has been used since the 2000 CRDC. (DG 990) 

ED will continue to study options that will allow it to better differentiate among the 

population of teachers who serve different schools.
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

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II. COMMENTS ABOUT SURVEY SCOPE AND ADMINISTRATION

Many of the commenters had specific, useful suggestions about revisions to particular data 

elements, which are addressed below. Each section below provides a summary of the public 

comments received, ED’s response to those comments, and any resulting changes made to the 

proposed data collection package. In addressing the public comments and making revisions to 

the package, ED focused on recommendations from the public comments that continue to move 

the CRDC forward in achieving the goals of consolidating collections, obtaining high quality 

data, and reducing burden on data suppliers.

ED also received a number of specific comments about how to display the results of the data 

collected to the public, including alterations of privacy protection methodologies. Those 

comments will not be addressed in this document, but will be considered as plans for releasing 

the data collected are formulated.

Furthermore, in this document, ED does not address technical and other minor changes that were 

made to the information collection package for clarity, accuracy, and consistency. ED also does 

not address general comments that raised concerns not directly related to the Notice.

CIVIL RIGHTS PURPOSE OF DATA COLLECTION

1. Relationship to Civil Rights 

Public Comments

Several commenters questioned the relationship between some data elements that ED is 

proposing to collect and civil rights. A few commenters suggested that the additional data 

requirements are an overextension of ED’s rulemaking authority, not sufficiently justified and 

not based on recent statutory or regulatory changes that would have precipitated the proposed 

data requirements. 

ED’s Response

Discussion: Section 203(c)(1) of the 1979 Department of Education Organization Act conveys to 

the Assistant Secretary for Civil Rights the authority to “collect or coordinate the collection of 

data necessary to ensure compliance with civil rights laws within the jurisdiction of the Office 

for Civil Rights” (20 U.S.C. § 3413(c)(1)). The civil rights laws enforced by OCR include: Title 

VI of the Civil Rights Act of 1964, which prohibits discrimination based on race, color, and 

national origin; Title IX of the Education Amendments of 1972, which prohibits discrimination 

based on sex; and Section 504 of the Rehabilitation Act of 1973, which prohibits discrimination 

on the basis of disability. OCR’s implementing regulations for each of these statutes requires 

recipients of ED’s Federal financial assistance to submit to OCR “complete and accurate 

compliance reports at such times, and in such form and containing such information” as OCR 

“may determine to be necessary to enable [OCR] to ascertain whether the recipient has complied 

or is complying” with these laws and implementing regulations (34 CFR 100.6(b), 34 CFR 

106.71, and 34 CFR 104.61). ED’s Assistant Secretary for Civil Rights has determined that the 

proposed data elements are necessary to ensure compliance with the civil rights laws.
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

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OCR’s fundamental mission is to ensure access to equal educational opportunity for all students. 

The new data items represent important areas of access to equal educational opportunities and 

are aligned with ED’s focus on providing equal access to educational opportunities to achieve 

college and career readiness.

OCR also works with offices within ED to help them effectively carry out programs of Federal

financial assistance that the Secretary of Education is responsible for administering. For 

example, OCR works with ED’s Office of Elementary and Secondary Education, which is 

responsible for administering the Elementary and Secondary Education Act of 1965 (ESEA). 

Section 9533 of the ESEA (20 U.S.C. § 7913) prohibits discrimination in the administration of 

the ESEA in violation of the Fifth or Fourteenth Amendments to the Constitution. In addition, 

Section 9534 of the ESEA (20 U.S.C. § 7914) prohibits discrimination in funded programs on 

the basis of race, color, religion, sex (except as otherwise permitted under Title IX), national 

origin, or disability. Thus, in addition to OCR's authority described above, the ESEA provides 

authority for ED to mandate that LEAs respond to this data collection.

Changes: None.

2. Public Availability of Data

Public Comments 

Several commenters requested that ED make the data collected on the CRDC publicly available 

in a timelier manner. Other commenters, who were aware of the public CRDC reporting 

website, indicated improvements should be made to the display of data to make the information 

more accessible.

ED’s Response

Discussion: ED has a longstanding commitment to transparency and recognizes the importance 

of making the CRDC data available to the public. ED is also committed to ensuring that the 

CRDC data are made available to the public consistent with ED’s privacy policies. After the data 

files are finalized from the CRDC, ED engages in a rigorous process to ensure that the data 

publicly reported protects against the disclosure of individual student information. This process 

takes several months to ensure that both the data files and the data provided through the website 

adhere to the highest standards for privacy protection. ED continually looks for ways to improve 

the efficiency of this process to ensure timelier access to the data without compromising the 

protection of individual student data. 

To increase the transparency and accessibility of the CRDC data, ED launched an enhanced 

reporting website in March 2012 that provided the public with visually intuitive displays of the 

CRDC data. Following the release of this new website, the number of visits to the CRDC data 

site increased seven fold. The investment in enhanced reporting features has supported broad 

and rich conversations among educational stakeholders about improving educational access and 

equity, resulting in changes to practice, policy and legislation in states and school districts across 

the nation. As funding allows, ED will continue to make improvements to the data display based 

on comments and suggestions from data users. 

Changes: None. 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

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3. Labeling Incomplete Responses

Public Comments

Commenters noted that there were notable instances with the 2009–10 collection, particularly 

surrounding new data items, where school districts unable to report complete and accurate data, 

may have reported zero students in these new data items. Commenters suggested that ED

incorporate a “compliance rating” (for district responses) that notes which data groups a district 

failed to report and that rates the district’s compliance. This would enable all educational 

stakeholders to urge districts to better report their data.

ED’s Response

Discussion: The CRDC is a mandatory data collection. The failure of an LEA to respond and 

report accurate data can lead to enforcement actions by OCR. ED expects complete and accurate 

data, but understands that, in some exceptional circumstances, data may not be provided in a 

timely manner. In those circumstances, ED is studying ways to identify incomplete data 

reporters without suggesting that this is a lawful or acceptable practice.

Changes: None.

DATA COLLECTION TIMELINE AND BURDEN 

4. Reporting Burden and Notification Timeline for New Data Elements

Public Comments

Many commenters raised concerns regarding the added burden on LEAs because of the new data 

elements. Several commenters expressed concern about the overall burden and cost to LEAs to 

report the expanded set of data. They objected to reporting on additional data elements at a time 

when LEAs are facing severe budgetary challenges and resources are limited. Some commenters 

suggested that modifications to their student information systems would have to be made, which 

would require working with outside vendors. Several commenters indicated that they should 

have been given more notice and lead time to respond to the new CRDC items. These 

commenters also noted that they should not be required to report data for the 2013–14 school 

year, since the data elements and definitions are not yet final. Many commenters suggested 

giving LEAs a year within which to revise and implement the proposed new data requirements to 

ensure accurate collection and reporting. Nevertheless, a few commenters stressed that the 

utility of the CRDC far outweighs any added burden imposed by the reporting requirements.

ED’s Response

Discussion: ED appreciates the comments received from LEAs regarding the notification of new 

data elements after the 2013–14 school year has begun. ED concurs with the concern raised by 

LEAs regarding the accuracy of data submitted without adequate time to ensure that the new data 

elements are appropriately added to student information systems. 

ED recognizes that LEAs are facing a challenging economic environment. ED has given 

significant consideration to all of the proposed data requirements and the additional burden they

may impose on LEAs. In response to comments, ED now proposes to remove two newly 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-9

proposed items regarding state and LEA policies (i.e., whether LEA has policy that allows 

retention of third grade students who are not proficient in reading (DG 963); whether SEA 

requires provision of full- or part-day kindergarten (DG 945)) because ED determined that the 

CRDC was not an efficient method for collecting that information. However, for the remaining 

proposed items, ED has determined that each is necessary to ensure compliance with the civil 

rights laws and that, individually and in total, the burden is justified by the need for the data. In 

addition, as noted below, ED will be taking additional steps to reduce the collection burden on 

LEAs.

In response to the request from school districts for ED to provide adequate notice of new data 

elements to be collected on the CRDC, ED now proposes delaying the mandatory completion of 

most new items that involve the reporting of counts or disaggregated counts data until the 2015–

16 CRDC. For the 2013–14 school year collection, reporting of most new items’ data will be 

optional. It is ED’s belief that by notifying school districts in the fall of 2013 of the new 

mandatory data elements for the 2015–16 school year, school districts will have sufficient time 

to make any necessary changes to data collection systems to report complete and accurate data 

for the 2015–16 CRDC. ED will continue to work to move up timelines for announcing changes 

to the data collection. 

Changes: ED is proposing that some of the new items be optional for the 2013–14 school year 

CRDC, and mandatory for the 2015–16 school year. In addition, in an effort to refine the data 

collected regarding Algebra I and Geometry, ED is proposing that the questions previously asked 

in 2011–12 school year regarding those subjects be mandatory again in 2013–14 school year, but 

be replaced with refined mandatory items for the 2015–16 school year CRDC. 

New data groups that ED is proposing as optional for 2013–14, and as mandatory for 2015–16 

are underlined below. The Algebra I and Geometry replacement items that ED is proposing for

2015–16 to replace existing items are at the end of the list below.

School & District Characteristics

 DG 989--Number of students (PS through grade 12) enrolled in LEA and served in nonLEA facilities only (LEA) 

 For justice facility only:

o DG 941--Number of students who participated in educational program for less than 

15 calendar days; 15-30 calendar days; 31-90 calendar days; 91-180 calendar days; 

more than 180 calendar days.

Discipline

 Students (K-12) who were transferred for disciplinary reasons (to alternative school; to 

regular school):

o DG 922--Number of K-12 students with disabilities who were transferred for 

disciplinary reasons (to alternative school; to regular school) (disaggregated by race, 

sex, disability-504 only, LEP)
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

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o DG 923--Number of K-12 students without disabilities who were transferred for 

disciplinary reasons (to alternative school; to regular school) (disaggregated by race, 

sex, LEP)

 Students who received corporal punishment:

o DG 921--Number of preschool students (ages 3-5) who received corporal punishment 

(disaggregated by race, sex, disability-IDEA, LEP)

o DG 917--Number of instances of corporal punishment that students (preschool 

through grade 12) received (disaggregated by students without disabilities, students 

with disabilities)

 DG 966--Number of school days missed by students who received out-of-school 

suspensions (disaggregated by race, sex, disability-IDEA, disability-504 only, LEP) 

 DG 952--Documented incidents that occurred at the school that would trigger discipline, 

including referrals to law enforcement and arrests:

o Number of incidents of robbery with a weapon

o Number of incidents of robbery with a firearm or explosive device

o Number of incidents of robbery without a weapon

o Number of incidents of physical attack or fight with a weapon

o Number of incidents of physical attack or fight with a firearm or explosive device

o Number of incidents of physical attack or fight without a weapon

o Number of incidents of threats of physical attack with a weapon

o Number of incidents of threats of physical attack with a firearm or explosive device

o Number of incidents of threats of physical attack without a weapon

o Number of incidents of rape or attempted rape

o Number of incidents of sexual battery (other than rape)

o Number of incidents of possession of a firearm or explosive device

 DG 919--Whether any of the school’s students, faculty, or staff died as a result of a 

homicide committed at the school

 DG 927--Whether there has been at least one incident at the school that involved a 

shooting (regardless of whether anyone was hurt)

Harassment or Bullying 

 DG 933--Number of reported allegations of harassment or bullying of K-12 students on 

the basis of: sexual orientation; religion

Early Childhood Education 

 DG 957--Number of students served by LEA in preschool programs in LEA and nonLEA facilities (disaggregated by age – 3, 4, 5) (LEA)

Pathways to College and Career

 DG 992--Number of students who participate in at least one credit recovery program 

 DG 993--Number of students enrolled in distance education courses (disaggregated by

race, sex, disability-IDEA, LEP) (LEA)

 DG 994--Number of students enrolled in at least one dual enrollment/dual credit program 

(disaggregated by race, sex, disability-IDEA, LEP)
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

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School Finance

 K-12 personnel FTEs and salaries at the school level (funded with state and/or local 

funds):

o DG 967--Number of FTE instructional aides

o DG 996--Amount of instructional aide salaries

o DG 967--Number of FTE support services staff (for pupils and for instructional staff)

o DG 971--Amount of support services staff (for pupils and for instructional staff)

salaries

o DG 967--Number of FTE school administration staff 

o DG 971--Amount of school administration staff salaries

 Preschool-12 personnel FTEs and salaries at the school level (funded with federal, state,

and/or local funds):

o DG 995--Amount of teacher salaries 

o DG 998--Number of FTE instructional aides

o DG 997--Amount of instructional aide salaries

o DG 998--Number of FTE support services staff (for pupils and for instructional staff)

o DG 999--Amount of support services staff (for pupils and for instructional staff)

salaries

o DG 998--Number of FTE school administration staff 

o DG 999--Amount of school administration staff salaries

o DG 1002--Total amount of instructional and support personnel salaries

 Total amount of non-personnel expenditures at the school level:

o DG 1000--Amount of non-personnel expenditures (funded with federal, state, and/or 

local funds)

Staff (funded with federal, state, and/or local funds)

 DG 1003--Number of teachers (counts):

o Number of current school year teachers (preschool through grade 12)

o Number of previous school year teachers (preschool through grade 12)

 DG 982--Support services staff:

o Number of FTE psychologists (preschool through grade 12) 

o Number of FTE social workers (preschool through grade 12) 

o Number of FTE nurses (preschool through grade 12) 

 DG 975--Security staff:

o Number of FTE security guards (preschool through grade 12) 

o Number of FTE sworn law enforcement officers (including school resource officers) 

(preschool through grade 12) 

Pathways to College and Career (replacement items for 2015–16 school year)

 DG 950--Number of Algebra I classes in grades 9-12 

 DG 906--Number of Algebra I classes in grades 7-8 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

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 DG 907--Number of students enrolled in Algebra I in grade 7 

 DG 908--Number of students enrolled in Algebra I in grade 8 (disaggregated by race, sex, 

disability-IDEA, LEP) 

 DG 910--Number of students who passed Algebra I in grade 7 

 DG 911--Number of students who passed Algebra I in grade 8 (disaggregated by race, 

sex, disability-IDEA, LEP)

 DG 950--Number of Geometry classes in grades 9-12 

 DG 930--Number of students enrolled in Geometry in grade 8 

 DG 951--Number of students enrolled in Geometry in grades 9-12 (disaggregated by

race, sex, disability-IDEA, LEP) 

5. Summer Comment Period

Public Comments

Several commenters raised concerns that the notice regarding the 60-day public comment period, 

from June 21, 2013 to August 20, 2013, occurred when many LEAs may be on summer break 

without staff to monitor and review notices from the Federal Register. 

ED’s Response

Discussion: ED greatly appreciates the time taken by commenters to read the clearance package 

and provide thoughtful comments on how to improve the CRDC as well as review the data 

collection process. ED regrets the 60-day public comment period began during the summer 

months when many key school district staff may have been unavailable. ED determined that the 

efforts to coordinate the proposed revisions to the CRDC with program offices across ED would 

result delaying the release of the package for public comment, but yield an improved clearance 

package that was better aligned with existing definitions and collections across ED. The 

improved clearance package would also help the public better understand ED’s information 

collection requirements. Furthermore, ED was aware that a second 30-day public comment 

period would take place when many school districts were back in session. The Federal Register 

notice accompanying these responses to public comment provides notice of this second 30-day

public comment period.

Changes: None. 

6. Annual and Universal Collection 

Public Comments 

Several commenters suggested that ED transition the CRDC to an annual collection, stating that 

the biennial collection limits parents’ and advocacy groups’ access to timely information about 

educational access and equity. 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-13

ED’s Response

Discussion: The CRDC has been traditionally collected as a biennial survey since 1968. 

Although ED concurs that the public and ED would benefit from an annual CRDC data 

collection, ED is aware of the significant burden of this collection on LEAs. Additionally, ED’s

financial constraints currently prevent it from conducting a survey that is annual. 

Changes: None.

7. Reducing LEA Reporting Burden by Collecting Data from SEAs

Public Comments 

Several commenters requested that ED gather data that are duplicated in SEA collections directly 

from SEAs to reduce the reporting burden on LEAs. A few other commenters requested that ED

not allow SEAs to report CRDC data to ED, on behalf of their LEAs, to ensure the CRDC 

remains certified by the LEA for the purposes of civil rights monitoring. 

ED’s Response

Discussion: ED is continually exploring ways to reduce the reporting burden on LEAs while also 

maintaining a rigorous standard to ensure the quality of information submitted. ED believes it is 

essential that the LEAs remain the certifying entity to validate their CRDC submission. Based 

on feedback received from the CRDC workgroup, which includes LEA and SEA representatives, 

ED has explored multiple options for SEAs to support LEAs in reporting CRDC data. For 

example, to reduce the burden on LEAs, beginning with the 2009–10 CRDC, the CRDC no 

longer collects disaggregated school data on the number of students served under the Individuals 

with Disabilities Education Act (IDEA) by disability category or educational environment. 

Instead, the CRDC uses the data that LEAs submit to the applicable SEA for the purpose of 

reporting required data under IDEA. Likewise, high school completer data are no longer 

collected by the CRDC because ED already collects those data from SEAs through the EDFacts

collection. The 2013–14 and 2015–16 CRDC will continue to leverage the data submitted 

through EDFacts to reduce the burden on LEAs.

For the 2011–12 CRDC, ED improved the CRDC submission system to allow SEAs to provide 

LEAs with flat-files of any duplicate data collected by the SEAs. While the LEA could choose 

to pre-load SEA supplied data files, the LEA was still required to review the accuracy of the data 

for the purposes of CRDC reporting. This option was used in various forms by five SEAs to 

support their LEAs.

For the 2013–14 CRDC, ED has been contacted by several SEAs looking for ways to support 

their LEAs in meeting the reporting requirements for the CRDC. Additionally, OCR is working 

with the National Center for Education Statistics to develop a collection tool for the 2013–14 

collection that will allow SEAs to voluntarily pre-populate LEA-level CRDC surveys with 

duplicate data found in the SEAs’ student information systems. If an SEA elects to do this, then 

LEAs will not be required to reenter that data into the tool, but simply certify its accuracy. 

Changes: None. 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-14

8. Coordination with Other Department Data Collections

Public Comments

A few commenters requested that the CRDC and the EDFacts collection be better aligned to 

eliminate the duplicative reporting of data. In addition, a few commenters requested that the 

CRDC align its reporting timeframes and definitions with the EDFacts dataset.

ED’s Response

Discussion: For the 2013–14 and 2015–16 CRDC, OCR met with program offices across ED to 

eliminate any duplication of data items and, where possible, to ensure that the CRDC uses 

definitions consistent with those used by other program offices. For example, OCR worked 

closely with the National Center for Education Statistics (NCES) to align the definitions used for 

the collection of school-level expenditures with the personnel account codes used by NCES and 

the U.S. Census Bureau in the collection of district-level expenditures. To consolidate and 

centralize preschool-grade 12 data collections, the same definitions of terms are used whenever 

possible to minimize the reporting burden on LEAs.

To coordinate the definitions used and identify possible duplication of data elements, OCR met 

with key staff throughout ED and convened a two-day technical working group, including 

participants from: NCES; the Office of Planning, Evaluation and Policy Development; the Office 

of English Language Acquisition; the Office of Special Education Programs; and the 

Correctional Re-Entry Group, to review the proposed 2013–14 and 2015–16 CRDC. This crossprogram office coordination provided an opportunity for experts in content areas and survey

design to raise potential areas of overlap. 

Wherever possible, ED aligned the CRDC reporting periods and definitions with the EDFacts

data set. For example, for the 2013–14 CRDC student enrollment counts, ED originally

proposed an October 1 snapshot reporting period—which was a date that was consistent with the 

October 1 date used by EDFacts. However, in response to some of the commenter’s concerns

regarding the timeline for reporting CRDC data, ED now proposes to expand the snapshot date 

for many of the data groups to as late as December 31, 2013. For the 2015–16 CRDC collection, 

ED continues to propose the use of the same reporting period for fall enrollment snapshots and 

IDEA counts as used by the EDFacts collection (i.e., October 1). 

Changes: For the 2013–14 CRDC, the fall snapshot reporting period for most data groups has 

been changed to a single day between September 27, 2013, and December 31, 2013. See 

Attachment A2.

9. Resources to Support School Districts 

Public Comments 

Several commenters requested that ED increase resources and technical assistance to states and 

school districts to support the accurate completion of the CRDC. 

ED’s Response

Discussion: ED has traditionally provided a Partner Support Center (PSC) to offer LEAs 

guidance and technical assistance in submitting their CRDC data. For both the 2009–10 and the 

2011–12 CRDC collection, over 79 percent of participating LEAs received direct technical 

assistance from the PSC upon their request. Additionally, the PSC has provided frequent 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-15

communications and reminders to all participating LEAs. ED is committed to working with 

LEAs to ensure accurate reporting of CRDC data and to improve the quality of this information 

for use by LEAs to improve educational access and opportunity. ED plans to improve the web 

submission system to both reduce the burden on LEAs of reporting this data, and to improve the 

accuracy of the data submitted. 

Changes. None.

10. Data Submission System

Public Comments

Several commenters expressed frustration with the amount of time required to submit CRDC 

data and resolve error messages. 

ED’s Response

Discussion: To reduce the potential burden, ED is developing a more interactive, user-friendly 

tool that will make it easier for LEAs to provide the data. The tool takes into consideration 

features that past users have suggested and will include increased flexibility to create customized 

skip patterns, eliminating the reporting burden of entering zeros to non-applicable cells or tables. 

Thus, for example, a school district that says that it has not administered corporal punishment 

will be able to skip all tables addressing corporal punishment. In addition, as noted above, ED is 

working develop a collection tool for the 2013–14 collection that will allow SEAs to voluntarily

pre-populate LEA-level CRDC surveys with duplicate data in their student information systems. 

Changes: None.

11. Privacy Protection of Data 

Public Comments

Several commenters noted that much of the student data sought in the CRDC requires the highest 

possible privacy protection. One commenter suggested that personal information linked to 

individual students should be limited to predetermined purposes and students should have notice 

about the information collection. In addition, the commenter stated that controls should be 

established over who can view the personally identifiable information and audit logs be kept to 

track this access. Finally, the commenter said that any outsourcing of this information should be 

strictly governed by contract with penalties for misuse, and that the information should be 

discarded after the applicable time period. 

ED’s Response

Discussion: ED is extremely sensitive to the concern raised by the commenters, and agrees that 

appropriate privacy protection should be maintained for any data collected. The Privacy Act of 

1974, the Family Education Rights and Privacy Act (FERPA) and other applicable laws and 

regulations govern ED’s use of data collected. ED already has numerous protocols in place to 

ensure that privacy breaches do not occur. Any information that is available on ED’s Web site 

that reports the CRDC data goes through an intensive review to ensure that the data posted does 

not reveal any personally identifiable information. 

Changes: None.
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-16

COLLECTION OF DATA WITH ADDITIONAL DISAGGREGATION

12. Disaggregating by Additional Racial/Ethnic Categories 

Public Comments

A few commenters requested additional disaggregation of certain race/ethnicity categories. A 

few commenters requested that the Asian and Native Hawaiian/Pacific Islander categories be 

further disaggregated to report by three separate categories, “Asian, “Native Hawaiian”, and 

“Pacific Islander.” Other commenters requested that ED pilot collecting data using the U.S.

Census Bureau’s major ethnicities. 

ED’s Response

Discussion: ED recognizes the diversity within the Asian and Native Hawaiian/Pacific Islander 

categories. On May 4, 2012, ED released a request for information to gather and share 

information about practices and policies regarding existing education data systems that 

disaggregate data on subgroups within the Asian and Native Hawaiian or Other Pacific Island 

(ANHPI) student population. ED anticipates making use of this information to help SEAs and 

LEAs identify, share, and implement promising practices and policies for identifying and 

overcoming challenges to gathering and disaggregating data on subgroups within the ANHPI

student population. SEAs and LEAs might then use those data to improve their ability to 

respond to the unique needs and issues that might exist for these subgroups.

However, for CRDC reporting purposes, ED’s October 2007, “Final Guidance on Maintaining, 

Collecting, and Reporting Racial and Ethnic Data to the U.S. Department of Education,” 72 Fed. 

Reg. 59,266 (Oct. 19, 2007), states that recipients are required to report by seven racial/ethnic 

categories (i.e., Asian, Native Hawaiian or Pacific Islander, Native Alaskan or American Indian, 

Black, Hispanic, or White). While school districts may choose to disaggregate these categories 

further, they are only required to comply with the requirements of ED’s guidance. See id. at 

59,278. The 2011–12 CRDC was an important milestone for full implementation of the ED

October 2007 guidance, in that every school district reporting CRDC data for the 2011–12 

school year was required to report data on Asian students separately from Native Hawaiian or 

Pacific Islander students. This finer grain of disaggregation gives ED greater insight to the 

educational opportunities for Native Hawaiian and Pacific Islander students that may have been 

previously concealed with the reporting of data within the broader category of Asian/Pacific 

Islander. 

Changes: None.

13. Disaggregating by Socioeconomic Status 

Public Comments

A few commenters requested that the CRDC collect data disaggregated by socioeconomic status. 

One commenter suggested including economically disadvantaged data collected through ED’s 

EDFacts initiative.

ED’s Response

Discussion: While ED believes disaggregation by socioeconomic status for CRDC data elements 

would be a useful data point for ED in general, reporting on these items in the CRDC would 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-17

significantly increase the scope and burden of the data collection. To provide important 

contextual information, ED has incorporated data on percent of students eligible for free or 

reduced priced lunch, which is collected by NCES, on its OCR website. Additionally, ED has 

provided information regarding each school’s Title I status on its OCR website, to view 

alongside the educational access and equity data collected on the CRDC. 

Changes: None. 

14. Disaggregating by Pregnant and Parenting Student Status

Public Comments

Several commenters sought additional data related to pregnant and parenting students. The 

proposed additions included: (1) the number of students who are pregnant or parenting; (2) 

whether the LEA or school offers a charter, separate, or alternative school or program 

exclusively or primarily for pregnant and parenting students; (3) whether the LEA or school has 

personnel assigned to pregnant and parenting student service coordination; (4) the number of 

students suspended, expelled, or removed for disciplinary reasons disaggregated by pregnancy

and parenting status; (5) the number of reported allegations of harassment or bullying on the 

basis of pregnancy or parenting status; and (6) the number of pregnant and parenting students 

enrolled in any of the “college and career pathway” programs reported in the CRDC.

ED’s Response

Discussion: While several of the data collection items proposed by commenters would provide 

useful additional information, reporting on these items in the CRDC would significantly increase 

the scope and burden of the data collection. Furthermore, except for the items involving the 

existence of separate schools and harassment, these items raise privacy concerns regarding the 

LEA’s identification of and record-keeping about pregnant and parenting students.

Changes: None.

15. Disaggregating by Status as Foster Youth, Migrant, and Homeless Students

Public Comments

A few commenters requested the collection of CRDC data disaggregated by foster, migrant, and 

homeless students, as these groups of students are particularly vulnerable and likely to receive 

differential treatment.

ED’s Response

Discussion: While ED believes collecting data disaggregated by these categories would be a 

useful data point for ED, collecting this information as part of the CRDC would greatly increase 

the reporting burden on LEAs and would not substantially further the core civil rights mission of 

the collection.

Changes: None. 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-18

III. COMMENTS ABOUT SPECIFIC ASPECTS OF THE COLLECTION

SCHOOL AND DISTRICT CHARACTERISTICS

16. Limited English Proficient Student Data 

Public Comments

Several commenters requested that ED collect more detailed data regarding educational

opportunities for students who are limited English proficient (LEP). 

ED’s Response

Discussion: While ED believes more detailed disaggregation by LEP status for CRDC data 

elements would be a useful data point for ED, collecting this type of information as part of the 

CRDC would greatly increase the reporting burden on LEAs. Additionally, much of this 

information is reported by SEAs through the EDFacts initiative and Consolidated State 

Performance Reports. For example, on an annual basis, each SEA reports the most commonly

spoken languages, other than English, for each school district and the number of students 

speaking each of the languages listed. Furthermore, each state is required to report the number of 

newly arrived English Language Learners who are exempted from participating in the 

reading/language arts assessment under ESEA (34 CFR 200.6 (b)(i)(C)). 

Changes: None.

17. Charter School Status 

Public Comments

ED received several comments about the importance of collecting data on charter schools. A 

few commenters requested that ED consider the special context of charter schools and the 

additional burden the collection may impose given that their student information systems are 

often separate from more traditional LEAs and schools.

ED’s Response

Discussion: ED recognizes that charter schools may be operating separate student information 

systems from traditional LEAs. Collecting data from all charter schools, including charter 

schools that are separate from traditional LEAs, provides data on college and career readiness, 

discipline and other civil rights issues. Each charter school that fills out the survey provides

disaggregated data in all the areas required by the CRDC, which enables the monitoring of the 

school’s civil rights obligations. ED has been working to address issues related to the collection 

of CRDC data from all charter schools and will continue to provide outreach and assistance to 

charter schools to facilitate the collection of all CRDC data. 

Changes: None. 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-19

18. Justice Facilities

Public Comments 

Many commenters supported expanding the information collection about education that youth 

receive while in justice facilities. They noted that there is a clear need for better data on how 

educational needs are met while youth are confined in correctional facilities. One commenter 

recommended that the data be collected from LEAs and SEAs, rather than from schools. Another 

commenter recommended that information about participants be disaggregated because it will 

provide a more complete picture of the students in justice facility education programs, and aid in 

identifying trends and practices that may violate students’ civil rights. Some commenters also 

suggested additional questions about: (1) the facility regarding recognition/award of credits; 

transfer of records; alignment of curriculum; and reentry support, and (2) the treatment of 

students after their release.

ED’s Response 

Discussion: Significant numbers of students are being educated, at least for certain periods of 

time, in juvenile justice facilities. Data from the 2009–10 and 2011–12 CRDCs revealed 

important information about the students served in long-term secure and boot camp juvenile 

justice facilities. For 2013–14, ED will expand its collection to include additional justice 

facilities types beyond long-term secure facilities and boot camps, such as pre-adjudication 

detention centers. 

While several of the data collection items proposed by commenters would provide useful 

additional information, reporting on these items in the CRDC would significantly increase the 

scope and burden of the data collection. Therefore, ED will not add any of the commenters’ 

proposed new items to the CRDC at this time. 

In response to some of the commenters’ general concerns regarding the timeline for reporting 

CRDC data (see Section II above), ED is now proposing that some of the new items specifically

intended for juvenile justice facilities be optional for 2013–14. 

Changes: For the 2013–14 CRDC, ED is proposing the collection of data on type of juvenile 

justice facility (DG 943), number of days that make up the regular school year (DG 940), and 

number of hours per week that the educational program is offered during the regular school year

(DG 942) as mandatory, and number of students who participated in the educational program, 

disaggregated by number of calendar days (DG 941) as optional. ED proposes no changes to the 

data elements for the 2015–16 CRDC. 

19. Coordinators

Public Comments

Many of the commenters supported the addition of the collection of information regarding civil 

rights coordinators in all three statutory areas (race, sex, and disability). A few of those who 

supported these data elements also supported collecting data on number of complaints received 

by the coordinators, their training, the overlap between coordinators assigned to various topics, 

and other variables. One commenter questioned ED’s authority to collect information on a Title 

VI coordinator, arguing that such a coordinator is not required under the regulations. The same 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-20

commenter argued that the information on coordinators was already available on LEAs’ websites 

and that ED should not collect contact information on coordinators because ED should not 

contact coordinators directly.

ED’s Response

Discussion: ED’s regulations implementing Title IX and Section 504 require that public school 

districts that receive federal financial assistance to appoint a “coordinator” to coordinate efforts 

to comply with the law, including investigation of any complaint. 34 C.F.R. 106.8(a), 104.7(a). 

A recipient must notify all its students and employees of the name, office address, and telephone 

number of the Title IX coordinator. 34 C.F.R. 106.8(a). ED has found that compliance with 

these regulations is not universal, and public reports of non-compliance persist. Asking each 

district to answer whether they have complied with these regulations is one appropriate step for 

ensuring compliance. 

Although no similar obligation is reflected in the Title VI regulations, ED believes many districts 

have appointed employees to serve a similar coordination function for issues involving race, 

color, and national origin. It is valuable to learn how many districts have done so in an effort to 

promote compliance with Title VI to determine the personnel resources districts are devoting to 

this issue or whether further regulation is required.

Collecting the name and contact information of the coordinator is appropriate for four reasons. 

First, it provides useful confirmation that the coordinator position is actually filled. Second, it 

allows ED to learn whether the same or different staff are being used for the different coordinator 

positions. Third, it will allow ED to assist in connecting members of the school community with 

existing coordinators (for whom, as a commenters note, the contact information is already

supposed to be publicly available). Finally, it will allow ED to keep coordinators informed as 

civil rights guidance and technical assistance is made available.

While several of the data collection items proposed by commenters would provide useful 

additional information, reporting on these items in the CRDC would significantly increase the 

scope and burden of the data collection. 

Changes: None.

20. Single-Sex Classes

Public Comments

Several commenters sought additional data related to single-sex classes. The proposed additions 

included reporting not only the absolute number of single-sex academic classes in the subjects 

listed by males/females only, but also the number of coeducational class sections within each of 

those subjects, as well as the grade level. Commenters also requested that single-sex classes 

items be disaggregated by race/ethnicity and disability, in a manner that may be fully crosstabulated, to enable analysis of whether students of color and students with disabilities are 

disproportionately channeled into either single-sex or coeducational classrooms. Furthermore, 

commenters requested clarification of what counts as a single-sex class, and specified that if the 

class is selected by sex-neutral factors, such as skill or ability (e.g., vocal range) resulting in it 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-21

being incidentally limited to members of one sex, then it should not be considered a single-sex 

class for CRDC reporting purposes.

ED’s Response

Discussion: While several of the data collection items proposed by commenters would provide 

useful additional information, reporting on these items in the CRDC would significantly increase 

the scope and burden of the data collection. ED, however, has amended the definition of “single 

sex class” to make clear that a class should be counted as a single-sex class only if it excludes 

students of one sex from enrolling or otherwise participating in that class because of their sex. 

Changes: The definition of “single-sex class” (see DG 976) has been amended to make clear that 

a class should be counted as a single-sex class only if it excludes students of one sex from 

enrolling or otherwise participating in that class because of their sex. A class is not considered

single-sex so long as it is open to members of both sexes, even if students of only one sex, or a 

disproportionate number of students of one sex, enroll. The Title IX regulations acknowledge 

two common examples of such classes: physical education classes that group students on the 

basis of ability, and vocal choruses that group students based on vocal range.

21. Students Awaiting Evaluation for Special Education

Public Comments

A few commenters requested that ED continue to collect the number of students awaiting 

evaluation for special education services. 

ED’s Response

Discussion: The obligation to evaluate a student for special education services arises under both 

504 and the Individuals with Disabilities Education Act. ED’s Office of Special Education and 

Rehabilitative Services already monitors data on the timeliness of evaluations and IDEA’s 

Annual Performance Report (Indicator 11) provides the public with data on the state’s adherence 

to the timeline for an initial evaluation for IDEA students. Continuing to collect this data would 

provide only marginally more information and its utility does not warrant the additional burden 

on LEAs.

Changes: None.

22. Ability Grouping 

Public Comments

A few commenters requested that ED continue to collect data on ability grouping. One 

commenter requested additional information on ED’s justification not to collect data on whether 

the school had classes that were ability grouped for English/reading/language arts. The 

commenter suggested that ED collect disaggregated ability grouping data by race/ethnicity. 

Another commenter suggested that ED report tracking/ability grouping by campus. One 

commenter suggested that ED collect ability grouping data by honors, regular or remedial 

coursework, and by which subjects students are ability grouped. The commenter also proposed 

that ED collect data on how schools define ability grouping.
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-22

ED’s Response

Discussion: ED acknowledges that continuing to collect data on whether students are ability

grouped would provide useful information, but it would also impose an additional burden on 

LEAs. The proposed survey seeks disaggregated data in a number of other areas related to class 

participation. ED believes that collecting data on ability grouping on the CRDC is not necessary

at this time.

Changes: None.

23. School Facilities and School Health

Public Comments

A few commenters recommended that ED collect information about school facilities and 

maintenance. One commenter also recommended that the CRDC include measures related to 

school health and wellness, including information about food and fitness, and health services. 

ED’s Response

Discussion: ED acknowledges that collecting information about school facilities and 

maintenance would be useful. However, reporting on these items in the CRDC would 

significantly increase the scope and burden of the data collection. Nevertheless, in response to 

the commenter’s request for information related to school health and wellness (and other 

commenters’ specific requests for nurse information as described under “Support Staffing” 

below), ED proposes to collect number of FTE nurses using the CRDC. 

Changes: ED proposes to add number of FTE nurses (DG 982) to the CRDC. 

24. Learning Time

Public Comments

One commenter recommended that the CRDC collect school time data to determine whether 

low-income and minority children are being systematically disadvantaged by having access to 

fewer hours of school learning time. 

ED’s Response

Discussion: ED acknowledges that the collection of information on school learning time would 

be useful. However, because measurement of instructional time at a school or student level 

raises difficult technical issues that require further study, ED has determined not to propose such 

a set of items at this time. Nevertheless, ED recognizes that many of the items to be collected –

including for example data regarding student absenteeism and exclusionary discipline – cover 

school instructional time information. In addition, ED will continue to explore possible learning 

time measures to include in the CRDC that may be useful for the purposes of identifying 

disparities in educational opportunities. 

Changes: None.

25. Other Policies and Monitoring

Public Comments

One commenter suggested that ED add indicators of a positive school climate, including: how

the school district has adopted coursework requirements for social and emotional learning; 

whether the school district has a policy or procedure to (1) monitor attendance, behavior, and 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-23

course performance, or (2) determine whether a student needs additional support services; 

whether the school district has formal mechanisms of conflict resolution and discipline; and 

whether the school district has a policy on teen dating violence.

ED’s Response

Discussion: ED acknowledges the importance of collecting data on indicators related to school 

climate. However, because of the need to balance the utility of data with the overall burden of 

the CRDC, ED has decided not to collect these data at this time. 

Changes: None.

DISCIPLINE

26. Expulsions - Transfers for Disciplinary Reasons

Public Comments

Many commenters supported ED’s proposal to collect data about students who are removed for 

the remainder of the school year to another school for disciplinary reasons—whether to another 

regular school or an alternative school. These commenters suggested that ED refer to these types 

of expulsions as “transfers” and not “removals.” Several commenters pointed to a 2012 report 

by the Georgetown Law Human Rights Institute Fact-Finding Mission, which found that 

“disciplinary transfers” to other regular or alternative schools within a school district are 

common, and can have the same disruptive effect on the student as other forms of expulsions 

with educational services. These commenters believed that collecting this data would permit ED

to learn which students experience a greater number of transfers and which schools have a high 

transfer rate.

ED’s Response

Discussion: The CRDC items regarding expulsion were always intended to capture all situations 

where a child was no longer able to attend his or her regular school for the remainder of the 

school year (if not longer) for disciplinary reasons, regardless of the name used by the school

district to describe the result. Recognizing that some school districts “expelled” children from a 

school but continued to provide educational services in another school or a home setting, the 

CRDC has previously collected separate counts of children expelled with and without 

educational services. The proposed changes to the CRDC were intended to get a clearer picture 

of where children who were expelled with educational services were receiving such services. 

For the proposed CRDC, ED agrees with the commenters’ suggestion to use the term “transfers”

instead of “removals” when referring to expulsions to another school. Therefore, ED has revised 

the Discipline Method category in Attachment A3 accordingly. ED will also make clearer in the 

survey instructions that all disciplinary transfers for the remainder of the school year (or longer) 

constitute “expulsions” for purposes of the collection. 

Changes: ED has adopted the term “transfers” when referring to expulsions to another school. 

See revisions to the Discipline Method category in Attachment A3.
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-24

27. Number of School Days Missed by Students Who Receive Out-of-School Suspensions 

Public Comments

Several commenters supported ED’s proposal to collect the number of school days missed by

students who received out-of-school suspensions. These commenters contended that the time 

spent out-of-school, including short periods of removal, speeds the disengagement process and 

can be a key entry into the “school-to-prison” pipeline. One commenter suggested that the 

information be collected in a more detailed format (i.e., the number of students suspended 1 day, 

2-5 days, 6-9 days, and 10 days or more). The same commenter requested that ED measure the 

amount of class time missed due to in-school suspensions.

ED’s Response

Discussion: Although the data collection items proposed by commenters would provide useful 

additional information, reporting on these items in the CRDC would significantly increase the 

scope and burden of the data collection. 

Changes: None.

28. Out-of-School Suspensions

Public Comments

Many commenters recommended that ED define out-of-school suspension uniformly for students 

with and without disabilities as “at least half a day.” They contended that this change would 

enable educators, parents and advocates to compare suspension rates for student with disabilities 

to their non-disabled peers. They also contended that the change would ease the collection 

burden by not requiring districts to count suspensions in different ways for different groups of 

students. Furthermore, some commenters suggested that ED report the total number of 

suspensions issued, rather than just the number of students suspended once, or more than once.

ED’s Response

Discussion: Historically, out-of-school suspensions under the Individuals with Disabilities 

Education Act (IDEA) have been measured as “at least half a day,” while out-of-school 

suspensions under the CRDC have been measured as “at least a day.” To align the definitions 

for students with disabilities across collections, ED proposed adopting the IDEA definition for 

IDEA students. At the same time, ED proposed retaining its traditional definition of “at least a 

day” for all other students so as to make it easier for users to compare out-of-school suspension 

numbers to past CRDC collections (spanning back decades). In light of the commenters’

suggestions, and in light of the growing concern regarding disruption in learning caused by even 

partial day suspensions, ED agrees that the definition of out-of-school suspension should be 

defined uniformly for all students in the CRDC as “at least half a day.” 

ED already collects sufficient suspension information to allow it to report on students receiving 

at least one suspension. ED will seriously consider computing this number and reporting it so 

that all stakeholders can easily understand precisely how many individual students are being 

suspended.
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-25

Changes: ED has revised the day length reference in the “out-of-school suspension” definition to

“at least half a day.” See revisions to the Discipline Method and Discipline Method (Preschool) 

categories in Attachment A3.

29. Referral to Law Enforcement

Public Comments

Some commenters urged ED to add more items extending to formal law enforcement interactions 

short of arrest, such as court referrals, citations, or tickets. These commenters noted that a first 

court appearance can quadruple the odds that a student will drop out of school. 

ED’s Response

Discussion: In many jurisdictions, it is apparently far more common for students to receive 

citations, court referrals, or tickets than to be arrested, yet these punishments are practically as 

severe and can result in missed school time, court fees and fines, and a criminal record. ED has 

always intended that the term “referral to law enforcement” include citations, tickets, and court 

referrals. Therefore, for the proposed CRDC, ED has amended the “referral to law enforcement” 

definition to clarify that these activities are included.

Changes: ED has amended the definition of “referral to law enforcement” to include citations, 

tickets, and court referrals. See revision to the Discipline Method category in Attachment A3.

30. Offenses

Public Comments

Many commenters supported ED’s proposed collection of school-based offenses. Some were 

concerned, however, that the offenses were not linked to whether disciplinary action was taken 

(and, indeed, that the offenses could involve non-students). Many commenters urged ED to add 

more items, such as “disorderly conduct,” “willful defiance,” and “disrupting public school.”

These commenters considered these items the acts for which most students are disciplined, 

arrested, or referred to law enforcement. Some commenters also suggested that ED collect 

disciplinary action data for the offenses categories. 

ED’s Response

Discussion: Most of the school-based offenses categories proposed for the CRDC were adopted 

from the School Survey on Crime and Safety (SSOCS). SSOCS is a survey of a nationally 

representative sample of public schools in the U.S., sponsored by the National Center for 

Education Statistics (NCES). These types of offenses help to provide an overall picture of 

school crime and safety in the U.S. Although they do not correspond with the proposed 

disciplinary action items for the CRDC, they do give a measure (comparable through SSOCS to 

historical data) of school safety, and they allow ED to correlate school safety rates to school 

discipline rates. 

ED appreciates the commenters’ suggestion that ED add non-violent offenses to the collection, 

and acknowledges that these types of offenses would provide useful additional information.

However, ED has determined that reporting on these items in the CRDC would significantly 

increase the scope and burden of the data collection. 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-26

Changes: None.

HARASSMENT OR BULLYING

31. Harassment or Bullying Motivated By Students’ Perceived Sexual Orientation or Religion

Public Comments

Many commenters expressed support for ED’s proposed addition of items involving incidents of 

harassment or bullying based on sexual orientation or religion. In addition, several of these 

commenters recommended that ED collect harassment or bullying data based on gender identity

or transgender status, or clarify that such harassment or bullying falls within the definition of 

harassment or bullying based on sex. A few commenters opposed the addition of these items 

because they believed: (1) it exceeded ED’s authority, and (2) it would be difficult or impossible 

to determine the motive for the harassment or bullying without an investigation of the sexual 

orientation or religion of the student. 

ED’s Response 

Discussion: ED has determined it has authority to collect these data items under the Department 

of Education Organization Act, Title VI, Title IX, and ESEA. ED has concluded that 

determining whether the motive for reported harassment is based on sexual orientation or 

religion is no more difficult than determining whether the motive is based on sex, 

race/color/national origin, or disability. No commenter identified such problems in any of the 

more than 10 states that currently collect this information about the harassment or bullying based 

on sexual orientation from their LEAs. Moreover, Congress currently requires institutions of 

higher education to collect and report data to ED on reported incidents in which the victim was 

selected because of actual or perceived sexual orientation or religion, so this is clearly within the 

ambit of educational institutions’ competence. ED has issued guidance to institutions of higher 

education of how to collect this data. OCR will provide similar guidance to school districts.

The commenters’ request to require separate reporting of harassment or bullying on the basis of 

gender identity or transgender has strong appeal, but ultimately does not warrant any additional 

disaggregation at this time. There is no doubt, as research identified by the commenters 

confirms, that students are often subjected to harassment or bullying based on their gender 

identity or transgender status. Congress currently requires institutions of higher education to 

collect and report data to ED on reported incidents in which the victim was selected because of 

actual or perceived gender identity, which suggests that it is something that educational 

institutions can report. 

ED is interested in collecting information about this serious problem. ED has intended for this 

type of harassment or bullying to be included within the existing definition of “harassment or 

bullying on the basis of sex.” At the behest of commenters, ED has amended the definition of 

“harassment or bullying on the basis of sex,” to clarify that it includes harassment or bullying 

based on gender identity, gender expression, and nonconformity with gender stereotypes. 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-27

However, estimates suggest that at most 1.3 percent of students identify as transgender, which is 

about three times smaller than the population of gay, lesbian, and bisexual students.1 Those 

estimates suggest that the number of reports of harassment or bullying would be comparatively

small at the school level, and would not yield numbers that would assist ED in identifying 

patterns of potential violations of Title IX. In addition, very few states are currently collecting or 

reporting this harassment or bullying data disaggregated by gender identity, and so adding this 

item would impose a new burden on a larger number of districts.

Changes: ED has amended the definition of “harassment or bullying on the basis of sex” to 

clarify that it includes harassment or bullying based on gender identity, gender expression, and 

nonconformity with gender stereotypes. See revisions to the civil rights allegations and student 

counts categories in Attachment A3.

32. Harassment and Bullying Policies

Public Comments

Several commenters urged ED not to drop the item regarding harassment or bullying policies. 

These commenters uniformly contended that collecting information about school districts’

harassment and bullying policies continues to provide significant information relevant to school 

climate and the school districts’ responsiveness to complaints. One commenter suggested that 

ED ask school districts to provide a link to their harassment policies if they were available on the 

internet.

ED’s Response 

Discussion: ED concurs with the commenters’ recommendations. The existence of policies 

prohibiting harassment or bullying on the basis of prescribed bases (including race, color, 

national origin, sex, and disability), and the dissemination of such policies, are important 

components of school districts’ efforts to establish and maintain an educational climate that does 

not impede the ability of all students to learn. ED’s analysis of the 2009–10 CRDC data suggests

that very few school districts indicated that they have a policy that prohibits one type of 

harassment or bullying and not the others. Therefore, in an effort to continue to reduce burden, 

ED proposes to reinstate the harassment or bullying policies item used in the 2009–10 and 2011–

12 CRDC, but collapse the three types of harassment or bullying bases (i.e., race, color, national 

origin; sex; and disability) into one category. In addition, ED proposes to ask school districts 

that have posted their policies on the internet to provide a link so that ED and the public will be 

able to easily locate district policies and compare the policies of different districts. Furthermore, 

ED will clarify in the CRDC survey instructions that for the purposes of the CRDC, in order to 

																																																												

1

See JP Shields et al (Feb 2013). Estimating Population Size and Demographic Characteristics of Lesbian, Gay, 

Bisexual, and Transgender Youth in Middle School. J. Adolesc. Health, pp. 248-250. (Report for San Francisco 

public middle schools); Also see G Gates (April 2011). The Williams Institute: How Many People Are Lesbian, 

Gay, Bisexual, And Transgender? pp. 5-6 (Report estimates that 0.3 percent of American adults are transgender and 

3.5 percent are gay, lesbian, and bisexual). 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-28

qualify, the school district’s policies must address harassment or bullying of students, and that

policies limited to harassment or bullying of employees or by employees will not be sufficient. 

Changes: ED proposes to reinstate the harassment or bullying policies item (DG 988) used in 

previous collections in modified form. ED also proposes to collect web links to the school 

districts’ harassment and bullying policies. 

RESTRAINT AND SECLUSION

33. Restraint and Seclusion

Public Comments

One commenter suggested that the definition of “mechanical restraint,” which was carried over 

from the previous collections, be revised to clarify whether school districts should report the use 

of handcuffs by law enforcement personnel as type of mechanical restraint. The same 

commenter requested additional examples and interpretative guidelines on the difference 

between “physical restraint” and “physical escort” or a “temporary touching or holding a 

student” for transportation purposes. The commenter also requested clarification between 

“seclusion” and traditional “time outs,” and clarification of what constitutes being “physically 

prevented from leaving.”

ED’s Response

Discussion: ED’s previous definitions for restraint and seclusion were drawn from the definition 

in the Children’s Health Act and accompanying regulations. See 42 U.S.C. § 290JJ(d)(1)-(4). 

These definitions have been relied on by ED in its Resource Guidance on restraint and seclusion

(available at http://www2.ed.gov/policy/seclusion/index.html). They serve as the model for 

many state and local administrative policies. 

Nonetheless, ED agrees that additional clarification would yield more accurate data about the 

scope of mechanical and physical restraint and seclusion. Therefore, ED will amend the CRDC 

survey instructions and provide technical assistance materials that make clear that the use of 

handcuffs by law enforcement personnel during an arrest should not be reported in this item, to 

avoid double counting with the count of students who are arrested. However, if the student is 

handcuffed and no arrest is made, then the mechanical restraint of the student should be included 

in the item. Other clarifications on these topics will be provided in the instructions and technical 

assistance materials.

Changes: None.

SINGLE-SEX INTERSCHOLASTIC ATHLETICS

34. Data Related to Single-sex Interscholastic Athletics

Public Comments

Several comments were submitted which, while expressing support for the CRDC elements, 

sought additional data related to women and girls’ sports. The proposed additions included: 

more significant information related to athletics, including participants’ race and ethnicity; 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-29

whether there are co-ed teams; expenditures for travel, equipment, uniforms, and facilities; the 

number and payment of coaches and assistant coaches; annual revenue generated by each team; 

benefits provided by non-school sources (e.g., booster clubs, donations, and fundraisers); and 

total number of competitions and practices scheduled. 

ED’s Response

Discussion: While several of the data collection items proposed by commenters would provide 

useful additional information, reporting on these items in the CRDC would significantly increase 

the scope and burden of the data collection. 

Changes: None.

EARLY CHILDHOOD EDUCATION

35. State Law Requiring Full-Day or Part-Day Kindergarten

Public Comments

Some commenters suggested that it was not appropriate to use the CRDC to collect information

about state law or regulation requirements for full-day or part-day kindergarten from LEAs

because the information was probably already available to the public. These commenters also 

noted that even if the information was not readily available, requesting all LEAs in a state to 

complete the same item would not be an efficient method for collecting the information.

ED’s Response

Discussion: Requesting information from LEAs about state law or regulation requirements can 

be useful to gauge their understanding of the requirements. However, ED concurs that this 

specific information should not be obtained using the CRDC, given that the information may be 

obtained through other sources. The burden on school districts is not warranted.

Changes: ED will not include this item (DG 945) in the CRDC.

36. Non-LEA Facilities

Public Comments

One commenter questioned whether ED’s reference to “non-LEA facilities” was intended to 

require an LEA to do a census of all private pre-school providers.

ED’s Response

Discussion: ED’s reference to “non-LEA facilities” is not intended to require an LEA to do a 

census of all preschool providers if the students served by those pre-school providers are not the 

responsibility of the LEA. ED has revised the data group that collects LEA membership (for

2015–16) to obtain counts of students enrolled in LEAs, who are served in non-LEA facilities 

(DG 989). In this data group, ED clarifies that school districts are being asked to report on only 

those students who are the responsibility of the LEA, but who are served in non-LEA facilities 

only. 

Changes: ED proposes to collect the number of students enrolled in LEAs, who are served in 

non-LEA facilities (DG 989). 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-30

PATHWAYS TO COLLEGE AND CAREER

37. Credit Recovery

Public Comments

One commenter requested that ED collect data on the number of students who participate in at 

least one credit recovery program, disaggregated by race/ethnicity, disability status, and LEP 

status. 

ED’s Response

Discussion: ED acknowledges that data counts of students who participate in credit recovery

programs, disaggregated by specific demographic subgroups would be useful to ED. However, 

because of the need to balance the utility of data with the overall burden of the CRDC, ED 

proposes to add to the CRDC a new item that collects from schools the total count of students 

who participate in credit recovery programs, and no disaggregated data.

Changes: ED proposes a new item for the CRDC that collects from schools the number of 

students who participate in at least one credit recovery program (DG 992). 

38. Distance Education 

Public Comments

One commenter urged ED to collect data on computer access and utilization, and high-speed 

internet access. Another commenter requested that the distance learning courses be 

disaggregated by dual enrollment/dual credit, credit recovery, International Baccalaureate and 

Advanced Placement courses, subjects not offered, test preparation, and GED preparation.

ED’s Response

Discussion: While the items proposed by the commenters would yield useful additional 

information, ED has determined that reporting on these items in the CRDC would significantly 

increase the scope and burden of the data collection. Nevertheless, because of the importance of 

this topic, ED proposes to add to the CRDC a new item that collects information on whether 

LEAs have any students enrolled in any distance education courses. 

Changes: ED proposes a new item that serves as an indicator of whether an LEA has any

students enrolled in any distance education courses (DG 924). 

39. Dual Enrollment 

Public Comments

Numerous commenters supported the collection of dual enrollment data, noting that students 

who take college-level courses while in high school are more than one and a half times more 

likely to enroll in, persist through, and complete college. One commenter suggested that schools 

be asked to distinguish between dual enrollment courses related to accelerated academics and 

those related to vocational matters.
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-31

ED’s Response

Discussion: Although the items proposed by the one commenter would provide useful additional 

information to ED, reporting on these items in the CRDC would significantly increase the scope 

and burden of the data collection. Nevertheless, because of the importance of this topic, ED 

proposes to add to the CRDC a new item that collects information on whether schools have any 

students enrolled in any dual enrollment/dual credit programs. 

Changes: ED proposes a new item that serves as an indicator of whether a school has any

students enrolled in any dual enrollment/dual credit programs (DG 925). 

40. Student Chronic Absenteeism 

Public Comments

Many commenters supported collecting data about student absenteeism because chronic 

absenteeism can be a sign of school climate issues that are driving children out of school, and of 

future problems for the child (e.g., dropping out). Some commenters supported counting those 

students absent 15 or more school days, particularly because it would permit easy cross-state and 

district-to-district comparisons. However, a greater number of commenters urged ED to adopt a 

percentage measurement, which was more consistent with existing state measures. In addition, 

some commenters recommended that ED disaggregate the data by excused and unexcused 

absences. 

ED’s Response

Discussion: ED recognizes the value of collecting data on absenteeism based upon the 

percentage of school days missed. The focus on percentages is valuable because student 

absenteeism serves as an early-warning sign for individual students. Thus, when being used for 

early intervention purposes, most authorities suggest absenteeism is appropriately measured by

LEAs during the course of the school year as a percentage, comparing the days missed to the 

days of school already held. 

By contrast, the CRDC collects data after the close of the school year. ED is seeking to 

determine whether in the aggregate there are disparities in student absenteeism among protected 

classes, not to measure the need for individual interventions. Thus, the use of percentages is not 

as pressing. Moreover, ED has determined that school districts in all states could report the 

number of students who were absent for a total of 15 or more days during the school year. 

LEAs can collect and report data on the number of days missed by each individual student more 

easily than they can calculate percentages. By collecting days, rather than percentages, ED will 

be making it simpler for LEAs to provide the data, which will improve accuracy.

Changes: None.

41. LEA Policy that Allows Retention of Third Grade Students 

Public Comments

Many commenters supported collecting data about retention policies. However, other 

commenters indicated that specific information about retention of students in third grade who 

are not proficient in reading does not provide useful information. 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-32

ED’s Response

Discussion: ED has considered the comments and has determined that because ED is continuing 

to collect data on retention on a disaggregated basis, and the collection of information on 

retention policies for third grade reading provides non-disaggregated data for all students, the 

additional burden needed to collect information on these types of retention policies outweighs

the benefit of collecting these data. 

Changes: ED proposes to drop from the CRDC the item that collects data on whether the LEA 

has a policy that allows retention of third grade students who are not proficient in reading (DG 

962). 

SCHOOL FINANCE

42. Non-Personnel Expenditures

Public Comment

Several LEAs and a few SEAs requested that ED eliminate, delay, or clarify the collection of 

non-personnel expenditures. In particular, a few commenters requested that ED cease collecting 

data on non-personnel expenditures, while several commenters expressed concern with the level 

of difficulty in reporting non-personnel expenditures, and questioned whether the data would 

provide an accurate picture of school resources. In addition, several commenters requested that 

ED clarify the types of expenditures that school districts should include and exclude in this 

category. 

Some commenters also expressed their support for ED’s collection of data on non-personnel 

expenditures, and requested that ED expand its collection on non-personnel expenditures at the 

school-level. A few commenters specifically noted their support for the collection of nonpersonnel expenditures data because they considered the data a lens that could be used to 

evaluate resource equity within school districts. One commenter requested that ED expand its 

data collection of non-personnel expenditures to include facility and maintenance costs at the 

school level. Another commenter expressed support for ED’s proposed continued collection of 

total non-personnel expenditures from state and local funds, and requested that ED also collect 

total non-personnel expenditures from federal, state, and local funds.

ED’s Response

Discussion: ED began collecting non-personnel expenditures in the 2008–09 school year with the 

school finance data collection mandated by the American Recovery and Reinvestment Act

(ARRA). See 74 Fed. Reg. 45,431 (Sept. 2, 2009). The 2009–10 and 2011–12 CRDC’s school 

finance data collection mirrored the data collected under the ARRA. ED recognizes the 

challenges in reporting non-personnel expenditures at the school-level and posed a directed 

question to explore alternatives that would provide a measure of resource equity at the schoollevel. ED appreciates the responses received to this question. 

ED’s collection of non-personnel expenditures has focused on the measurement of intra-district 

resource equity. ED appreciates and understands that without more standardized school-level 

accounting systems shared among school districts, the data on non-personnel expenditures may
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-33

not be comparable across districts. To address the commenters’ concerns, ED has revised its 

definition of non-personnel expenditures to clarify the types of expenditures to be included or 

excluded. 

ED appreciates the commenters’ suggestion to expand the non-personnel expenditures data 

collection. At this time ED remains interested in focusing only on non-personnel expenditures 

associated with instruction, pupil support, instructional support, and administration. Therefore, 

the non-personnel expenditures definition will not be amended to include facility and 

maintenance costs. However, in an effort to obtain a more complete picture of a school’s 

resources, and a deeper understanding of the distribution of resources among schools within a 

district, ED has added the collection of total non-personnel expenditures from federal, state, and 

local funds as a proposed new data group. 

Changes: Additional clarification has been added to the definition of non-personnel expenditures.

Also, a new proposed total non-personnel expenditures from federal, state, and local funds data 

group (DG 1000) has been added to the CRDC. 

43. Categories of Personnel and Personnel Expenditures

Public Comment 

A few commenters requested that ED eliminate the collection of school-level personnel 

expenditures given the limited number of school districts tracking expenditures at the school 

building level and absence of standardized protocols for attributing expenditures to individual 

schools. A few other commenters suggested that ED expand the collection of school expenditure 

data to include further disaggregation within the support personnel for pupils and the support 

personnel for instructional staff. Other commenters requested that ED rename “support services 

staff for pupils” to “specialized instructional support personnel” to minimize confusion and align 

the definition with draft reauthorizations of the Elementary and Secondary Education Act

(ESEA). Another commenter requested that ED reduce the number of categories of personnel, 

and collect separately total funds, in addition to state and local funds, spent on these categories. 

In particular, this commenter requested that the personnel categories be limited to teachers, 

support services staff, and school administration staff.

ED’s Response

Discussion: ED appreciates the commenters’ suggestion to further disaggregate the “support 

services staff for pupils” and the “support services staff for instructional staff” categories, and 

the request to align the “support services staff for pupils” category with the currently proposed 

definition in the ESEA reauthorization. The categories of “support services staff for pupils” and 

“support services staff for instructional staff” align with the LEA-level expenditure categories 

collected by NCES and the U.S. Census Bureau’s F-33 survey. The F-33 provides extensive 

supporting documentation to LEAs regarding the types of functions and codes used in 

accounting systems to track personnel expenditures. In an effort to minimize the burden on 

LEAs for reporting this data at the school-level, ED has tried to maintain, and will continue to try

to maintain as close an alignment as possible to the F-33. ED, however, does intend to closely

monitor the staffing categories used in the reauthorization of ESEA, and work on aligning or 

clearly mapping the definitions used in ESEA to the school-level personnel expenditure 

categories proposed in the future for the CRDC. 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-34

In an effort to obtain a more complete picture of a school’s instructional and support personnel 

resources, reduce the reporting burden where possible, and improve the quality of information 

reported by LEAs at the school level, ED has revised the personnel categories, and has expanded 

the collection to include total funds (i.e., federal, state, and local funds), spent on specific 

personnel. In particular, the personnel categories are now limited to teachers, instructional aides, 

support services staff, and school administration staff. Total FTEs and total salary expenditures 

for each personnel category, funded with state and local funds only, and funded with total 

federal, state, and local funds, are currently included in the proposed school finance data

collection. 

Changes: The personnel categories have been revised to include teachers, instructional aides, 

support services staff, and school administration staff. The non-instructional staff category has 

been dropped. The collection has been expanded to include total funds spent on specific 

personnel categories. See DGs 967-969, 971-972, 995-999, and 1001-1002. 

TEACHERS AND OTHER STAFF

44. Certified Teachers

Public Comments

Several commenters strongly opposed ED’s proposed removal of the collection of the FTE of 

teachers in schools meeting all state certification/licensing requirements. In addition, many

commenters requested that ED collect the FTE of teachers deemed highly qualified but who were 

still enrolled in an alternative route-to-certification program. 

ED’s Response

Discussion: Data on the FTE of teachers meeting all state certification/licensing requirements has 

served as an important measure of whether students have access to fully trained teachers. The 

past two administrations of the CRDC have revealed that nearly all teachers are reported as 

meeting state certification and licensing requirements. This may be the result of a 

misunderstanding that the certification and licensing requirement is identical to the “highly 

qualified teacher” (HQT) standard used in No Child Left Behind (NCLB). However, this CRDC 

item was never intended to measure HQT, and the instructions will be revised accordingly to 

make that clear. 

Although most schools and districts report high percentages of certified teachers, ED 

acknowledges that identifying those that do not serves a valuable purpose. Therefore, ED 

proposes to reinstate the teacher certification data element into the CRDC. ED is also giving

serious consideration to how this data element may be revised to gather more useful information 

about students’ access to certified teachers. 

Congress has already required ED to collect data about so-called “alternative certification” 

teachers under Section 145(b) of Public Law No. 112-175. ED determined that the most 

practical and least burdensome approach to respond to the data reporting requirement was to 

collect this information through the EDFacts initiative. On September 12, 2013, ED published a 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-35

notice in the Federal Register soliciting public comment on that proposed data collection. 

Because ED intends to collect this data through a separate collection, and given that duplication 

of data collection place a great burden on LEAs, ED will not add this data element to the 2013–

14 CRDC. Depending on the results of this separate collection, ED will consider whether to add 

the same or similar items to the 2015–16 CRDC.

Changes: ED proposes to reinstate the certification and licensing item (DG 990) used in prior 

collections. 

45. Teachers

Public Comments

Several commenters strongly supported ED’s continued collection of data on teachers’ FTEs, 

length of experience, and absenteeism. In general, commenters suggested that ED continue to 

explore how teacher data elements could be used as measures of educational equity. 

ED’s Response

Discussion: Given the commenters’ overwhelming support of teacher data elements for the 

CRDC, ED proposes to gauge teacher turnover from one year to the next at a school by

collecting the number of teachers employed at a school in the current school year and asking 

how many of those teachers were also employed at that school during the prior school year. . 

Changes: ED proposes to add a new item that collects information on the number of (1) current 

school year teachers and (2) previous school year teachers (DG 1003).

46. Support Staff – Psychologists, Social workers, and Nurses

Public Comments

Several commenters requested that ED expand the current permitted values of “psychologist” 

and “social worker” to include “school psychologist” and “school social worker.” Commenters 

expressed that these professionals are specifically trained to work in school settings and the 

CRDC should reflect the number of personnel with this type of specific training employed by 

school districts. One commenter urged ED to collect data on what percentage of these school 

personnel have received training to work with youth who are lesbian, gay, bisexual, or 

transgender. Several commenters also expressed their support for ED’s expanded collection of 

educational support professionals on the CRDC. Furthermore, numerous commenters urged ED

to collect information regarding nurses. Other commenters recommended that ED not collect 

this data because such data can be inherently misleading.

ED’s Response

Discussion: ED concurs with the commenters who seek to clarify these categories. The intent of 

the support staff item is to collect the number of FTE psychologists and the number of FTE 

social workers—inclusive of school psychologists and school social workers. ED appreciates the 

comments received and has made this clarification to the categories in Attachment A3. In 

addition, ED agrees that nurses should be added as a separate category. 

While collecting and reporting data by more nuanced categories would provide useful additional 

information, reporting on these items in the CRDC would significantly increase the scope and 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-36

burden of the data collection and would make it more difficult to compare aggregate support 

staff numbers. ED’s more general support staff categories are considered appropriate for the 

purpose for identifying inequitable distribution of critical personnel, which would raise civil 

rights concerns.

Changes: ED has clarified the definitions for psychologists and social workers in Attachment A3. 

Also, ED proposes to add a new item to the CRDC that collects the number of FTE nurses (DG 

982). 

47. Security Staff 

Public Comments

Several commenters requested additional information about school resource officers (SROs) or 

other law enforcement on campus. These commenters cautioned that the definition proposed by

ED for SRO did not align with definitions in Federal funding statutes. They also suggested that 

ED add juvenile probation officers and truancy officers to the type of security staff included. 

Other suggested additions were items on (1) whether the security staff was armed, and (2) 

instances in which force was used against students.

ED’s Response

Discussion: ED concurs with the commenters that the definition of SRO originally proposed 

does not align with other collections, and may be difficult to distinguish from the sworn law 

enforcement officer definition. Therefore, ED proposes to eliminate the separate category of 

SROs, and revise the sworn law enforcement officer category to include SROs. In addition, ED

is proposing for the 2013–14 collection to add a yes/no item on whether a sworn law 

enforcement officer was assigned to a school, and postpone mandatory collection of FTE data 

about sworn law enforcement officers and security guards until the 2015–16 collection.

Changes: ED has dropped the SRO category and has revised the sworn law enforcement officer 

definition to include SROs in Attachment A3. ED also proposes a new item for the 2013–14 

CRDC only that collects information on whether sworn law enforcement officers were assigned 

to a school (DG 991).
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-37

IV. REVISED BURDEN ESTIMATES

ED’s revisions to the CRDC, in response to the public comments received during the 60-day

comment period, have resulted in changes to the estimates of burden hours for CRDC 

respondents. The changes to the estimates are described below, and are consistent with the 

revised responses to Questions 12 and 15 in Supporting Statement A. 

For the CRDC, the respondent is the LEA; the LEA must complete one LEA-level survey plus 

one school-level survey for each of its schools. For the school year (SY) 2011–12 CRDC, the 

burden was estimated to be 1,282,492 hours across 16,785 LEA respondents and their 

approximately 96,523 schools with students in membership, based on an estimated 12.8 hours 

per school survey and 2.8 hours per LEA survey on average. For elementary schools, the burden 

was estimated to be 8.1 hours per school survey since several of the data elements are only 

applicable to secondary schools. For secondary schools, the burden was estimated to be 14.9 

hours per school survey. 

The SY 2013–14 CRDC survey content will remain about the same compared to the SY 2011–12 

CRDC survey for Preschool-12 schools. The total burden estimate is 1,342,818 hours. For 

elementary schools, the burden is estimated to be 8.3 hours per school survey since several of the 

data elements are only applicable to secondary schools. For secondary schools, the burden is 

estimated to be 14.6 hours per school survey. By combining several data elements on Advanced 

Placement, the overall reporting burden for secondary schools decreases slightly from SY 2011–

12 to SY 2013–14. Since the number of schools per LEA varies so widely, it should be noted that 

a district with only one school would, on the average, take 2.8 hours for the LEA survey and 12.7

hours for the school survey, for a total of 15.5 hours. An LEA with 10 schools would take 2.8 

hours on the LEA survey and average 12.7 hours on each of the school surveys, for a total of 

129.8 hours. 

The SY 2015–16 CRDC survey content will increase by approximately 17 percent compared to 

the SY 2013–14 CRDC survey for Preschool-12 schools, based on a total burden estimate of 

1,510,075 hours. For elementary schools, the burden is estimated to be 9.3 hours per school 

survey since several of the data elements are only applicable to secondary schools. For 

secondary schools, the burden is estimated to be 15.8 hours per school survey. Because the 

number of schools per LEA varies so widely, it should be noted that a district with only one 

school would, on the average, take 4.2 hours for the LEA survey and 14.1 hours for the school 

survey, for a total of 18.3 hours. An LEA with 10 schools would take 4.8 hours on the LEA 

survey and average 14.1 hours on each of the school surveys, for a total of 145.8 hours. 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-38

Respondents Hours/Response Total Hours

Previous – CRDC (2011) Schools: 96,523 

LEAs: 16,785 

Schools: 12.8 

LEAs: 2.8

Schools:1,235,494 

LEAs:46,998 

Total: 1,282,492

New – CRDC (2013) Schools:101,849 

LEAs: 17,620

Schools: 12.7 

LEAs: 2.8

Schools: 

1,293,482 

LEAs: 49,336

Total: 1,342,818 

New – CRDC (2015) Schools:101,849 

LEAs: 17,620

Schools: 14.1 

LEAs:4.2

Schools: 

1,436,071 

LEAs: 74,004

Total: 1,510,075

New Burden (2015-2011) Schools:+1.6hrs/survey

LEAs: +1.4hrs/survey

Schools:200,577 

LEAs: 27,006

The total respondent cost for the SY 2013–14 CRDC is estimated to be $60,426,810 (1,342,818 

hours multiplied by an average wage of $45 per hour). The total respondent cost for the SY 

2015–16 CRDC is estimated to be $67,953,375 (1,510,075 hours multiplied by an average wage 

of $45 per hour). There is a wide range of hourly salaries associated with the professionals that 

will provide this data, but $45/hour is a reasonable average.

The SY 2013–14 and SY 2015–16 CRDC survey content revisions are a result of program 

change due to agency discretion. Approximately 17,620 LEAs will respond for themselves and 

their 101,849 schools to the request for data. This results in a total burden estimate of 1,342,818

hours for SY 2013–14 and 1,510,075 hours for SY 2015–16.

The annual government cost is similar to the cost of previous surveys, the last of which was the 

2011–12 CRDC, conducted in 2012.
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-39

V. COMPLETE LIST OF ITEMS PROPOSED FOR THE 

CIVIL RIGHTS DATA COLLECTION

All of the items that ED is proposing for the CRDC are presented below. New items that ED is 

proposing to add as mandatory for the 2013–14 school year CRDC are underlined and bolded. 

New items that ED is proposing to add as mandatory for the 2015–16 CRDC are just bolded. 

New items that ED is proposing to add as optional for the 2013–14 CRDC and as mandatory for 

the 2015–16 CRDC are just underlined. Items without formatting were previously collected in 

the 2009–10 CRDC and the 2011–12 CRDC, and are proposed for continued collection.

School & District Characteristics

 Number of public schools (LEA)

 Grades offered (PS-12) (PS refers to preschool and excludes birth-2)

 Whether ungraded school has mainly elementary school age students; middle school 

age students; high school age students; elementary and middle school age students; 

middle and high school age students; elementary middle, and high school age 

students 

 Number of students (PS through grade 12) served in LEA and non-LEA facilities (LEA) 

(for 2013–14 only)

 Number of students (PS through grade 12) enrolled in LEA and served in non-LEA 

facilities only (LEA) 

 Total number of students (preschool through grade 12) enrolled in school (disaggregated 

by race, sex, disability-IDEA, disability-504 only, LEP) 

 Number of students with disabilities (disaggregated by race, sex, LEP) 

 Number of LEP students and number of students enrolled in LEP programs 

(disaggregated by race, sex, disability-IDEA) 

 Whether the school is operating a magnet program for all students or some students 

within the school (and if so, whether entire school population participates in the magnet 

program)

 Whether the school is an alternative school (and if so, for academic or discipline or both)

 Whether the school is focused primarily on serving students with disabilities

 Whether the school is a charter school

 For justice facility only:

o Type of facility (pre- or post-adjudication/conviction or both)

o Number of days that makeup the justice facility’s regular school year

o Total number of hours per week that educational program is offered during 

regular school year

o Number of students who participated in educational program for less than 15 

calendar days; 15-30 calendar days; 31-90 calendar days; 91-180 calendar days; 

more than 180 calendar days.

 Number of single-sex academic classes (with males only; with females only) in the 

following courses/subject areas:

o Algebra I, Geometry, and/or Algebra II
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-40

o Other mathematics

o Science

o English/reading/language arts

o Other academic subjects

 Whether LEA has civil rights coordinators for discrimination against students on 

basis of sex, race, and disability (and contact information) (LEA)

 Whether LEA is covered by desegregation order or plan (LEA)

Discipline

 Students (K-12) who received one or more in-school suspension:

o Number of K-12 students without disabilities who received one or more in-school 

suspension (disaggregated by race, sex, LEP)

o Number of K-12 students with disabilities who received one or more in-school 

suspension (disaggregated by race, sex, disability-504 only, LEP)

 Students who received one out-of-school suspension:

o Number of preschool students who received one out-of-school suspension 

(disaggregated by race, sex, disability-IDEA, LEP) 

o Number of K-12 students without disabilities who received one out-of-school 

suspension (disaggregated by race, sex, LEP)

o Number of K-12 students with disabilities who received one out-of-school 

suspension (disaggregated by race, sex, disability-504 only, LEP)

 Students who received more than one out-of-school suspension: 

o Number of preschool students who received more than one out-of-school 

suspension (disaggregated by race, sex, disability-IDEA, LEP) 

o Number of K-12 students without disabilities who received more than one out-ofschool suspension (disaggregated by race, sex, LEP)

o Number of K-12 students with disabilities who received more than one out-ofschool suspension (disaggregated by race, sex, disability-504 only, LEP)

 Number of preschool students who were expelled (disaggregated by race, sex, disabilityIDEA, LEP) 

 Students (K-12) who were expelled (with educational services; without educational 

services; because of zero-tolerance policies):

o Number of K-12 students without disabilities who were expelled (with 

educational services; without educational services; because of zero-tolerance 

policies) (disaggregated by race, sex, LEP)

o Number of K-12 students with disabilities who were expelled (with educational 

services; without educational services; because of zero-tolerance policies) 

(disaggregated by race, sex, disability-504 only, LEP)

 Students (K-12) who were transferred for disciplinary reasons (to alternative school; to 

regular school):

o Number of K-12 students without disabilities who were transferred for 

disciplinary reasons (to alternative school; to regular school) (disaggregated by

race, sex, LEP)
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-41

o Number of K-12 students with disabilities who were transferred for disciplinary

reasons (to alternative school; to regular school) (disaggregated by race, sex, 

disability-504 only, LEP)

 Students (K-12) who were referred to law enforcement agency or official: 

o Number of K-12 students without disabilities who were referred to law 

enforcement agency or official (disaggregated by race, sex, LEP)

o Number of K-12 students with disabilities who were referred to law enforcement 

agency or official (disaggregated by race, sex, disability-504 only, LEP)

 Students (K-12) who were arrested for school-related activity:

o Number of K-12 students without disabilities who were arrested for school-related 

activity (disaggregated by race, sex, LEP)

o Number of K-12 students with disabilities who were arrested for school-related 

activity (disaggregated by race, sex, disability-504 only, LEP)

 Students who received corporal punishment:

o Number of preschool students (ages 3-5) who received corporal punishment 

(disaggregated by race, sex, disability-IDEA, LEP)

o Number of K-12 students without disabilities who received corporal punishment 

(disaggregated by race, sex, LEP)

o Number of K-12 students with disabilities who received corporal punishment 

(disaggregated by race, sex, disability-504 only, LEP)

 Number of instances of corporal punishment that students (preschool through grade 12) 

received (disaggregated by students without disabilities, students with disabilities)

 Number of school days missed by students who received out-of-school suspensions 

(disaggregated by race, sex, disability-IDEA, disability-504 only, LEP) 

 Documented incidents that occurred at the school that would trigger discipline, including 

referrals to law enforcement and arrests:

o Number of incidents of robbery with a weapon

o Number of incidents of robbery with a firearm or explosive device

o Number of incidents of robbery without a weapon

o Number of incidents of physical attack or fight with a weapon

o Number of incidents of physical attack or fight with a firearm or explosive device

o Number of incidents of physical attack or fight without a weapon

o Number of incidents of threats of physical attack with a weapon

o Number of incidents of threats of physical attack with a firearm or explosive 

device

o Number of incidents of threats of physical attack without a weapon

o Number of incidents of rape or attempted rape

o Number of incidents of sexual battery (other than rape)

o Number of incidents of possession of a firearm or explosive device

o Whether any of the school’s students, faculty, or staff died as a result of a 

homicide committed at the school

o Whether there has been at least one incident at the school that involved a shooting 

(regardless of whether anyone was hurt)
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-42

Harassment or bullying 

 Number of reported allegations of harassment or bullying of K-12 students on the basis 

of: sex; race, color, or national origin; disability; sexual orientation; religion

 Number of K-12 students reported as harassed or bullied on the basis of: sex; race, color, 

or national origin; disability (disaggregated by race, sex, disability-IDEA, disability-504 

only, LEP)

 Number of K-12 students disciplined for engaging in harassment or bullying on the basis 

of: sex; race, color, or national origin; disability (disaggregated by race, sex, disabilityIDEA, disability-504 only, LEP) 

 Existence of harassment or bullying policy on the basis of race, sex, or disability

Restraint and Seclusion 

 Students (K-12) subjected to mechanical restraint:

o Number of non-IDEA K-12 students subjected to mechanical restraint 

(disaggregated by race, sex, disability-504 only, LEP) 

o Number of K-12 students with disabilities (IDEA) subjected to mechanical 

restraint (disaggregated by race, sex, LEP)

 Students (K-12) subjected to physical restraint:

o Number of non-IDEA K-12 students subjected to physical restraint (disaggregated 

by race, sex, disability-504 only, LEP) 

o Number of K-12 students with disabilities (IDEA) subjected to physical restraint 

(disaggregated by race, sex, LEP)

 Students (K-12) subjected to seclusion:

o Number of non-IDEA K-12 students subjected to seclusion (disaggregated by 

race, sex, disability- 504 only, LEP) 

o Number of K-12 students with disabilities (IDEA) subjected to seclusion 

(disaggregated by race, sex, LEP)

 Number of instances of mechanical restraint, physical restraint, seclusion (disaggregated 

by students without disabilities, students with disabilities-IDEA, students with 

disabilities-504 only) 

Single Sex Interscholastic Athletics

 Number of single-sex interscholastic athletics high school sports (with males only; with 

females only)

 Number of single-sex interscholastic athletics high school teams (with males only; with 

females only) 

 Number of student participants on single-sex interscholastic athletics high school sports 

teams (with males only; with females only)
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-43

Early Childhood Education 

 Whether LEA’s early childhood program(s) serve non-IDEA children birth-2 (LEA)

 Preschool length offered (full-day, part-day) and cost (free, partial charge, full charge)

(LEA)

 Number of students served by LEA in preschool programs in LEA and non-LEA 

facilities (disaggregated by age – 3, 4, 5) (LEA)

 Whether preschool is provided to: all students, students with disabilities (IDEA), students 

in Title I schools, students from low income families (LEA)

 Whether preschool serves non-IDEA students age 3; age 4; age 5 (LEA)

 Number of students ages 3-5 enrolled in preschool (disaggregated by race, sex, disabilityIDEA, LEP) 

 Whether the school’s preschool program serves non-IDEA students (Yes/No by age-

- 3, 4, 5)

 Kindergarten length offered (full-day, part-day) and cost (free, partial charge, full 

charge) (LEA)

Pathways to College and Career

 Number of students enrolled in gifted & talented programs (disaggregated by race, sex, 

disability-IDEA, LEP) 

 Whether LEA has any students enrolled in any distance education courses (Yes/No)

 Number of students enrolled in distance education courses (disaggregated by race, sex, 

disability-IDEA, LEP) (LEA)

 Whether school has any students enrolled in dual enrollment/dual credit program 

(Yes/No)

 Number of students enrolled in at least one dual enrollment/dual credit program 

(disaggregated by race, sex, disability-IDEA, LEP)

 Whether the school has any students who participate in at least one credit recovery 

program that allows them to earn missed credit to graduate from high school 

(Yes/No)

 Number of students who participate in at least one credit recovery program 

 Number of students absent 15 or more school days (disaggregated by race, sex, 

disability-IDEA, disability-504 only, LEP)

 Number of students enrolled in the International Baccalaureate (IB) Diploma Programme 

(disaggregated by race, sex, disability-IDEA, LEP)

 Number of different AP courses provided 

 Whether students are allowed to self-select for participation in AP courses 

 Number of students enrolled in at least one AP course (disaggregated by race, sex, 

disability-IDEA, LEP)

 Number of students enrolled in at least one AP course in specific subject area 

(disaggregated by race, sex, disability, LEP) 

o AP math of any kind

o AP science of any kind

o Other AP subjects of any kind (including foreign language)
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-44

 Number of students who took one or more AP exams for one or more (which may 

include all) AP courses enrolled in (disaggregated by race, sex, disability-IDEA, LEP)

 Number of students who were enrolled in one or more AP courses but who did not take 

any AP exams (disaggregated by race, sex, disability-IDEA, LEP)

 Number of students who received a qualifying score on one or more AP exams for one or 

more (which may include all) AP courses enrolled in (disaggregated by race, sex, 

disability-IDEA, LEP)

 Number of students who did not receive a qualifying score on any AP exams for the one 

or more AP courses enrolled in (disaggregated by race, sex, disability-IDEA, LEP)

 Number of science classes in grades 9-12 (Biology, Chemistry, Physics) 

 Number of students enrolled in science classes in grades 9-12 (Biology, Chemistry, 

Physics) (disaggregated by race, sex, disability-IDEA, LEP) 

 Number of math classes in grades 9-12 (Algebra II, Advanced Math, Calculus) 

 Number of Algebra I classes in grades 9-12 (for 2015–16 only) 

 Number of Algebra I classes in grades 7-12 (for 2013–14 only)

 Number of Algebra I classes in grades 7-8 (for 2015–16 only)

 Number of students enrolled in Algebra I in grade 7 (for 2015–16 only) 

 Number of students enrolled in Algebra I in grade 8 (disaggregated by race, sex, 

disability-IDEA, LEP) (for 2015–16 only) 

 Number of students enrolled in Algebra I in grades 7-8 (disaggregated by race, sex, 

disability-IDEA, LEP) (for 2013–14 only) 

 Number of students enrolled in Algebra I in grades: 9-10; 11-12 (disaggregated by race, 

sex, disability-IDEA, LEP)

 Number of students who passed Algebra I in grade 7 (for 2015–16 only)

 Number of students who passed Algebra I in grade 8 (disaggregated by race, sex, 

disability-IDEA, LEP) (for 2015–16 only)

 Number of students who passed Algebra I in grades 7-8 (disaggregated by race, sex, 

disability-IDEA, LEP) (for 2013–14 only) 

 Number of students who passed Algebra I in grades: 9-10; 11-12 (disaggregated by race, 

sex, disability-IDEA, LEP)

 Number of Geometry classes in grades 7-12 (for 2013–14 only)

 Number of Geometry classes in grades 9-12 (for 2015–16 only)

 Number of students enrolled in Geometry in grade 8 (for 2015–16 only)

 Number of students enrolled in Geometry in grades 7-12 (disaggregated by race, sex, 

disability-IDEA, LEP) (for 2013–14 only)

 Number of students enrolled in Geometry in grades 9-12 (disaggregated by race, 

sex, disability-IDEA, LEP) (for 2015–16 only)

 Number of students enrolled in math courses in grades 9-12 (Algebra II, Advanced Math, 

Calculus) (disaggregated by race, sex, disability-IDEA, LEP)

 Number of students who took SAT, ACT, or both, anytime during school year 

(disaggregated by race, sex, disability-IDEA, LEP)

 GED preparation program (LEA):

o Number of students ages 16-19 who participated in LEA-operated GED prep 

program (disaggregated by race, sex, disability-IDEA, LEP)
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-45

o Number of students ages 16-19 who participated in LEA-operated GED prep 

program, succeeded on GED test, and received high school equivalency credential 

(disaggregated by race, sex, disability-IDEA, LEP)

 Number of students retained in specified grade, by grade (K-12) (disaggregated by race, 

sex, disability-IDEA; disability-504 only, LEP)

School finance

 K-12 personnel FTEs and salaries at the school level (funded with state and/or local 

funds)

o Number of FTE teachers and amount of their salaries 

o Amount of instructional staff (teachers and aides) salaries (for 2013–14 only)

o Number of FTE instructional aides and amount of their salaries

o Number of FTE support services staff (for pupils and for instructional staff) and 

amount of their salaries

o Number of FTE school administration staff and amount of their salaries

o Total amount of instructional and support personnel salaries

 Preschool-12 personnel FTEs and salaries at the school level (funded with federal, state,

and/or local funds)

o Amount of teacher salaries 

o Number of FTE instructional aides and amount of their salaries

o Number of FTE support services staff (for pupils and for instructional staff) and 

amount of their salaries

o Number of FTE school administration staff and amount of their salaries

o Total amount of instructional and support personnel salaries

 Total amount of non-personnel expenditures at the school level

o Amount of non-personnel expenditures (funded with state and/or local funds)

o Amount of non-personnel expenditures (funded with federal, state, and/or local 

funds)

Teachers (funded with federal, state, and/or local funds)

 Number of current school year teachers (preschool through grade 12)

 Number of previous school year teachers (preschool through grade 12)

 Number of FTE teachers (preschool through grade 12) 

 Number of FTE first-year teachers (preschool through grade 12) 

 Number of FTE second-year teachers (preschool through grade 12)

 FTE of teachers meeting all state licensing/certification requirements 

 Number of FTE teachers absent more than 10 school days (excluding professional 

development) (preschool through grade 12) 

 Number of FTE school counselors (preschool through grade 12) 

 Number of FTE psychologists (preschool through grade 12) 

 Number of FTE social workers (preschool through grade 12) 

 Number of FTE nurses (preschool through grade 12) 

 Number of FTE security guards (preschool through grade 12) 
Attachment B – Response to Public Comment

CRDC Data Set for School Years 2013–14 and 2015–16

Page B-46

 Whether a sworn law enforcement officer (including school resource officer) was 

assigned to the school (Yes/No) (for 2013–14 only)

 Number of FTE sworn law enforcement officers (including school resource officers) 

(preschool through grade 12)