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FOR PAPERWORK REDUCTION ACT 

SUBMISSION

Mandatory Civil Rights Data Collection

November 2013

SUPPORTING STATEMENT, PART A: 

JUSTIFICATION

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 Revised after 60-day public comment period.

The Civil Rights Data Collection (CRDC) is a longstanding and critical aspect of the overall 

enforcement and monitoring strategy used by the Department of Education’s Office for Civil 

Rights (OCR) to ensure that recipients of the Department’s federal financial assistance do not 

discriminate on the basis of race, color, national origin, sex, and disability. OCR relies on 

CRDC data as it investigates complaints alleging discrimination, determines whether the federal 

civil rights laws it enforces have been violated, initiates proactive compliance reviews to focus 

on particularly acute or nationwide civil rights compliance problems, and provides policy

guidance and technical assistance to educational institutions, parents, students, and others.

The Department of Education (the Department) has collected CRDC data on school 

characteristics, programs, services, and student outcomes on a biennial basis since 1968. For 

many years, the collection operated as the Elementary and Secondary School Civil Rights 

Compliance Report (approved by OMB as control # 1870-0500). Recent administrations of the 

CRDC—2004, 2006, and 2009-10—were conducted primarily on-line through a survey tool in 

partnership with EDFacts. As such, through 2011, it was cleared under OMB control # 1875-

0240. However, beginning with the 2013-14 CRDC, OCR is submitting this new separate 

clearance package for the CRDC. 
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With the exception of two state education agencies (SEAs), each Local Education Agency (LEA) 

that is included submits an LEA summary survey and a survey about each school in the LEA

(one SEA provided all the data on behalf of its LEAs and another SEA provided some data on 

behalf of its LEAs during this time). Generally, the collection has included a sample of about 

6,000-7,000 LEAs, although the 1976, 2000, and 2011-12 collections were universal collections 

from all LEAs. The CRDC is a mandatory data collection. 

Responses to, and changes made as a result of, comments received during the 60-day public 

comment period from June 21 through August 21, 2013, are primarily addressed and 

reflected in Attachment B. In Supporting Statement A, responses to Questions 12 and 15, 

and the list of items in the Appendix were amended in response to the comments received. 

1. Explain the circumstances that make the collection of information necessary. 

Identify any legal or administrative requirements that necessitate the collection. 

Attach a hard copy of the appropriate section of each statute and regulation 

mandating or authorizing the collection of information, or you may provide a valid 

URL link or paste the applicable section. Please limit pasted text to no longer than 

3 pages. Specify the review type of the collection (new, revision, extension, 

reinstatement with change, reinstatement without change). If revised, briefly 

specify the changes. If a rulemaking is involved, make note of the sections or 

changed sections, if applicable.

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), located at

http://www.law.cornell.edu/uscode/text/20/3413). 

The civil rights laws enforced by the 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 the 

Department’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, located at http://www2.ed.gov/policy/rights/reg/ocr/index.html). In 

addition, pursuant to a delegation by the Attorney General of the United States, OCR shares in 

the enforcement of Title II of the Americans with Disabilities Act of 1990, which prohibits 

discrimination based on disability. Any data collection that OCR has determined to be necessary

to ascertain or ensure compliance with these laws is mandatory. 
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OCR also works with Department offices to help them effectively carry out programs of Federal 

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

generally, Sections 201, 202(g), 411(a), and 412 of the Department of Education Organization 

Act (20 U.S.C. §§ 3411, located at http://www.law.cornell.edu/uscode/text/20/3411, 3412(g), 

located at http://www.law.cornell.edu/uscode/text/20/3412, 3471(a), located at 

http://www.law.cornell.edu/uscode/text/20/3471, and 3472, located at 

http://www.law.cornell.edu/uscode/text/20/3472, respectively). OCR works with the 

Department’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, located at http://www.law.cornell.edu/uscode/text/20/7913) 

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, 

located at http://www.law.cornell.edu/uscode/text/20/7914) 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 the Department to mandate that LEAs respond to this data collection.

As with previous CRDC collections, the purpose of the 2013-14 and 2015-16 CRDC is to obtain 

vital data related to the civil rights laws’ requirement that public LEAs and elementary and 

secondary schools provide equal educational opportunity. OCR has extensively analyzed the 

uses of every data element collected in 2011-12 and sought advice from experts across the 

Department to refine, improve, and where appropriate, add or remove data elements from the 

collection. The 2013-14 and 2015-16 CRDC redesign effort ensured that, while several new 

indicators were added to the collection, data elements also were removed where appropriate. 

OCR also made the CRDC data definitions and metrics consistent with other mandatory

collections across the Department wherever possible. 

The proposed additions and changes to the 2013-14 and 2015-16 CRDC reflect the need for a 

deeper understanding of and accurate data about the educational opportunities and school context 

for our nation’s students. The information in the next few paragraphs summarizes the changes 

proposed for some general areas of information collected in the CRDC. For a more detailed list 

of what is proposed for 2013-14 and 2015-16, including retained elements and proposed 

additions, see Appendix 1 to this Supporting Statement A. [Note for an updated list reflecting 

the revisions after the 60-day comment period, see Section V of Attachment B.]School and 

District Characteristics

The CRDC will continue to cover such topics as the number of magnet and alternative schools, 

districts operating under desegregation orders or plans, and student membership disaggregated 

by race, ethnicity, sex, disability, and English learner status. The proposed changes provide 

greater context to deepen OCR’s understanding of the schools and districts in which students 

receive their education. For example, items about civil rights coordinators in each district will 

measure compliance with civil rights regulations and permit OCR to communicate with 

coordinators, and new items on the educational programs in justice facilities will provide a more 
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accurate account of the educational opportunities available to students. (See attachment A-5 for 

a directed question on this topic.) 

Discipline

The 2009-10 CRDC made public long-hidden data about indicators of school culture, including: 

numbers of students, broken down by demographic characteristics, who were suspended once 

and multiple times, expelled, and arrested in school; and new information about the use of 

restraint and seclusion in the classroom. The proposed changes provide additional information 

about the amount of time students are suspended; this reflects the findings of OCR enforcement 

actions and other reports that have shown that disproportionality in discipline extends beyond the 

type of punishment (in- or out-of-school suspensions) to length of time out of class. Other 

proposed changes include additional attention to preschool discipline practices and corporal 

punishment. Proposed refinements to existing expulsion items are intended to make clear that 

such involuntary transfers from a student's school for discipline reasons constitute expulsion, 

regardless of label, and to track where such students are sent to receive educational services 

(regular or alternative school). Other proposed changes will incorporate into the CRDC critical 

data elements taken from the NCES School Survey on Crime and Safety to obtain school 

violence and safety information.

Harassment and Bullying 

Safe environments are critical to learning. Since the 2009, the CRDC has provided a lens on 

school climate and the bullying and harassment that students too often endure on the basis of 

race, sex, and disability. The proposed changes add sexual orientation and religion to types of 

allegations of harassment that need to be counted, but the proposal does not extend the reporting 

requirements about demographic data of the alleged complainant or harasser. (Note that the 

proposed changes will not authorize schools to inquire about the sexual orientation or religion of 

students. In classifying the allegations of harassment or bullying, respondents are directed to 

look to the likely motives of the alleged harasser/bully, and not the actual status of the alleged 

victim. See more information in response to question 11.)

Early Childhood Education 

The CRDC continues to cover such topics as children’s access to and participation in LEAoperated early childhood education programs. In order to deepen OCR’s understanding of 

services provided to our youngest students, OCR is proposing to expand the collection of early 

childhood experience elements to learn more about how programs serve the youngest children. 

Pathways to College and Career

The CRDC continues to cover topics such as students’ participation in Algebra and other 

college-preparatory subjects, grade-level retention, and access to Advanced Placement (AP) 

courses. The proposed changes provide a more accurate account of course taking and passing 

opportunities. The previous collection allowed masking of important trends including middle 

school math opportunities and whether or not students have access to dual enrollment and/or 
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credit recovery. Proposed changes also reflect efforts to reduce burden (and better focus on

STEM opportunities) by streamlining AP course-taking information. Another proposed change 

measures which schools have high and low chronic absenteeism rates. Chronic absenteeism can 

be a sign of serious school climate issues that are driving children out of school. It is also a 

warning sign of serious problems in the future for the child (e.g., dropping out). 

School finance (funded with state and local funds)

Since 2009, the CRDC has been a source of information for exploring resource equity among 

schools within a district. The proposed changes would provide finer-grained data on total 

personnel expenditures between schools for teachers and instructional aides, administrators, and 

those who provide critical support services for students and instruction. (See Attachment A-5 for 

directed question on this topic.)

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

Since 2009, the CRDC has been a resource for data on the number of first- and second-year 

teachers in schools, the number of high school counselors in schools, and teacher absenteeism. 

The proposed changes will add school support and security staffing data for every school. OCR 

also proposes to incorporate into the CRDC critical data elements taken from the NCES Schools 

and Staffing Survey. These data will deepen our understanding of how to make schools and 

communities safer and allow OCR to compare resources available to schools of different 

populations. 

2. Indicate how, by whom, and for what purpose the information is to be used. 

Except for a new collection, indicate the actual use the agency has made of the 

information received from the current collection.

Since 1968, the CRDC (and its predecessor surveys) have served as the cornerstone for federal 

enforcement of children’s civil rights in public schools. OCR relies on CRDC data as it 

investigates complaints alleging discrimination, determines whether the federal civil rights laws 

it enforces have been violated, initiates proactive compliance reviews to focus on particularly 

acute or nationwide civil rights compliance problems, and provides policy guidance and 

technical assistance to educational institutions, parents, students, and others. 

In 2009, OCR extensively redesigned the CRDC. It sought input from a wide range of experts 

within the Department and throughout federal government, and from stakeholders from state and 

local education agencies and the broader education community, through meetings and two public 

comment periods. Sources of advice and expertise included the Education Information 

Management Advisory Committee (a committee of the Council of Chief State School Officers), 

the National Center for Education Statistics Forum, state data coordinators from the 

Department’s EDFacts data submission system, and a sampling of LEAs to ensure coordination 

among data collections and to minimize the burden on LEAs. OCR attorneys and staff from 

throughout the country were heavily involved to ensure the collection’s maximum utility in the 

investigatory process. The resulting 2009-10 CRDC was more detailed, providing new data on 
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college and career-readiness, discipline, teacher equity, retention, access to pre-K programs, 

bullying and harassment, and school-level expenditures, and disaggregating data by race, 

ethnicity, sex, disability, and English learner status. 

The transformed 2009-10 CRDC has been heralded as a first-of-its-kind opportunity gap data 

tool that is allowing citizens and schools nationwide to identify educational equity-related 

problems and their solutions. For OCR staff across the country, as they launch investigations, the 

CRDC is used to prepopulate their data requests so that recipients do not have to make duplicate 

reports and submissions. This expedites investigations and reduces the reporting burdens.

The 2011-12 CRDC built on these efforts by adding more data checks (to ensure the data’s 

integrity), and by combining the fall snapshot data and spring outcome data collection periods 

into a single collection period (to minimize the burden to respondents). 

The CRDC’s utility reaches far beyond OCR to the entire Department, to other agencies and to 

researchers and policymakers across the nation. CRDC data have also been used by other 

Department offices for purposes such as monitoring compliance with requirements for federal 

professional development funding, monitoring states under ESEA flexibility waivers, defining 

program requirements on discipline disparities in the Race to the Top district competition, and 

evaluating the Office of English Language Acquisition’s (OELA) programs and activities. 

Individual offices also rely on CRDC data to analyze issues and prepare reports on topics such as 

achievement gaps. 

State and federal agencies, policymakers, researchers, and many others outside of the 

Department also use the CRDC data. (Data are available to the public via the Web in privacyprotected format.) For each of these constituencies, the CRDC is an invaluable source of 

information about access to educational opportunities in our nation’s public schools. 

Researchers, advocacy organizations, and news media have used CRDC data to identify possible 

civil rights concerns in our nation’s schools and to find models of success. State legislatures and 

state boards of education have relied on CRDC data in crafting and revising educational policies. 

And for LEAs and schools across the country, the CRDC data is a critical tool for self-analysis 

and a mechanism for highlighting and correcting areas of educational concern. 

3. Describe whether, and to what extent, the collection of information involves the use 

of automated, electronic, mechanical, or other technological collection techniques 

or forms of information technology, e.g. permitting electronic submission of 

responses, and the basis for the decision of adopting this means of collection. Also 

describe any consideration given to using technology to reduce burden.

Like recent collections, the primary collection instrument for the 2013-14 and 2015-16 CRDC

will be a Web-based system; users will either upload data files and/or enter the data in response 

to questions displayed on the screen; and the data will be transmitted directly into a database. To 

reduce burden, the Department will utilize a user-friendly interactive tool that ensures schools 

and LEAs only have to answer applicable questions. Guiding questions facilitate this approach 
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and may precede data group tables. For example, if a user indicates the school serves only 

elementary students, the questions about high schools will not be presented. Similarly, a high 

school will be asked if the school provided Advanced Placement (AP) courses. If the user 

answers “No,” then the series of tables about AP will be skipped; if the user answers “Yes,” then 

the tables about AP will be presented.

Flat file submissions, such as Excel files, are allowed for districts that have the capacity to create 

them; and paper submissions are allowed for LEAs with no Internet connectivity or limited Web 

access. States that wish to submit data on behalf of their LEAs are allowed to do so, as they have 

been in the past. 

Before 2011-12, LEAs had to choose to submit all their data either by flat file submission (FFS) 

or through the Web-based system. For the 2011-12 CRDC, OCR implemented improvements to 

the web collection tool to allow LEAs the flexibility to use both methods of submitting their data 

to the CRDC. As a result, the percentage of LEAs using FFS increased significantly, from 6% 

in 2009 to 26% in 2011. 

The flexibility in submission methods allows LEAs to submit whatever portion of the CRDC is 

included in their student information system in flat files. These flat files then “pre-populate” the 

Web-based screens and allow the school (or another department within the school district) to 

either verify or complete the remaining sections of the CRDC. This option will continue to be 

available in the 2013-14 and 2015-16 collections.

Through computer control of the data collection process and the monitoring of responses, the 

computer-based system offers the capacity for substantial improvements in data quality and data 

collection efficiency over a survey conducted using paper and pencil. Incidents of missing and 

inconsistent data are greatly reduced since questionnaire skip patterns are computer controlled. 

Moreover, invalid entries, contradictory entries, or entries inconsistent with available data on the 

school or LEA are questioned by the computer and must be resolved or confirmed by the 

respondent during the self-directed Web instrument data collection. 

4. Describe efforts to identify duplication. Show specifically why any similar 

information already available cannot be used or modified for use for the purposes 

described in Question 2 above.

The CRDC is the unique source of data for the vast majority of data elements collected. Starting 

with the 2009-10 CRDC, OCR leveraged data submitted to the Department by state departments 

of education to reduce the burden on LEAs. In addition, in planning the 2009-10 CRDC, OCR 

carefully examined all data groups already collected by EDFacts and dropped several tables 

previously in the CRDC because the data are available through the state-based portion of 

EDFacts, the EDEN Submission System (ESS). OCR continues to use this approach for the 

CRDC. 
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For the 2013-14 and 2015-16 CRDC, OCR also met with program offices across the Department 

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

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

National Center on Educational Statistics (NCES) to align the definitions used for the collection 

of school-level expenditures with the definitions used by NCES and Census in the collection of 

district-level expenditures. In order to consolidate and centralize preschool-12 data collections, 

definitions need to be standardized. If the same term has multiple definitions, the reporting 

burden on LEAs and SEAs increases significantly. Therefore, the same definitions of terms are 

used whenever possible.

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

with key staff throughout the Department 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. 

5. If the collection of information impacts small businesses or other small entities, 

describe any methods used to minimize burden. A small entity may be (1) a small 

business which is deemed to be one that is independently owned and operated and 

that is not dominant in its field of operation; (2) a small organization that is any 

not-for-profit enterprise that is independently owned and operated and is not 

dominant in its field; or (3) a small government jurisdiction, which is a government 

of a city, county, town, township, school district, or special district with a 

population of less than 50,000.

The CRDC allows small districts with limited or no Web access to submit via a paper form. For 

the 2011-12 CRDC, 0.1% (16 out of nearly 17,000) of LEAs submitted the CRDC through a 

paper form. Additionally, smaller LEAs often face additional challenges with the timing of the 

CRDC collection. At the close of the school year, small and rural LEAs “roll over” their data 

systems, effectively closing out one school year and beginning the next. The end of year “roll 

over” can make accessing data from the prior school year challenging. With advice from the 

CRDC workgroup, which includes representatives from geographically diverse LEAs and SEAs, 

OCR created a set of pre-collection tools to allow smaller LEAs to collect and store their CRDC 

data in a format that could be easily uploaded into the CRDC submission system. With these 

tools, smaller LEAs could store their CRDC data in ready-to-use flat files once the survey

submission website opened in the fall of the next school year. These pre-collection tools were 

widely used and OCR received many positive comments regarding their ease of use. As a result, 

OCR plans to continue to provide these tools for the 2013-14 and 2015-16 CRDC. 
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6. Describe the consequences to Federal program or policy activities if the collection is 

not conducted or is conducted less frequently, as well as any technical or legal 

obstacles to reducing burden.

Education in this nation is on an annual cycle where success and failure are measured and 

reported annually and civil rights complaints must be investigated and resolved on an ongoing 

basis. The most recent CRDC contained data from the fall and spring of school year 2011-12. It 

is critical that more recent information be available so that the Department can carry out its 

mandate to ensure civil rights under the applicable laws. Further, OCR enforcement offices rely 

on data in the CRDC to prepopulate data requests to districts and schools when conducting 

investigations and compliance reviews. It is important that OCR have recent data to conduct 

these investigations. 

7. Explain any special circumstances that would cause an information collection to be 

conducted in a manner:

 requiring respondents to report information to the agency more often than 

quarterly;

 requiring respondents to prepare a written response to a collection of 

information in fewer than 30 days after receipt of it;

 requiring respondents to submit more than an original and two copies of any 

document;

 requiring respondents to retain records, other than health, medical, government 

contract, grant-in-aid, or tax records for more than three years;

 in connection with a statistical survey, that is not designed to produce valid and 

reliable results than can be generalized to the universe of study;

 requiring the use of a statistical data classification that has not been reviewed 

and approved by OMB;

 that includes a pledge of confidentiality that is not supported by authority 

established in statute or regulation, that is not supported by disclosure and data 

security policies that are consistent with the pledge, or that unnecessarily 

impedes sharing of data with other agencies for compatible confidential use; or

 requiring respondents to submit proprietary trade secrets, or other confidential 

information unless the agency can demonstrate that it has instituted procedures 

to protect the information’s confidentiality to the extent permitted by law.

This information collection activity does not have special circumstances that would include any

of the requirements listed above.

8. As applicable, state that the Department has published the 60 and 30 Federal 

Register notices as required by 5 CFR 1320.8(d), soliciting comments on the 

information collection prior to submission to OMB. Summarize public comments 

received in response to that notice and describe actions taken by the agency in 
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response to these comments. Specifically address comments received on cost and 

hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on 

the availability of data, frequency of collection, the clarity of instruction and record 

keeping, disclosure, or reporting format (if any), and on the data elements to be 

recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained 

or those who must compile records should occur at least once every 3 years – even if 

the collection of information activity is the same as in prior periods. There may be 

circumstances that may preclude consultation in a specific situation. These 

circumstances should be explained.

The Department will provide the public an opportunity to comment through both 60-day and 30-

day notices.

Additionally, during the two-day technical working group (referenced in response to question 4), 

OCR met with key staff throughout the Department who offered their recommendations on 

improvements to data items. Following the technical working group review of the CRDC data 

elements, the full list of proposed new data elements and data elements OCR proposed to no 

longer collect was reviewed and approved by the Department’s Policy Committee, which sought 

to ensure the collection of these data elements was necessary, permitted and non-duplicative.

In addition to publishing a notice in the Federal Register, OCR will conduct outreach to LEAs 

and SEAs. On a semi-annual basis, OCR convenes a workgroup of representatives from 

geographically diverse LEAs and SEAs to provide guidance and advice on ways to improve the 

CRDC. The CRDC workgroup plays a vital role in understanding the availability of data, within 

either state or local data systems, and the burden of reporting new or continuing data items. 

9. Explain any decision to provide any payment or gift to respondents, other than 

remuneration of contractors or grantees with meaningful justification.

There is no current remuneration for any school district or school. 

10. Describe any assurance of confidentiality provided to respondents and the basis for 

the assurance in statute, regulation, or agency policy. If personally identifiable 

information (PII) is being collected, a Privacy Act statement should be included on 

the instrument. Please provide a citation for the Systems of Record Notice and the 

date a Privacy Impact Assessment was completed as indicated on the IC Data 

Form. A confidentiality statement with a legal citation that authorizes the pledge of 

confidentiality should be provided. Requests for this information are in accordance 

with the following ED and OMB policies: Privacy Act of 1974, OMB Circular A108 – Privacy Act Implementation – Guidelines and Responsibilities, OMB 
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Circular A-130 Appendix I – Federal Agency Responsibilities for Maintaining 

Records About Individuals, OMB M-03-22 – OMB Guidance for Implementing the 

Privacy Provisions of the E-Government Act of 2002, OMB M-06-15 –

Safeguarding Personally Identifiable Information, OM:6-104 – Privacy Act of 1974 

(Collection, Use and Protection of Personally Identifiable Information). If the 

collection is subject to the Privacy Act, the Privacy Act statement is deemed 

sufficient with respect to confidentiality. If there is no expectation of 

confidentiality, simply state that the Department makes no pledge about the 

confidentially of the data.

There has been no assurance of confidentiality provided to the respondents beyond the 

agreement to protect individual student information under the Federal Educational Rights and 

Privacy Act. The CRDC does not collect any personally identifiable information (PII). 

Confidentiality issues with the CRDC are specific to the amount of data found in a “cell” that 

might make the identification of an individual student or staff member possible when combined 

with other information not collected in the CRDC. OCR is committed to protecting individual 

privacy by not making public any data in rows or columns where a single cell is below a certain 

threshold of size. OCR will continue to review the submitted data for any other security 

requirements.

11. Provide additional justification for any questions of a sensitive nature, such as 

sexual behavior and attitudes, religious beliefs, and other matters that are 

commonly considered private. The justification should include the reasons why the 

agency considers the questions necessary, the specific uses to be made of the 

information, the explanation to be given to persons from whom the information is 

requested, and any steps to be taken to obtain their consent.

As noted above in response to question 1, OCR proposes to collect data about the number of 

allegations received by a school of bullying/harassment on the basis of religion and sexual 

orientation. The questions are not intended or expected to elicit private information about 

students. The questions are intended to record, for any reported harassment, the school’s 

understanding about the harasser’s perceived motivation. In classifying the allegations of 

harassment or bullying, respondents are directed to look to the likely motives of the alleged 

harasser/bully, and not the actual status of the alleged victim. Because the questions are not 

focused on students’ sexual behavior or attitudes or religious beliefs, OCR does not believe these 

questions are of a sensitive nature. Nonetheless, OCR provides the following justification for the 

proposed addition of these questions.

Beginning in 2009, OCR collected data at the school level regarding bullying/harassment on the 

basis of (1) sex, (2) race/color/national origin, and (3) disability. For each category, the CRDC 

collected the number of allegations of bullying/harassment received by a school, the number of 

students bullied/harassed, and the number of students disciplined for bullying/harassment. For 
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the “students bullied/harassed” and “students disciplined” items, the CRDC collected 

disaggregated data by sex, race/ethnicity, disability, and LEP status.

Bullying and harassment of students on the basis of religion and sexual orientation is reportedly

prevalent. The NIH’s Health Behavior in School-Aged Children Survey reported that 8.5% of

students (grades 6-10) are bullied about their religion.[1] Another survey found that, of those who 

had been subjected to religious slurs and degrading language in school, Jewish and Muslim 

students were more commonly targeted.[2] Likewise, despite the lack of nationally representative 

or uniform school-level harassment data, bullying and harassment in educational settings of 

those perceived to be lesbian, gay or bisexual is reportedly common and has a negative impact 

on those students. For example, one 2011 analysis of 18 studies found that gay, lesbian, and 

bisexual youth were more likely to be verbally harassed and teased or physically and sexually

victimized than heterosexual youth, and more likely to experience detrimental outcomes, such as 

suicidal thoughts and attempts.[3]

In May 2012, the Government Accountability Office noted the "prevalence of bullying of youths 

in certain vulnerable demographic groups is not known," and specifically highlighted that none 

of the four government-sponsored bullying-related national surveys collected information about 

harassment of students based on their sexual orientation. The GAO also stated more generally 

that collecting additional information about bullying and harassment "would better inform 

federal efforts to prevent and remedy bullying" and "could aid policymakers in determining 

whether additional actions are needed to protect vulnerable groups of students who are subjected 

to bullying.”

[4]

In response to the critical need for national data, OCR is proposing to expand its data collection 

to address more comprehensively the bullying and harassment in educational settings to include 

the number of allegations of bullying or harassment on the basis of religion and sexual 

orientation. Collecting these data would allow OCR to provide technical assistance where there 

 

[1] GAO, School Bullying: Extent of Legal Protections for Vulnerable Groups Needs to Be More Fully Assessed, at 

40, App. IV, tbl. 9 (May 2012), http://www.gao.gov/assets/600/591202.pdf; see also U.S. Commission on Civil 

Rights, Peer-to-Peer Violence and Bullying: Examining the Federal Response at 8-9 (Sept. 2011), 

http://www.usccr.gov/pubs/2011statutory.pdf (national survey shows 1.6% of students ages 12-18 reported being 

targeted by hate-related words based on religion; another survey shows 11% of all students in grades 7, 9, and 11 in 

California reported being subjected to bullying or harassment based on religion).

[2]

Stephen L. Wessler and Lelia L. De Andrade, “Slurs, Stereotypes, and Student Interventions: Examining the 

Dynamics, Impact, and Prevention of Harassment in Middle and High School,” Journal of Social Issues, vol. 62, no. 

3 (2006), http://onlinelibrary.wiley.com/doi/10.1111/j.1540-4560.2006.00471.x/full; see also U.S. Commission on 

Civil Rights, supra, at 21 (collecting “demonstrative, albeit largely anecdotal, evidence” of harassment of Jewish 

and Muslim students, as well as those perceived to be Muslim).

[3] Alicia L. Fedewa and Soyeon Ahn, “The Effects of Bullying and Peer Victimization on Sexual-Minority and 

Heterosexual Youths: A Quantitative Meta-Analysis of the Literature,” Journal of GLBT Family Studies, vol. 7, no. 

4 (2011), as described in GAO, supra, at 10.

[4]

See GAO, supra, at 27.
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are patterns of harassment and to assist with investigations in response to complaints. In 2010, 

OCR issued guidance regarding bullying and harassment that indicated that, under some 

circumstances, harassment against gay and lesbian students would violate Title IX (prohibiting 

sex discrimination), and that, under some circumstances, harassment against Jewish and Muslim 

students would violate Title VI (prohibiting national origin discrimination).[5]In addition, these 

data would further the effective administration of programs under the ESEA. 

OCR proposes to collect only the number of allegations received by a school of bullying and 

harassment on the basis of sexual orientation or religion. OCR is not proposing that schools 

collect data about students’ sexual orientation or religion. OCR is not proposing that schools 

collect counts of students who were harassed or disciplined for harassment on those bases. 

School districts will not be required to include perceived sexual orientation or religious 

affiliation of students as part of their administrative records. 

To assess whether even making an inquiry about the number of allegations of harassment 

received by a school might cause invasions of privacy, OCR contacted SEAs in some of the 10 

states that currently collect such sexual orientation harassment data from their public school 

districts and none reported any student or parental complaints or known incidents of teachers 

invading student privacy in an effort to fill out the state’s data reporting forms. OCR also 

contacted several school districts (of various sizes and urban/rural mix) in those states to 

determine whether these data reporting requirements had led to sexual-orientation notations on 

individual student records or had raised any complaints or concerns and none were reported.

12. Provide estimates of the hour burden of the collection of information. The 

statement should:

 Indicate the number of respondents by affected public type (federal government, 

individuals or households, private sector – businesses or other for-profit, private 

sector – not-for-profit institutions, farms, state, local or tribal governments), 

frequency of response, annual hour burden, and an explanation of how the 

burden was estimated, including identification of burden type: recordkeeping, 

reporting or third party disclosure. All narrative should be included in Question

12. Unless directed to do so, agencies should not conduct special surveys to 

obtain information on which to base hour burden estimates. Consultation with a

sample (fewer than 10) of potential respondents is desirable. If the hour burden 

 

[5]

See Guidance Letter from OCR regarding Bullying, at 8 (Oct. 26, 2010) (“When students are subjected to 

harassment on the basis of their LGBT status, they may also ... be subjected to forms of sex discrimination 

prohibited under Title IX.”), http://www.ed.gov/ocr/letters/colleague-201010.pdf; id. at 5 (“[A]nti-Semitic 

harassment can trigger responsibilities under Title VI. ... These principles apply not just to Jewish students, but also 

to students from any discrete religious group that shares, or is perceived to share, ancestry or ethnic characteristics 

(e.g., Muslims or Sikhs). Thus, harassment against students who are members of any religious group triggers a 

school’s Title VI responsibilities when the harassment is based on the group’s actual or perceived shared ancestry or 

ethnic characteristics, rather than solely on its members’ religious practices.”).
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on respondents is expected to vary widely because of differences in activity, size, 

or complexity, show the range of estimated hour burden, and explain the reasons 

for the variance. Generally, estimates should not include burden hours for 

customary and usual business practices.

 If this request for approval covers more than one form, provide separate hour 

burden estimates for each form and aggregate the hour burdens in the ROCIS 

IC Burden Analysis Table. (The table should at minimum include Respondent 

types, IC activity, Respondent and Responses, Hours/Response, and Total 

Hours)

 Provide estimates of annualized cost to respondents of the hour burdens for 

collections of information, identifying and using appropriate wage rate 

categories. The cost of contracting out or paying outside parties for information 

collection activities should not be included here. Instead, this cost should be 

included in Question 14.

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 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 PS-12 schools. 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 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 was 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. 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 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. 
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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). There is a wide range of hourly salaries 

associated with the professionals that will provide this data, but $45/hour is a reasonable average.

13. Provide an estimate of the total annual cost burden to respondents or record 

keepers resulting from the collection of information. (Do not include the cost of 

any hour burden shown in Questions 12 and 14.)

 The cost estimate should be split into two components: (a) a total capital and 

start-up cost component (annualized over its expected useful life); and (b) a total 

operation and maintenance and purchase of services component. The estimates 

should take into account costs associated with generating, maintaining, and 

disclosing or providing the information. Include descriptions of methods used to 

estimate major cost factors including system and technology acquisition, 

expected useful life of capital equipment, the discount rate(s), and the time 

period over which costs will be incurred. Capital and start-up costs include, 

among other items, preparations for collecting information such as purchasing 
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computers and software; monitoring, sampling, drilling and testing equipment; 

and acquiring and maintaining record storage facilities.

 If cost estimates are expected to vary widely, agencies should present ranges of 

cost burdens and explain the reasons for the variance. The cost of contracting 

out information collection services should be a part of this cost burden estimate. 

In developing cost burden estimates, agencies may consult with a sample of 

respondents (fewer than 10), utilize the 60-day pre-OMB submission public 

comment process and use existing economic or regulatory impact analysis 

associated with the rulemaking containing the information collection, as 

appropriate.

 Generally, estimates should not include purchases of equipment or services, or 

portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory 

compliance with requirements not associated with the information collection, (3) 

for reasons other than to provide information or keep records for the 

government or (4) as part of customary and usual business or private practices.

Also, these estimates should not include the hourly costs (i.e., the monetization of 

the hours) captured above in Question 12.

Total Annualized Capital/Startup Cost:

Total Annual Costs (O&M): 

Total Annualized Costs Requested:

The collection of CRDC data for the foreseeable future will require no additional systems 

development efforts by the local agencies. 

14. Provide estimates of annualized cost to the Federal government. Also, provide a 

description of the method used to estimate cost, which should include 

quantification of hours, operational expenses (such as equipment, overhead, 

printing, and support staff), and any other expense that would not have been 

incurred without this collection of information. Agencies also may aggregate cost 

estimates from Questions 12, 13, and 14 in a single table.

The estimated annual government cost for the next CRDC is $4.942 million. This estimate is 

based on contractual costs to develop a revised survey tool, provide technical support for all 

LEAs in the nation, and produce and analyze the resulting database of survey responses.

15. Explain the reasons for any program changes or adjustments. Generally, 

adjustments in burden result from re-estimating burden and/or from economic 

phenomenon outside of an agency’s control (e.g., correcting a burden estimate or 

an organic increase in the size of the reporting universe). Program changes result 

from a deliberate action that materially changes a collection of information and 

generally are result of new statute or an agency action (e.g., changing a form, 

revising regulations, redefining the respondent universe, etc.). Burden changes 
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should be disaggregated by type of change (i.e., adjustment, program change due to 

new statute, and/or program change due to agency discretion), type of collection 

(new, revision, extension, reinstatement with change, reinstatement without 

change) and include totals for changes in burden hours, responses and costs (if 

applicable).

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.

16. For collections of information whose results will be published, outline plans for 

tabulation and publication. Address any complex analytical techniques that will be 

used. 

The Department presently makes CRDC results available on the Web with privacy protections in 

place. Additionally, the Department makes available on the Web national and state projections 

based on the raw data. The Department makes data available through a website that displays a 

“summary of select facts” for a district or school, which displays data about key issues through 

tables and charts. Users then have the option to access additional data for that district or school. 

The website also contains a Flexible Tables interface, which allows users to select data from 

more than one district or school, for the current CRDC and/or prior CRDCs. 

In an effort to make the new CRDC easily usable by the public and OCR’s investigators and 

attorneys, OCR designed a new Web-based data reporting tool that allows users to tailor the 

school-level indicators and produce visually intuitive graphic displays of school- and districtlevel tables, and made it available to the public in a privacy-protected format on OCR’s website, 

http://ocrdata.ed.gov. The new website is also research-friendly. For example, users have 

enhanced ability to search and query the database for types of schools as well as schools or 

districts meeting certain criteria.

17. Provide the time schedule for the entire project, including beginning and ending 

dates of the collection of information, completion of report, publication dates, and 

other actions.

There are three distinct phases of the collection of CRDC data from LEAs:

 Notification and verification of reporting status,

 Collection of data by LEAs, and
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 Survey submission window.

The first phase in the CRDC is to notify school districts of their obligation to report, designate a 

principal point of contact, and verify the reporting status of LEAs and schools. The result of this 

first phase is a full directory of LEAs and schools and their CRDC reporting status. For the 

2013-14 collection, this phase will commence in Fall 2013 and for the 2015-16 collection, this 

phase will begin in Fall 2015.

During the second phase of the CRDC, LEAs gather and validate the required data to be 

submitted to OCR. During this time, OCR provides frequent training opportunities for school 

districts to understand the data elements collected on the CRDC and the survey submission 

process. A support center is also available to school districts to call or email questions regarding 

the content of the data to be collected. OCR has also provided pre-collection tools for school 

districts to gather and prepare flat files of the required data to prepare for the survey submission 

opening. For the 2013-14 collection, this second phase will take place between Fall 2013 and 

Summer 2014 and for the 2015-16 collection, this second phase will take place between Fall 

2015 and Summer 2016.

During the third phase, the survey submission widow opens with email notification to all 

participating school districts. School districts are typically given a minimum of three months to 

submit their data to OCR. During the survey submission period, frequent communication occurs 

with participating school districts to offer technical assistance and, as the survey due date 

approaches, reminders are sent to school districts that have not yet certified their CRDC 

submission. For the 2013-14 collection, we anticipate this third phase will take place between 

Fall 2014 and Winter 2015 and for the 2015-16 collection, we anticipate this third phase will 

take place between Fall 2016 and Winter 2017.

Following the close of the survey submission window, OCR reviews the data to identify possible 

reporting anomalies and offer LEAs an opportunity to amend their CRDC submission as 

necessary. This process takes approximately three months. Following the data quality review, 

OCR then works to post the data on its reporting website (ocrdata.ed.gov) to provide the public 

with easy access and visually intuitive displays of the data.

18. If seeking approval to not display the expiration date for OMB approval of the 

information collection, explain the reasons that display would be inappropriate.

This collection will display the OMB approval date in all transmittal documents requesting the 

information from the state or local agencies and in any written discussion or representation of the 

collection. The OMB number will be properly displayed on any Web form and paper form used 

by the Civil Rights Data Collection.
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19. Explain each exception to the certification statement identified in the Certification 

of Paperwork Reduction Act.

ED is requesting no exemptions from the Certification.
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Appendix: List of New and Continuing CRDC Questions*

*For an updated list reflecting the revisions after the 60-day comment period, see Section V 

of Attachment B. 

Items that OCR is proposing to add are underlined.

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 by LEA in LEA and non-LEA facilities 

(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.

 Whether co-educational school has one or more single-sex classes

 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

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)
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 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 removed for disciplinary reasons (to alternative school; to 

regular school):

o Number of K-12 students without disabilities who were removed for disciplinary 

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

LEP)

o Number of K-12 students with disabilities who were removed 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)
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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 students without disabilities, students with disabilities (IDEA), 

students with disabilities (504 only) 

 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)

Harassment and 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
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 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) 

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

 Whether the school has any students who participate in 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)

Early Childhood Education 

 Whether LEA provides early childhood program(s) for children birth-2 (LEA)

 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)
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 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 (disaggregated by 

age-- 3, 4, 5)

 Whether LEA is required to provide full-day or part-day kindergarten by state statute or 

regulation (LEA)

 Kindergarten length offered (full-day, part-day) and cost (free, partial charge, full charge)

(LEA)

Pathways to College and Career

 Whether the school has one or more gifted/talented programs

 Number of students enrolled in gifted & talented programs (disaggregated by race, sex, 

disability-IDEA, LEP) 

 Whether students are enrolled in distance education courses (LEA)

 Number of students enrolled in distance education courses (disaggregated by race, sex, 

disability-IDEA, LEP) (LEA)

 Whether any students participate in a dual enrollment/dual credit program 

 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 

 Number of students absent 15 or more school days (disaggregated by race, sex, disabilityIDEA, disability-504 only, LEP)

 Whether the school offers the International Baccalaureate Diploma Programme

 Number of students enrolled in the International Baccalaureate (IB) Diploma Programme 

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

 Whether students are enrolled in one or more AP courses 

 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)

 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)
25

ICRAS ICR ID and OMB Number: (1974.01) 1870-NEW

Revised: 11/25/2013

RIN Number: XXXX-XXXX (if applicable)

 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 passed 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 pass any AP exams for the one or more AP courses 

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

 Number of classes in math and science (Algebra I, Geometry, Algebra II, Advanced 

Math, Calculus, Biology, Chemistry, Physics) 

 Number of students enrolled in Algebra I in grade 7 (total count) 

 Number of students enrolled in Algebra I in grades: 8; 9&10; 11&12 (disaggregated by 

race, sex, disability-IDEA, LEP)

 Number of students who passed Algebra I in grade 7 (total count)

 Number of students who passed Algebra I in grades: 8; 9&10; 11&12 (disaggregated by 

race, sex, disability-IDEA, LEP)

 Number of students enrolled in Geometry in grade 8 (total count) 

 Number of students enrolled in Geometry in grades 9-12 (disaggregated by race, sex, 

disability-IDEA, LEP)

 Number of students (grades 9-12) enrolled in other math and science courses, by subject 

(Algebra II, Advanced Math, Calculus, Biology, Chemistry, Physics) (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 Whether LEA operated a GED prep program 

o Number of students ages 16-19 who participated in LEA-operated GED prep 

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

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)

 Whether LEA has policy that allows retention of third grade students who are not 

proficient in reading (LEA)

 Number of students retained in specified grade, by grade (K-12) (disaggregated by race, 

sex, disability-IDEA; disability-504 only, LEP)

School finance (funded with state and local funds)

 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 Number of FTE instructional staff (teachers & aides) and amount of their salaries

o Number of FTE support services staff for pupils and amount of their salaries

o Number of FTE support services staff for instructional staff and amount of their 

salaries

o Number of FTE school administration staff and amount of their salaries
26

ICRAS ICR ID and OMB Number: (1974.01) 1870-NEW

Revised: 11/25/2013

RIN Number: XXXX-XXXX (if applicable)

o Number of FTE non-instructional staff and amount of their salaries

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

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

 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)

 Number of FTE teachers absent more than 10 school days (excluding professional 

development) (PS -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 security guards (preschool through grade 12) 

 Number of FTE school resource officers (preschool through grade 12) 

 Number of FTE sworn law enforcement officers (preschool through grade 12)