OPPORTUNITIES AND 

RESPONSIBILITIES FOR STATE AND 

LOCAL REPORT CARDS UNDER THE 

ELEMENTARY AND SECONDARY 

EDUCATION ACT OF 1965, AS 

AMENDED BY THE EVERY STUDENT 

SUCCEEDS ACT

Non-Regulatory

Informational Document

September 2019
2

Table of Contents

PURPOSE ..........................................................................................................................................................7

A. GENERAL INFORMATION ............................................................................................................9

A-1. What are the responsibilities of an SEA and an LEA for preparing a report card?........9

A-2. When should an SEA or LEA post annual report cards on its website?..........................9

A-3. Is there a particular report card style or format that an SEA or an LEA must use?.......9

A-4. Are there considerations or principles for displaying student and school performance 

data that may be helpful to SEAs and LEAs as they develop, prepare, and disseminate State 

and local report cards?.......................................................................................................................10

A-5. How can an SEA and LEA meet the requirement for report cards to be concise?......11

A-6. What does the ESEA require regarding how an SEA and LEA can ensure the 

accessibility of report cards?.............................................................................................................11

A-7. How might an SEA and LEA ensure that its report card is accessible to parents who 

are limited English proficient?..........................................................................................................12

A-8. How might an SEA or an LEA ensure that its report card is accessible to parents with 

disabilities?...........................................................................................................................................12

A-9. How can an SEA or LEA ensure the online accessibility of its report cards?...............12

A-10. How can an SEA and an LEA ensure that the information on its report card does not 

reveal personally identifiable information about individual students? .......................................13

A-11. May an SEA and LEA use Title I funds to prepare and disseminate its report card?..14

A-12. How can an SEA or an LEA ensure the accuracy of its report card data?.....................14

A-13. Must an SEA and LEA include information for private school students and teachers 

on its report card? ..............................................................................................................................14

B. SEA RESPONSIBILITIES ................................................................................................................14

B-1. What information must an SEA include on its State report card?...................................14

B-2. What additional information might an SEA include on its State report card?...............15

B-3. How does the ESEA require an SEA to disseminate its State report card?...................16

B-4. Does the ESEA require that an SEA provide to the public information that can be 

cross-tabulated by student subgroup?.............................................................................................17

B-5. For which data elements does the ESEA require that an SEA provide information that 

can be cross-tabulated by student subgroup?.................................................................................17

B-6. What does it mean to provide information that can be cross-tabulated by student 

subgroup?............................................................................................................................................18

B-7. What information about school improvement funds reserved under ESEA section 

1003 does the ESEA require that an SEA include on the State report card? ...........................18

B-8. How might an SEA display on the State report card the required information about 

school improvement funds? .............................................................................................................19

C. LEA RESPONSIBILITIES................................................................................................................19
3

C-1. What information does the ESEA require that an LEA include on its report card?....19

C-2. May an LEA include additional information on its report card?.....................................20

C-3. How does the ESEA require that an LEA disseminate its report card?.........................20

C-4. How can an LEA help parents to understand and act on the information provided on 

the local report card, particularly information related to the schools their children attend?..20

D. REPORTING STUDENT ACHIEVEMENT DATA BASED ON STATE ASSESSMENTS

................................................................................................................................................................21

D-1. What achievement data does the ESEA require an SEA and LEA to include on its 

report card? .........................................................................................................................................21

D-2. How must an SEA calculate student achievement for the purposes of State and local 

report cards?........................................................................................................................................21

D-3. For purposes of disaggregating achievement data on State and local report cards, what 

definitions apply?................................................................................................................................22

D-4. In reporting student achievement for the English learner subgroup, may an SEA and 

an LEA include results for former English learners?....................................................................22

D-5. In reporting student achievement for the children with disabilities subgroup, may an 

SEA and LEA include results for children who were formerly identified as children with 

disabilities?...........................................................................................................................................22

D-6. If an SEA exempts recently arrived English learners from the first administration of its 

reading/language arts assessment, how is achievement for these students reported on State 

and local report cards?.......................................................................................................................23

D-7. How must an SEA and LEA report results for students with the most significant 

cognitive disabilities who take an alternate assessment aligned with alternate academic 

achievement standards (AA-AAAS) under ESEA section 1111(b)(2)(D)? ...............................23

D-8. What information must an SEA and LEA include on its report card regarding 

participation rates? .............................................................................................................................23

D-9. May an SEA and LEA count students without a valid score as participating in the 

State assessments?..............................................................................................................................24

E. REPORTING STATE ACCOUNTABILITY SYSTEM INFORMATION............................24

E-1. What information must State and local report cards include regarding a description of 

the statewide accountability system? ...............................................................................................24

E-2. How can SEAs and LEAs meet the requirement to include a description of the State 

accountability system on State and local report cards?.................................................................25

E-3. What information must State and local report cards include regarding results of the 

statewide accountability system?......................................................................................................26

E-4. What additional information may help parents and other stakeholders understand the 

performance and progress of schools based on the State accountability system?....................27

E-5. For which indicators may an SEA and LEA include former English learners in 

reporting the accountability system results for the English learner subgroup? ........................27

E-6. May an SEA or an LEA include the assessment results for children who were formerly 
4

identified as children with disabilities in reporting on any accountability system results for 

the children with disabilities subgroup?..........................................................................................28

E-7. Must an SEA and LEA include the results for children with disabilities who take an 

AA-AAAS for students with the most significant cognitive disabilities in calculating and 

reporting accountability determinations?........................................................................................28

E-8. How must the performance of recently arrived English learners on reading/language 

arts and mathematics assessments be reported for accountability purposes on State and local 

report cards?........................................................................................................................................28

F. REPORTING DATA FROM THE CIVIL RIGHTS DATA COLLECTION (CRDC) .......30

F-1. What is the data collected under section 203(c)(1) of the Department of Education 

Organization Act that SEAs and LEAs must include on report cards?.....................................30

F-2. What information regarding the categories of CRDC data required under the ESEA 

can SEAs and LEAs include on report cards to meet this requirement? ..................................31

F-3. What preschool enrollment information is an SEA and LEA required to include on 

report cards?........................................................................................................................................34

F-4. How does an SEA and LEA determine the percentage of students enrolled in 

accelerated coursework to earn post-secondary credit while still in high school?....................34

F-5. Does the ESEA require that the SEA and LEA use the CRDC data described in 

question F-2 to meet the reporting requirements?........................................................................34

F-6. How can an SEA and LEA meet their privacy obligations while including the CRDC 

data on State and local report cards?...............................................................................................34

F-7. Does the ESEA require that the SEA and LEA include CRDC data on report cards 

annually? ..............................................................................................................................................35

F-8. What if an SEA or LEA has more recent data than what is available in the CRDC data 

file provided by the Department?....................................................................................................35

F-9. May an SEA or an LEA provide a web link to CRDC data on its report card in lieu of 

including the actual CRDC data?.....................................................................................................35

F-10. Which school year of data must SEAs and LEAs include on the report cards and how 

can SEAs and LEAs obtain the data file(s)?...................................................................................35

F-12. Where can an SEA and LEA find documentation about the data file(s)?......................36

F-13. What privacy protections are implemented in the data files?...........................................36

F-14. What should an SEA do if the data submitted for the CRDC are missing or 

incomplete? .........................................................................................................................................36

F-15. What level of CRDC data must be included on State and local report cards?...............36

G. REPORTING ON EDUCATOR QUALIFICATIONS..............................................................37

G-1. What information must State and local report cards include on educator qualifications?

37

G-2. What definitions apply to the requirement that each SEA and LEA report on educator 

qualifications?......................................................................................................................................37

H. REPORTING PER-PUPIL EXPENDITURES ............................................................................38
5

H-1. What information must State and local report cards include on per-pupil expenditures?

38

H-2. Can an SEA and its LEAs follow different procedures when calculating per-pupil 

expenditure data for State and local report cards? ........................................................................38

H-3. Can an SEA and LEA report per-pupil expenditures on State and local report cards by 

including average salary costs for school-level staff?....................................................................38

H-4. What expenditures are included in the numerator and denominator when calculating 

per-pupil expenditures for State and local report cards?..............................................................38

H-5. Should funds received from private sources be included in per-pupil expenditure 

calculations?.........................................................................................................................................40

H-6. Should Federal funds intended to replace local tax revenues be included in per-pupil 

expenditure calculations as Federal funds or as State and local funds? .....................................40

H-7. What options exist for reporting particular expenditures at the LEA and school level?

41

H-8. How should per-pupil expenditure information be disaggregated on State and LEA 

report cards?........................................................................................................................................43

H-9. Do a State’s per-pupil expenditure reporting procedures need to align with existing 

Federal data collections on education spending?...........................................................................43

H-10. When should expenditures of funds distributed across multiple State fiscal years be 

reported?..............................................................................................................................................43

H-11. How should expenditures be reported if they are consolidated under a schoolwide 

program?..............................................................................................................................................44

H-12. Are small and rural LEAs exempted from the per-pupil expenditure reporting 

requirement?........................................................................................................................................44

H-13. May SEAs and LEAs report per-pupil expenditures on a different timeline than other 

report card data?.................................................................................................................................44

H-14. Are SEAs and LEAs required to report per-pupil expenditures on report cards for the 

2017-18 school year?..........................................................................................................................44

H-15. How may SEAs and LEAs present per-pupil expenditure data on State and local 

report cards to ensure the information is understood to parents and other stakeholders? ....45

H-16. What resources are available to an SEA and its LEAs to support their implementation 

of the per-pupil expenditure reporting requirement? ...................................................................45

H-17. Where can an SEA or LEA learn more about public reporting of school financial data?

46

I. REPORTING STATE PERFORMANCE ON THE NATIONAL ASSESSMENT OF 

EDUCATIONAL PROGRESS (NAEP)........................................................................................47

I-1. What is NAEP?.......................................................................................................................47

I-2. What information from NAEP does the ESEA require on State and local report 

cards?48

I-3. What are the key differences between State assessments and State NAEP?..................48
6

I-4. How can an SEA or an LEA clearly articulate the differences between NAEP 

and State assessments in a manner that is easily understandable to parents and the public? .49

I-5. May an SEA or an LEA provide a web link to NAEP results on its report card in lieu 

of reproducing the actual NAEP results?.......................................................................................49

I-6. How can an SEA and LEA ensure the timely release of its report card and still report 

the most current State NAEP results for reading and mathematics?.........................................49

J. REPORTING POSTSECONDARY ENROLLMENT RATES FOR EACH HIGH 

SCHOOL..............................................................................................................................................50

J-1. What postsecondary data does the ESEA require that an SEA and its LEAs include on 

their report cards?...............................................................................................................................50

J-2. How does the ESEA define a “cohort” for purposes of reporting on postsecondary 

enrollment?..........................................................................................................................................50

J-3. How should an SEA and its LEAs calculate a postsecondary enrollment rate?............50

J-4. What is a “program of postsecondary education” for the purposes of reporting 

postsecondary enrollment? ...............................................................................................................51

J-5. Where may an SEA obtain postsecondary enrollment data?............................................51

J-6. Does the ESEA require that an SEA and its LEAs report postsecondary enrollment 

by type of institution (e.g., public, private, two-year, or four year)?...........................................51

J-7. When reporting postsecondary enrollment, what academic terms may be included? ..51

J-8. Which graduating class does ESEA require an SEA and its LEAs to include on their 

report cards for the purposes of reporting postsecondary data? ................................................52

J-9. What should an SEA and its LEAs report if they do not currently collect or have 

postsecondary enrollment data?.......................................................................................................52

J-10. May an SEA and its LEAs report on additional indicators related to programs of 

postsecondary education? .................................................................................................................53

APPENDIX A: SEA AND LEA CHECKLIST FOR REPORT CARD ELEMENTS.....................54

APPENDIX B: DATA VISUALIZATION EXAMPLES ......................................................................59

APPENDIX C: PER-PUPIL EXPENDITURE EXAMPLE – All Expenditures Reported at the 

School Level..........................................................................................................................................63

APPENDIX D: PER-PUPIL EXPENDITURE EXAMPLE – Only Direct Instruction 

Expenditures Reported at the School Level ....................................................................................65
7

PURPOSE

The Elementary and Secondary Education Act of 1965 (ESEA), as amended by the Every Student 

Succeeds Act (ESSA),

1

establishes requirements for State educational agencies (SEAs) and local 

educational agencies (LEAs) to prepare and disseminate report cards that provide information on 

State, LEA, and school performance and progress in an understandable and uniform format. This 

document is intended to assist SEAs and LEAs in implementing the report card requirements under 

Title I, Part A (Title I) of the ESEA. Although SEAs and LEAs may consider this document in

developing and disseminating report cards, an SEA or LEA is free to develop alternative approaches 

and formats that are consistent with applicable Federal statutes and regulations. Nothing in this 

document should be construed to proscribe a particular approach or limit or prohibit SEA and LEA 

flexibility permitted in the ESEA.

This document supersedes the U.S. Department of Education’s (Department’s) guidance entitled 

Every Student Succeeds Act State and Local Report Cards Non-Regulatory Guidance, issued in January 2017. 

The Department has determined that this document is significant guidance under the Office of 

Management and Budget’s Final Bulletin for Agency Good Guidance Practices, 72 Fed. Reg. 3432 

(Jan. 25, 2007). See https://www.gpo.gov/fdsys/granule/FR-2007-01-25/E7-1066.

Significant guidance is non-binding and does not create or impose new legal requirements, nor does 

it create or confer any rights for or on any person.

SEAs and LEAs must comply with Federal civil rights laws that prohibit discrimination based on 

race, color, national origin, sex, disability, and age. These laws include Title VI of the Civil Rights 

Act of 1964, Title IX of the Education Amendments of 1972, Section 504 of the Rehabilitation Act 

of 1973 (Section 504), Title II of the Americans with Disabilities Act, the Age Discrimination Act of 

1975, and the Equal Educational Opportunities Act of 1974. 

If you are interested in commenting further on this document, please email us your comment at 

OESE.Feedback@ed.gov or write to us at the following address:

U.S. Department of Education

Office of Elementary and Secondary Education

ATTN: Report Card Document

400 Maryland Avenue, SW

Washington, DC 20202

For further information about the Department’s guidance processes, please visit 

www2.ed.gov/policy/gen/guid/significant-guidance.html. 

1 Throughout this document, unless otherwise indicated, citations to the ESEA refer to the ESEA, as amended by the 

ESSA.
8

INTRODUCTION

Under Title I of the ESEA, SEAs and LEAs are required to publish State and local report cards. 

Report cards must include information on the State overall and on each public LEA and school in 

the State. Report cards are an important resource for parents and other stakeholders, as they can 

use them to understand a school’s challenges and successes. Information from report cards can be 

used to have targeted conversations about a child’s school and can empower parents to be partners

in their child’s education. It is important for SEAs and LEAs to consider how parents and other 

stakeholders will be using these data and present information in a manner that is appropriate for the 

target audience.

The Department held listening sessions with parents and other stakeholders between February 2018 

and April 2018 to gather their feedback on report cards. These listening sessions provided the 

Department with an opportunity to hear from parents and their advocates about how they access 

report card information, what information is most important to them, how they communicate about 

the information, and challenges they currently encounter when using report cards. It was clear from 

these sessions that parents and other stakeholders place a high value on having access to information 

about their child’s school, and are concerned about making sure that report cards provide 

information in a manner that they can understand and use.

The Department also provided a 30-day opportunity in April 2019 for the public to comment on a 

draft of this document and received approximately 30 comments. The Department has taken those 

comments into consideration in revising the draft document. This non-regulatory informational 

document provides SEAs and LEAs with information about how to implement State and local 

report cards. It clarifies reporting requirements, provides optional templates related to data 

presentation, and incorporates information about stakeholder priorities. 

 
9

A. GENERAL INFORMATION 

A-1. What are the responsibilities of an SEA and an LEA for preparing a report card?

The ESEA requires that each SEA and LEA that receives Title I funds prepare and disseminate an 

annual report card. (ESEA section 1111(h)(1) and (h)(2)). Generally, an SEA and LEA is required 

by the ESEA to include on its report card information about public schools related to a wide variety 

of student and school performance metrics, accountability, per-pupil expenditures, and educator 

qualifications, as well as any other information that the SEA or LEA deems relevant. (See sections 

B and C for more detail on SEA and LEA responsibilities).

The ESEA requires that State and local report cards be concise and presented in an understandable 

and uniform format accessible to the public, including persons with disabilities, and, to the extent 

practicable, provided in a language that parents and other stakeholders can understand. (See 

questions A-6 through A-9 of this document for more information on the accessibility of State and 

local report cards).

A-2. When should an SEA or LEA post annual report cards on its website?

Under the ESEA, beginning with information from the 2017–2018 school year, report cards must 

be posted annually on SEA and LEA2 websites. (ESEA section 1111(h)(1)(A), (B)(iii) and (h)(2)(A), 

(B)(iii)). Although an SEA and LEA has discretion regarding when to issue its report card, parents

and other stakeholders will likely find it most useful if the report cards are issued before the start of 

the succeeding school year or as early in the succeeding school year as possible (e.g., back-to-school

time). Timely publication of report cards will encourage and foster open and transparent discussion 

between parents and other stakeholders and school officials about school performance. 

A-3. Is there a particular report card style or format that an SEA or an LEA must use?

No. The ESEA requires that State and local report cards be concise, presented in an understandable 

and uniform format, and accessible to the public. (ESEA section 1111(h)(1)(B) and (h)(2)(B)). 

Beyond these requirements, SEAs and LEAs have flexibility to use the report card style or format 

they determine to be most effective in presenting information to stakeholders, including parents. 

To help ensure that parents contribute to decisions related to report cards, the ESEA requires that 

SEAs consult with parents in developing the State report card. (ESEA section 1111(h)(1)(B)(ii)).

For example, an SEA may:

• Hold accessible meetings or hearings at varying locations across the State or district and at 

multiple times during the day, including after the end of the typical work day or on the 

weekends, and, if possible, offer child care, so that working parents, teachers, school leaders, 

and other professionals are best able to participate;

• Ensure meetings or committees include a broad range of stakeholder voices, including those 

who have been traditionally left out of such conversations, and facilitate broad participation 

beyond the representatives that will be attending the meetings or hearings in person;

2 Under ESEA section 1111(h)(2)(B)(iii)(II), if an LEA does not operate a website, it must determine another way to 

provide the local report card. 
10

• Make publicly available the name and contact information of officials and stakeholders who 

will be working on State implementation; and

• Publish mock-up or drafts of possible designs and examples prior to meetings so that 

participants can come to meetings informed and prepared, and encourage comments on 

posted versions of reports or templates on the State website for those unable to attend 

meetings in person.

A report card is both a stand-alone document and a part of an SEA’s and LEA’s larger system for 

providing information to parents and the general public. As SEAs and LEAs make decisions about 

the format of their report cards, they may want to consider whether the proposed format presents a 

full story by itself, and whether stakeholders, such as parents, can find all essential information.

SEAs and LEAs may want to consider consulting with parents and other stakeholders on a regular 

basis and as necessary update their report cards based on this consultation. 

A-4. Are there considerations or principles for displaying student and school performance 

data that may be helpful to SEAs and LEAs as they develop, prepare, and 

disseminate State and local report cards?

As noted above, within certain parameters described in the ESEA, SEAs and LEAs have flexibility 

to design State and local report cards that best suit their particular contexts. In determining the 

design of report cards, SEAs and LEAs may want to consider the following questions based on 

feedback the Department received from parent organizations: 

• Does the report card reflect feedback based on different presentation formats presented to a 

variety of audiences representing likely consumers of report cards to ensure precise and clear 

communication of the data? 

• Are the data available in both chart/graph and table format, and do the graphics and artwork 

improve readability and maintain user interest?

• Does the report card include narrative summaries of relevant information that use plain 

language and avoid using jargon not well known to parents and other stakeholders?

• Is social media embedded to allow parents and other stakeholders to easily share 

information? 

• Does the report card link to historical information provided in previous years?

• Is the information provided in a mobile-ready format that is accessible across a variety of 

devices? 

• Are the State and local report cards disseminated in formats that are accessible to individuals 

with disabilities and to those with limited English proficiency?

SEAs and LEAs also may consider the following resources related to transparency of report cards 

and presentation of report card information. These resources are provided for the reader’s 

convenience and are examples of the many resources that SEAs and LEAs may find helpful and use 

at their discretion. The Department does not control or guarantee the accuracy, relevance, 

timeliness, or completeness of this outside information. Further, these links to items and examples 

do not reflect their importance, nor are they intended to represent or be an endorsement by the 

Department of any materials provided: 

• Transparency for Families and Communities:

http://dataqualitycampaign.org/event/transparency-families-communities/
11

• Other Resources available from the Data Quality Campaign: 

http://dataqualitycampaign.org/showmethedata/

• School Report Cards do not Matter if Parents Can’t Find Them:

https://edexcellence.net/articles/school-report-cards-dont-matter-if-parents-cant-find-them

• An Economist’s Guide to Visualizing Data: 

http://pubs.aeaweb.org/doi/pdfplus/10.1257/jep.28.1.209

• Communicating Performance: A Best Practices Resource for Developing State Report 

Cards: 

https://ccsso.org/resource-library/communicating-performance-best-practices-resourcedeveloping-state-report-cards

• What Makes a Good Report Card?: 

https://www.pta.org/docs/default-source/uploadedfiles/advocacy/lh-and-national-ptawhat-makes-a-good-essa-report-card-webinar.pdf

• Examples of report cards: 

https://resourcelibrary.ccsso.org

A-5. How can an SEA and LEA meet the requirement for report cards to be concise?

ESEA sections 1111(h)(1)(B)(i) and (h)(2)(B)(i) require that State and local report cards be concise. 

An SEA and LEA has flexibility in determining how to ensure its report card is presented in a 

concise manner. For example, an SEA and LEA could:

• Provide an introductory section that includes information on key metrics and/or subgroups

(as determined by the SEA and LEA) that can help parents and other stakeholders quickly 

access and understand such information and provide context for the complete set of data 

included on the State and local report cards.

• Provide the report card on an interactive platform that allows users to see high-level data 

about the State and LEA, and allows the user to access additional information within that 

category through drop-down menus or other interactive tools.

High-level, easy-to-understand summaries are particularly important for parents, who have indicated 

through outreach and other feedback mechanisms that they want to know the most important 

points about a school first, before exploring more detailed information. Please see Appendix B for 

an example of how SEAs and LEAs might present the required information concisely. While this is 

one option for displaying information concisely, there are many ways this can be done, and the 

ESEA does not require a specific template or format.

A-6. What does the ESEA require regarding how an SEA and LEA can ensure the 

accessibility of report cards? 

The ESEA requires that State and local report cards be widely accessible to the public. Specifically, 

report cards must be in an understandable and uniform format and, to the extent practicable, written 

in a language that parents can understand. (ESEA section 1111(h)(1)(B) and (h)(2)(B)).

Questions A-7 through A-9 provide further information on ensuring accessibility of report cards. 
12

A-7. How might an SEA and LEA ensure that its report card is accessible to parents who 

are limited English proficient? 

An SEA and an LEA has an obligation under Title VI of the Civil Rights Act of 1964 to ensure 

meaningful access to national origin minority parents who have limited English proficiency. 

Depending on local needs, it may be necessary for the SEA and LEA to produce versions of its 

report card in other languages or support local translations of some report card information. For 

example, an SEA and LEA might translate the report card into the languages spoken by the major 

language groups served by the SEA and LEA and distribute the translated copies to parents who are 

limited English proficient. Posting copies of the report card translations online and in any other 

forum likely to reach the intended audiences, as well as providing supplements, inserts, or links to 

the report card in other languages, would also help ensure meaningful access.

Parents and other stakeholders who are not from the major language groups serviced by an SEA and

LEA must also have meaningful access. An SEA and LEA may provide this access in the same 

manner as it does for its major language groups, or, if that is not practicable, by translating the 

report card upon request, translating an effective summary of the report card, or providing effective 

oral interpretations of the report card.

A-8. How might an SEA or an LEA ensure that its report card is accessible to parents 

with disabilities?

An SEA and LEA has an obligation under Section 504 and Title II of the Americans with 

Disabilities Act (ADA) to ensure that communications with individuals with disabilities are as 

effective as communications with non-disabled individuals. (28 CFR § 35.160 and 34 CFR §

104.4(b)(1)(iii)). Thus, each SEA and LEA must disseminate its annual report cards in a manner that 

provides parents with disabilities and individuals with disabilities who are members of the public 

with an equal opportunity to access the report cards. To do so, the SEA and LEA may need to take 

appropriate steps, including providing accommodations or modifications when necessary. This is 

the same requirement that applies to any service, program, or activity that an SEA and LEA

provides, including to the SEA’s and LEA’s electronic dissemination of information,

3

distribution of 

print material, and the conduct of any related activities, such as public forums or workshops to 

discuss the report card.4

A-9. How can an SEA or LEA ensure the online accessibility of its report cards?

The ESEA requires that an SEA make its report card available on a single webpage of the SEA’s 

website. (ESEA section 1111(h)(1)(B)(iii)). Similarly, if an LEA has a website, the ESEA requires 

3

For example, in disseminating its annual report card on its website, an SEA or an LEA must ensure that persons who 

are blind or have low vision have an equal opportunity to access the information in the report. For more information 

about these requirements in the context of emerging technology, please refer to “Joint Dear Colleague Letter: Electronic 

Book Readers,” issued on June 19, 2010 by the Office for Civil Rights (OCR) and the Department of Justice, available 

at: https://www2.ed.gov/about/offices/list/ocr/letters/colleague-20100629.html, and “Frequently Asked Questions 

About the June 29, 2010 Dear Colleague Letter” issued on May 26, 2011, by OCR, available at:

https://www2.ed.gov/about/offices/list/ocr/docs/dcl-ebook-faq-201105.html.

4 For example, if an SEA or an LEA schedules public forums for parents, the notices should specify that the SEA or the 

LEA will provide, upon request, auxiliary aids and services to enable parents with disabilities to participate. An example 

would be a request for a sign language interpreter to enable a parent who is deaf to participate.
13

that the LEA post the local report card on such website. (ESEA section 1111(h)(2)(B)(iii)(I)). To 

ensure accessibility of State and local report cards on websites, SEAs and LEAs may consider 

meeting modern standards such as the World Wide Web Consortium’s Web Content Accessibility 

Guidelines (WCAG), and the Web Accessibility Initiative Accessible Rich Internet Applications 

Suite 1.0 for web content. These standards include important criteria that provide comprehensive 

web accessibility to individuals with disabilities--including those with visual, auditory, physical, 

speech, cognitive, developmental, learning, and neurological disabilities. WCAG has been designed 

to be technology neutral to provide web developers more flexibility to address accessibility of 

current as well as future web technologies; in addition, Level AA conformance is widely used, 

indicating that it is generally feasible for web developers to implement. The developers of WCAG 

have made an array of technical resources available on the W3C website at no cost to assist entities 

in implementing the standard. For more information, see http://www.w3.org/WAI/. 

A-10. How can an SEA and an LEA ensure that the information on its report card does not 

reveal personally identifiable information about individual students?

The ESEA requires that when presenting data on a report card, an SEA and LEA ensure that it 

protects the privacy of individuals and the privacy of personally identifiable information contained in 

students’ education records consistent with the Family Educational Rights and Privacy Act (FERPA) 

(20 U.S.C. 1232g; 34 CFR Part 99). (ESEA section 1111(i)). Likewise, personally identifiable data, 

information, and records on students who are children with disabilities, as defined in section 602(3) 

of the Individuals with Disabilities Education Act (IDEA), collected or maintained by SEAs and 

LEAs are subject to the confidentiality of information provisions in the IDEA, which are generally 

consistent with FERPA. (20 U.S.C. 1417(c) and 34 CFR §§300.611 through 300.626). More 

information is available at: https://studentprivacy.ed.gov/resources/ferpaidea-cross-walk.

Accordingly, the ESEA requires that the number of students, teachers, or principals or other school 

leaders in a category of reported data generally be sufficient so that it does not reveal personally 

identifiable information. (ESEA section 1111(i)(3)).

More information and resources on protecting student privacy can be found at the links below to 

the Department’s Privacy Technical Assistance Center (PTAC). The Department’s Institute of 

Education Sciences (IES) has issued a Statewide Longitudinal Data Systems (SLDS) brief on 

protecting student privacy here: https://nces.ed.gov/pubs2011/2011603.pdf. In addition, the 

Department will be providing additional information on applying privacy protections to State and 

local report card data.

PTAC serves as a “one-stop” resource for education stakeholders seeking to learn about best 

practices for ensuring the confidentiality and security of personally identifiable information 

contained in students’ education records and for promoting compliance with FERPA. PTAC has 

developed a series of documents on protecting student privacy when using student-level data 

systems for education decision-making and reporting. Information about PTAC and its resources is 

available at: https://studentprivacy.ed.gov. SEA and LEA officials who need technical assistance or 

have questions on FERPA may contact PTAC’s Student Privacy Help Desk by emailing 

PrivacyTA@ed.gov. 
14

A-11. May an SEA and LEA use Title I funds to prepare and disseminate its report card? 

Yes. An SEA and LEA may use its administrative funds under Title I to prepare and disseminate 

the report cards required by ESEA section 1111(h). 

A-12. How can an SEA or an LEA ensure the accuracy of its report card data?

It is extremely important that an SEA and LEA have systematic and uniform data collection 

guidelines, a system of internal controls, and an infrastructure to collect, produce, and report data 

that are accurate, reliable, and high quality. To help promote data quality and the importance of a 

control environment and control procedures, IES conducted a webinar about internal controls and 

posted the slides here: https://edfacts.grads360.org/.

Further, IES published an issue brief available here: 

https://nces.ed.gov/programs/slds/pdf/Data_Quality_Striking_a_Balance_May2014.pdf. 

Please be aware that individuals and entities responsible for reporting inaccurate data could be 

subject to civil fines and penalties. The intentional reporting of inaccurate data could lead to 

criminal prosecution and penalties in addition to any civil consequences. An SEA and LEA, and all 

its employees, contractors, and other agents, must promptly refer to the Office of Inspector General 

(OIG) any credible evidence of suspected fraud or the intentional manipulation or reporting of 

incorrect data. Information on how to report suspected fraud to the OIG is available at:

http://www2.ed.gov/about/offices/list/oig/hotline.html.

A-13. Must an SEA and LEA include information for private school students and teachers 

on its report card?

No. The report card requirements in ESEA section 1111(h)(1) and (h)(2) apply only to public 

schools and LEAs.

B. SEA RESPONSIBILITIES

B-1. What information must an SEA include on its State report card?

The ESEA requires that each SEA that receives Title I funds prepare and disseminate an annual 

report card. (ESEA section 1111(h)(1)(A)). The table in Appendix A of this document details the 

information that the ESEA requires an SEA to include on its State report card, including the

required indicators and the subgroups for which it must provide disaggregated data. State report 

cards must include information on the following categories: 

• Description of, and results from, the State accountability system (see section E); 

• Student achievement at each level of achievement on the reading/language arts, mathematics 

and science assessments required under ESEA section 1111(b)(2) (see section D); 

• Information on school improvement funds under ESEA section 1003 (see section B);

• 4-year adjusted cohort graduation rates and, at the State’s discretion, extended-year adjusted 

cohort graduation rates (see sections B and E);

• The number and percentage of English learners achieving English language proficiency;
15

• Information on the progress of students toward meeting the State-designed long-term goals 

and measurements of interim progress under ESEA section 1111(c)(4)(A) (see section E);

• Students assessed and not assessed on the assessments required under ESEA section 

1111(b)(2) (see section D);

• Information collected and reported in compliance with the Civil Rights Data Collection 

(CRDC) under 20 U.S.C. 3413(c)(1) (see section F); 

• Information on educator qualifications (see section G);

• Information on per-pupil expenditures (see section H); 

• Number and percentage of students with the most significant cognitive disabilities who take 

an alternate assessment under ESEA section 1111(b)(2)(D), by grade and subject (see section 

D);

• Results at grades 4 and 8 on the reading and mathematics National Assessment of 

Educational Progress (NAEP) (see section I);

• Information on postsecondary enrollment (see section J);

• As applicable, information an SEA must provide under ESEA section 8401(e) if it receives a 

waiver of a statutory or regulatory requirement under the ESEA; and 

• Any other information that the SEA deems relevant. 

(ESEA sections 1003(i); 1111(h)(1)(C); and 8401(e)).

B-2. What additional information might an SEA include on its State report card?

An SEA may include on its State report card any other information it believes will best inform 

parents, students, and other members of the public about the progress of each elementary and 

secondary school. (ESEA section 1111(h)(1)(C)(xiv)). To increase the utility of report cards, many 

SEAs are taking advantage of the full range of available data and are producing more comprehensive 

State report cards that extend beyond the required elements. For example, an SEA might include 

information on the percentage of students requiring or not requiring remediation in postsecondary 

education, the percentage of students attaining career and technical certifications, the percentage of 

students who drop out, or the percentage of first-time 9th graders who were promoted on time.

Further, some SEAs may wish to provide student achievement information disaggregated by 

additional subgroups than what the ESEA requires or disaggregated further within subgroups 

required to be reported under the ESEA. For example, SEAs may wish to provide data 

disaggregated by youth in the juvenile justice system or English learner subgroup (e.g., recently 

arrived English learners, long-term English learners, or English learners who are students with 

interrupted formal education (SIFE)) to help provide a more nuanced picture of the performance of 

the students in these subgroups and better target efforts to support student needs. Other optional 

information an SEA could provide on State report cards includes: 

• Teacher workforce characteristics, e.g., average years of teacher experience and annual 

turnover and absentee rates of first- or second-year teachers;

• School readiness of kindergarten students;

• The percentage of students completing accelerated coursework and the rate of students 

attaining a score that provides college credit on accelerated coursework tests (e.g., Advanced 

Placement (AP), International Baccalaureate (IB), and courses for college credit); 
16

• The percentage of students taking a college entrance examination and earning a score 

accepted for admission or placement into credit-bearing courses by the State’s four-year 

institutions of higher education; 

• Achievement on other statewide assessments such as assessments in social studies;

• Parent and student surveys; and

• Demographic information about the school, district, or State.

When considering optional information to include, the ESEA requires an SEA to ensure that such 

information does not reveal personally identifiable information about individual students. 

An SEA can make many of these optional data elements more meaningful if it accompanies them 

with comparison data that provide context to the data element, such as by comparing data among 

LEAs in the State or by offering longitudinal data for any data element to show progress over time. 

The more contextual information an SEA can provide regarding any of these optional components, 

the more relevance the information will have to the reporting audience. 

B-3. How does the ESEA require an SEA to disseminate its State report card?

The ESEA requires an SEA to disseminate its annual report card by making it available on a single 

page of the SEA’s website. (ESEA section 1111(h)(1)(B)(iii)). To meet this requirement, an SEA 

would most likely post a static or an interactive version of its report card in a prominent place on its 

website. However, because not all parents or members of the public have access to the internet, an 

SEA might consider additional methods for disseminating its report card. In addition an SEA may 

consider enlisting its LEAs in helping to disseminate the State report card. Other suggestions an 

SEA could consider to promote increased dissemination of the State report card include: 

• Printing the report card and making copies available in local schools, libraries, local parent 

centers, community organizations, and other easily accessible public locations;

• E-mailing information about the report card, including how parents may gain access, to 

parents of students enrolled in schools who have agreed to receive such information;

• Distributing information about the report card, including how parents and the public may 

gain access, via statewide or local newspapers and other print media, including foreignlanguage newspapers and publications in communities in which languages other than English 

are predominantly spoken;

• Developing public service announcements about the report card, including how parents and 

the public may gain access, via radio or television and advertising through local access 

broadcast media, community electronic bulletin boards, and other news sources;

• Engaging stakeholder groups, such as parent-teacher organizations, other parent advisory 

groups, and bilingual/multilingual community forums, that have the ability to reach diverse 

groups of parents, including low-income parents, parents with limited English proficiency,

and parents with disabilities; and

• Developing smartphone applications or other mobile technologies for parents to access

important information contained in report cards.

When using an online, interactive report card website, an SEA may wish to provide parents with 

information on how to access, as well as directions on how to use, its interactive features to 

understand and use information on schools, student learning, and test performance. The SEA, in 

coordination with its LEAs, might offer workshops for parents and community members, develop 

and post short training or orientation videos, or provide other assistance on how to access and use 
17

the features its website offers so that parents and community members can take full advantage of 

any interactive graphics, advanced analyses of longitudinal trends, and other features. 

B-4. Does the ESEA require that an SEA provide to the public information that can be 

cross-tabulated by student subgroup?

Yes. For certain State report card elements (see question B-5 for more information), the ESEA 

requires that an SEA provide to the public information in an easily accessible and user-friendly 

manner that can be cross-tabulated by student subgroup. (ESEA section 1111(g)(2)(N)). The 

ESEA requires that these subgroups include, at a minimum, each major racial and ethnic group, 

gender, English proficiency status, and status as a child with or without disabilities. States may at 

their discretion include other subgroups, such as subgroups based on migrant status, homeless 

status, status as a child in foster care, or status as a student with a parent who is a member of the 

Armed Forces on active duty or serves on full-time National Guard duty.

5

In providing information 

that can be cross-tabulated by student subgroup, the ESEA requires that the SEA ensure it does not 

reveal personally identifiable information about an individual student or include in any subgroup a 

number of students that is insufficient to yield statistically reliable information (i.e., less than the 

State’s minimum n-size for reporting purposes), and that it complies with the requirements of 

FERPA. 

B-5. For which data elements does the ESEA require that an SEA provide information 

that can be cross-tabulated by student subgroup?

The ESEA requires that an SEA provide certain data elements from State report cards in a manner 

that can be cross-tabulated by, at a minimum, each major racial and ethnic student subgroup (as 

defined by the State in its approved consolidated State plan), gender, English proficiency status, and 

children with and without disabilities on each of the following:

• Student achievement on the academic assessments in mathematics, reading/language arts,

and science under ESEA section 1111(b)(2) at each level of achievement;

• For public elementary and secondary schools that are not high schools, performance on the 

Academic Progress indicator under ESEA section 1111(c)(4)(B)(ii);

• High school graduation rates, including the four-year adjusted cohort graduation rate and, if 

adopted by the State, any extended-year adjusted cohort graduation rate; and

• The percentage of students assessed and not assessed on the academic assessments in 

mathematics, reading/language arts, and science under ESEA section 1111(b)(2).

An SEA may meet the cross-tabulation requirement by including this information on its report card,

but also has the flexibility to include the cross-tabulation information at another publicly accessible 

location. (ESEA section 1111(g)(2)(N)).

5 It is important to note that the requirement to provide data that can be cross-tabulated by student group is different 

from the requirement to report disaggregated data on report cards. Also note that subgroup disaggregation varies across 

reporting requirements depending on the indicator being reported. Please see Appendix A for details about which 

subgroups are required for each reporting requirement.
18

B-6. What does it mean to provide information that can be cross-tabulated by student 

subgroup?

In basic terms, cross-tabulating information on a measure means analyzing and displaying the 

information in a table using multiple discrete variables. Providing information on a measure that 

can be cross-tabulated by student subgroup means, accordingly, that the SEA enables users of the 

information to create a table of results on the measure using multiple subgroups. For example, 

through cross-tabulation, a user could obtain the four-year adjusted cohort graduation rate for 

students in the State based on a combination of English proficiency and status as a child with a 

disability, as reflected in the following table:

Table 1. Example of Four-Year Adjusted Cohort Graduation 

Rate of English Learners (ELs) by Disability Status

Data 

Element

All ELs ELs Without 

Disability

ELs With 

Disability

Four-year 

adjusted 

cohort 

graduation 

rate

xx % xx % xx %

To meet the requirement to provide information that can be cross-tabulated by student subgroup, 

an SEA must ensure that users can obtain results for any combination of subgroups, provided, as 

discussed in questions A-10 and B-4, that such combination does not reveal personally identifiable 

information about an individual student, include a number of students that is insufficient to yield 

statistically reliable information, or otherwise violate the requirements of FERPA. (ESEA section 

1111(g)(2)(N)).

B-7. What information about school improvement funds reserved under ESEA section 

1003 does the ESEA require that an SEA include on the State report card? 

Under section 1003(a) of the ESEA, an SEA is required to reserve a portion of its Title I allocation 

to assist LEAs that serve schools implementing comprehensive support and improvement plans or 

targeted support and improvement plans under ESEA section 1111(d). The ESEA further requires 

that the State report card include a list of all the LEAs and schools that received section 1003 school 

improvement funds, including the amount of funds each school received and the types of strategies 

implemented in each school with such funds. (ESEA section 1003(i)).

For the 2017-2018 school year, SEAs were not required to identify schools for comprehensive 

support and improvement or targeted support and improvement. As a result, SEAs were given 

flexibility to use school improvement funds to support low-performing schools based on their status 

as priority or focus schools (for SEAs that operated under ESEA flexibility prior to the termination 

of that flexibility) or as schools in need of improvement, corrective action, or restructuring (for 

SEAs that did not operate under ESEA flexibility). Accordingly, for report cards based on the 

2017-2018 school year, an SEA may meet the reporting requirement under ESEA section 1003(i) 

based on such schools’ receipt of section 1003(a) funds during the 2017-2018 school year.
19

B-8. How might an SEA display on the State report card the required information about 

school improvement funds?

SEAs have flexibility in how they display the required information. One approach an SEA may 

consider would be to create a table with columns for the LEA name, school name, school

identification (e.g., Comprehensive Support and Improvement (lowest-performing five percent of 

Title I schools)), amount of funds received, and type of strategy or strategies implemented, as in the 

following table:

Table 2. Receipt and Use of School Improvement Funds by District and School 

LEA Name School 

Name

School 

Identification 

Funds 

Received 

Strategies Implemented 

LEA A School A Targeted Support 

and Improvement 

(low-performing 

subgroup)

$323,456 • Increasing instructional 

time

• Increasing access to 

effective teachers 

LEA A School B Comprehensive 

Support and 

Improvement 

(lowest 

performing—

bottom five percent) 

$534,567 • Increasing access to 

high-quality preschool

• Replacing school 

leadership

• Implementing a new 

instructional model

LEA B School C Comprehensive

Support and 

Improvement 

(lowest 

performing—

bottom five percent)

$145,678 • Replacing school 

leadership

• Implementing a new 

instructional model

C. LEA RESPONSIBILITIES

C-1. What information does the ESEA require that an LEA include on its report card? 

In general, the ESEA requires that an LEA, including a charter school LEA, that receives Title I 

funds report the same information on local report cards as is required for State report cards in the 

categories of information listed in question B-1 (with the exception noted below). The ESEA also 

requires that an LEA report all information for the LEA as a whole and for each school served by 

the LEA, including public charter schools. (ESEA section 1111(h)(2)(C)). Thus, although 

individual school report cards are not required, information about each school is required to be 

included on the local report card. The table in Appendix A details the information that an LEA is 

required to include on its local report card for the LEA as a whole and each school, including the 

required indicators and the subgroups for which it must provide disaggregated data.

Local report cards are required to include information in the following categories: 
20

• As noted above, all information listed in question B-1 required on State report cards but as 

applied to the LEA and each school, except information on school improvement funds 

under ESEA section 1003; 

• Student achievement comparisons as follows: 

o At the LEA level, information that shows how students served by the LEA achieved on 

the State assessments under ESEA section 1111(b)(2)(B)(v) in each subject compared to 

students in the State as a whole (ESEA section 1111(h)(2)(C)(i)); and

o At the school level, information that shows how the school’s students achieved on the 

State assessments under ESEA section 1111(b)(2)(B)(v) in each subject compared to 

students served by the LEA and the State as a whole (ESEA section 1111(h)(2)(C)(ii)); 

and

• Any other information that the LEA deems relevant. 

(ESEA sections 1111(h)(1)(C) and (h)(2)(C); and 8401(e)).

C-2. May an LEA include additional information on its report card?

Yes. In addition to the data elements required by the ESEA, an LEA may include any other 

information it determines to be appropriate, whether or not that information is included on the State 

report card. (ESEA section 1111(h)(2)(D)). An LEA may wish to include supplemental information 

that parents may find useful that is both academic and non-academic. When considering optional 

information to include, the ESEA requires an LEA to ensure that such information does not reveal 

personally identifiable information about individual students. (See question A-10 above regarding 

how the LEA can do so.)

C-3. How does the ESEA require that an LEA disseminate its report card?

The ESEA requires that an LEA make the annual local report card publicly available on the LEA’s 

website. If an LEA does not operate a website, the LEA may provide the information to the public 

in another manner determined by the LEA. (ESEA section 1111(h)(2)(B)(iii)). For example, an 

LEA may make copies of the local report card available at the LEA administrative office, each 

school served by the LEA, local libraries, or other locations widely accessible to the public. (See 

question B-3 above for recommendations for disseminating State report cards for additional 

suggestions for how an LEA may strengthen dissemination efforts.)

C-4. How can an LEA help parents to understand and act on the information provided on 

the local report card, particularly information related to the schools their children 

attend? 

In addition to making local report cards publicly available, LEAs and schools may want to support 

parents in understanding the information provided in local report cards so that parents will be better 

able to contribute to improved teaching and learning for their children. Taking into consideration 

the context of the particular LEA and school, LEA and school staff may want to consider helping 

parents understand local report cards through opportunities such as back-to-school nights, parentteacher conferences, bilingual/multilingual community forums where information is presented in 

parents’ home language and parents can provide input in the language they feel most comfortable,

brief webinars on accessing and reading the report cards, teacher or other school staff phone calls to 
21

parents, messaging publication of and information contained on report cards via social media, and 

focus groups during family events hosted at LEAs or schools. Question B-3 above offers 

suggestions for State report cards that may also be helpful to LEAs and schools in ensuring that 

parents understand information provided on local report cards.

Schools can use report cards as one mechanism to engage parents in school improvement efforts.

For example, if report card data show all or certain subgroups of students in a school have limited 

access to accelerated coursework, parents and school officials can use such data to engage in 

conversations about how to increase student access to such coursework.

D. REPORTING STUDENT ACHIEVEMENT DATA BASED ON 

STATE ASSESSMENTS

D-1. What achievement data does the ESEA require an SEA and LEA to include on its 

report card? 

The ESEA requires that State and local report cards include information on student achievement

based on the reading/language arts, mathematics, and science assessments administered under 

ESEA section 1111(b)(2). In reporting achievement data, SEAs and LEAs must include data at 

each level of achievement, as determined by the State under ESEA section 1111(b)(1), for all 

students and disaggregated by each major racial and ethnic subgroup, economically disadvantaged 

students as compared to students who are not economically disadvantaged, children with 

disabilities as compared to children without disabilities, English proficiency status, gender, 

migrant status, homeless status, status as a child in foster care, and status as a student with a 

parent who is a member of the armed forces on active duty. (ESEA sections 1111(b)(2)(B)(xi),

1111(h)(1)(C)(ii) and (h)(2)(C)).

D-2. How must an SEA calculate student achievement for the purposes of State and local

report cards? 

In calculating and reporting student achievement results, the ESEA requires that an SEA and LEA 

include all students tested. (ESEA section 1111(h)(1)(C)(ii) and (h)(2)(C)). Thus, the denominator 

for this calculation must include all students enrolled during the testing window who participated in 

the assessment. The numerator must include the number of students at each level of achievement

based on the State’s grade-level academic achievement standards. Note that the denominator for 

this calculation must equal the numerator used in the calculation of the participation rate.6

6 A State may have a policy to allow newly arrived English learners to take the State’s English language proficiency 

assessment in lieu of the State’s reading/language arts assessment. In that situation, the denominator for the academic 

achievement calculation would not match the numerator used in the calculation of the participation rate. Instead, the 

denominator of the achievement calculation plus the count of students taking the English language proficiency 

assessment in lieu of the reading/language arts assessment would match the numerator used in the calculation of the 

participation rate. (See question D-6 for additional information about newly arrived English learners and assessments.)
22

D-3. For purposes of disaggregating achievement data on State and local report cards, 

what definitions apply? 

The ESEA does not define each of the subgroups for which an SEA and LEA must disaggregate 

achievement data. Under 34 CFR § 200.2(b)(11), however, a State’s assessment system must enable 

results to be disaggregated within each State, LEA, and school by the same subgroups required for 

reporting student achievement and in accordance with the following definitions:

• English proficiency status. Status as an English learner as defined in ESEA section 

8101(20);

• Children with disabilities. Defined in accordance with section 602(3) of the IDEA;

• Migrant status. Status as a migratory child as defined in ESEA section 1309(3);

• Homeless status. Status as a homeless child or youth as defined in accordance with section 

725(2) of title VII, subtitle B of the McKinney-Vento Homeless Assistance Act, as amended;

• Status as a child in foster care. ‘‘Foster care’’ means 24-hour substitute care for children 

placed away from their parents and for whom the agency under title IV–E of the Social 

Security Act has placement and care responsibility. This includes, but is not limited to,

placements in foster family homes, foster homes of relatives, group homes, emergency 

shelters, residential facilities, child care institutions, and preadoptive homes. A child is in 

foster care in accordance with this definition regardless of whether the foster care facility is 

licensed and payments are made by the State, tribal, or local agency for the care of the child, 

whether adoption subsidy payments are being made prior to the finalization of an adoption, 

or whether there is Federal matching of any payments that are made; and

• Military connected status. Status as a student with a parent who is a member of the armed 

forces on active duty or serves on full-time National Guard duty, where ‘‘armed forces,’’ 

‘‘active duty,’’ and ‘‘full-time National Guard duty’’ have the meanings given them in 10 

U.S.C. 101(a)(4), 101(d)(1), and 101(d)(5).

D-4. In reporting student achievement for the English learner subgroup, may an SEA and

an LEA include results for former English learners?

No. It is important that parents and the public have a clear picture of the academic achievement of 

students who are currently learning English. Therefore, the ESEA provides that in reporting on the 

English learner subgroup, an SEA and LEA may only include current English learners in reporting 

on student achievement on the assessments required under ESEA section 1111(b)(2). (ESEA 

section 1111(h)(1)(C)(ii) and (h)(2)(C)). However, an SEA may include the results of former English 

learners for not more than four years after such students cease to be identified as English learners 

for the purposes of the State accountability system. (See question E-5 for more information on this 

flexibility.) 

D-5. In reporting student achievement for the children with disabilities subgroup, may an 

SEA and LEA include results for children who were formerly identified as children 

with disabilities?

No. It is important that parents and the public have a clear picture of the academic achievement of 

students who are currently receiving special education services under the IDEA. Therefore, the 

ESEA requires that in reporting on the children with disabilities subgroup, an SEA and LEA may 

include only current children with disabilities in reporting on student performance on the 
23

assessments required under ESEA section 1111(b)(2). (ESEA section 1111(h)(1)(C)(ii) and 

(h)(2)(C)). 

D-6. If an SEA exempts recently arrived English learners from the first administration of 

its reading/language arts assessment, how is achievement for these students 

reported on State and local report cards?

An SEA has the flexibility to exempt English learners in their first 12 months of schooling in the 

United States from one administration of the reading/language arts assessment. (ESEA section 

1111(b)(3)(A)(i)). If an SEA takes advantage of this flexibility, both the SEA and its LEAs must 

report on State and local report cards, respectively, the number of recently arrived English learners 

who are exempted from taking the reading/language arts assessment. (34 CFR § 200.6(i)(1)(iii)). 

Since these students do not take the reading/language arts assessment, an SEA and LEA would not 

include such students in the achievement calculation. However, an SEA and LEA may include these 

students as participants in calculating the participation rate for the State reading/language arts 

assessment if they take the State’s English language proficiency assessment. If an SEA does not 

exempt recently arrived English learners from the State’s reading/language arts assessment, the SEA 

and its LEAs must include results for those students in reporting student achievement. (ESEA 

section 1111(b)(3)(A)(ii)(I)).

Recently arrived English learners are required to participate in the mathematics and science 

assessments. (34 CFR § 200.6(i)(3)). Accordingly, if a recently arrived English learner receives a 

valid mathematics or science score, his or her results must be included in reporting student 

achievement for those subjects on State and local report cards.

D-7. How must an SEA and LEA report results for students with the most significant 

cognitive disabilities who take an alternate assessment aligned with alternate 

academic achievement standards (AA-AAAS) under ESEA section 1111(b)(2)(D)?

In reporting on student achievement, the ESEA requires that State and local report cards include the 

results for students with the most significant cognitive disabilities who take an AA-AAAS under 

ESEA section 1111(b)(2)(D). (ESEA section 1111(h)(1)(C)(ii) and (h)(2)(C)). Thus, the percentage 

of students at each level of achievement must include students with the most significant cognitive 

disabilities who take an AA-AAAS.

In addition, State and local report cards must include the number and percentages of students with 

the most significant cognitive disabilities who take an AA-AAAS, by grade and subject. (ESEA 

section 1111(h)(1)(C)(xi) and (h)(2)(C)).

D-8. What information must an SEA and LEA include on its report card regarding 

participation rates?

The ESEA requires that an SEA and LEA report, for all students and disaggregated by each 

subgroup of students described in ESEA section 1111(b)(2)(B)(xi) (each major racial and ethnic 

group; economically disadvantaged students as compared to students who are not economically 

disadvantaged; children with disabilities as compared to children without disabilities; English 

proficiency status; gender; and migrant status) the percentage of students assessed and not assessed 

on the State’s mathematics, reading/language arts, and science assessments. (ESEA section 
24

1111(h)(1)(C)(vii) and (h)(2)(C)). (See question D-3 for information on the definitions that apply to 

the required subgroups.) 

D-9. May an SEA and LEA count students without a valid score as participating in the 

State assessments?

No. Only students with a valid score, as determined by the State, may be counted as participants on 

the State assessments. Under the ESEA, a State must design an assessment system that provides 

coherent information about student attainment of challenging State academic standards and use that 

system to assess all students in the tested grades in a valid and reliable manner, including students 

with disabilities and English learners. (ESEA section 1111(b)(2)(B)(ii), (vii)). Given the requirement 

to assess all students, participation rate plays an important role in calculating the academic 

achievement indicator used in a State’s system of meaningfully differentiating among 

schools. (ESEA section 1111(c)(4)(B)(i), (E)). Moreover, participation rate must be reported on 

State and local report cards. (ESEA section 1111(h)(1)(C)(vii), (2)(C)). These requirements would 

be meaningless without a valid score for each participant. Accordingly, students without a valid 

score may not be reported as participating in State assessments on either the State or local report 

card (i.e., such students may not be in the numerator in calculating the participation rate but must be 

in the denominator). In addition, all students considered participants by the State must be included 

in the proficiency calculations described in question D-2. Under the IDEA, children with disabilities 

must be included in all general State and districtwide assessment programs, including assessments 

described in ESEA section 1111, with appropriate accommodations and alternate assessments where 

necessary and as indicated in their respective individualized education programs (IEPs). (20 U.S.C. 

1412(a)(16)(A) and 34 CFR § 300.160(a)). The SEA (or in the case of a districtwide assessment, the 

LEA) must develop guidelines for the provision of appropriate accommodations for each 

assessment that identify those accommodations that do not invalidate the score. (20 U.S.C. 

1412(a)(16)(B) and 34 CFR § 300.160(b)).

E. REPORTING STATE ACCOUNTABILITY SYSTEM 

INFORMATION

E-1. What information must State and local report cards include regarding a description 

of the statewide accountability system? 

The ESEA requires that State and local report cards include a clear and concise description of the 

State accountability system. (ESEA section 1111(h)(1)(C)(i), (h)(2)(C)). This information is 

intended to help ensure that parents, teachers, principals, and other key stakeholders have access to 

information on each element of the State accountability system and how the elements work together 

in a coherent system. Such information will support a better understanding of school performance 

and progress based on a State’s particular accountability system and can help focus parent, teacher, 

principal, and other stakeholder efforts to meaningfully contribute to school improvement activities 

and initiatives.

The table in Appendix A details what the ESEA requires regarding the description of the State’s 

accountability system on State and local report cards. The ESEA requires State and local report 
25

cards to include a description of the following elements of the State’s approved accountability 

system: 

• The minimum number of students (i.e., n-size) that the State determines are necessary to be 

included in each of the subgroups of students for use in the accountability system;

• For all students and each subgroup of students as defined in ESEA section 1111(c)(2), the 

State-designed long-term goals and measurements of interim progress for academic 

achievement and graduation rate and, for the subgroup of English learners, the Statedesigned long-term goals and measurements of interim progress for progress in achieving 

English language proficiency; 

• The indicators that the State uses in its accountability system to meaningfully differentiate all 

public schools in the State;

• The State’s system for annually meaningfully differentiating all public schools in the State, 

including the: 

o Specific weight of the accountability indicators;

o Methodology by which the State differentiates all public schools in the State; 

o Methodology by which the State identifies schools as consistently underperforming for 

any subgroup of students, including the time period the State uses to determine 

consistent underperformance; and 

o Methodology by which the State identifies schools for comprehensive support and 

improvement based on: 

1) Being among not less than the lowest-performing 5 percent of all Title I schools in 

the State; 

2) For a public high school, failing to graduate one third or more of their students; and 

3) For a Title I school, having one or more subgroups that were identified for 

additional targeted support and improvement under ESEA section 1111(d)(2)(C) 

and, after a State-determined number of years, failing to meet the statewide exit 

criteria for such schools; and

• The exit criteria established by the State for:

1) Schools identified for comprehensive support and improvement; and 

2) Schools identified for additional targeted support and improvement based on having 

one or more subgroups whose performance, on its own, would lead to identification 

as a school among the lowest-performing five percent of Title I schools (i.e., 

additional targeted support and improvement schools), including the Statedetermined number of years after which, if not having achieved these exit criteria, 

such a Title I school will be identified for comprehensive support and improvement.

SEAs and LEAs may include on their report cards any other long-term goals and measurements of 

interim progress they may have set (e.g., for the Other Academic indicator or for one or more

School Quality or Student Success indicators).

(ESEA section 1111(h)(1)(C)(i) and (h)(2)(C)). 

E-2. How can SEAs and LEAs meet the requirement to include a description of the State 

accountability system on State and local report cards? 

SEAs and LEAs may meet the requirement to provide a description of the State accountability 

system by including such information directly on State and local report cards, respectively. SEAs 
26

and LEAs may also meet this requirement by providing the web address and linking to the 

description, provided the web page to which it links includes all of the accountability system 

description elements detailed in question E-1.

SEAs and LEAs, in developing their report cards, may consider the amount of information needed 

to help parents and other stakeholders engage in and understand the State accountability system. 

For example, an SEA may wish to indicate its n-size directly on its report card, even though it is 

available elsewhere, because such information likely facilitates understanding of how school 

performance is measured and provide the website for the reader to access the other required 

information. Additionally, SEAs and LEAs may want to describe the State accountability system in 

a way that enables parents and other stakeholders to understand what the system means and its 

implication for students. (See question E-4 for further information on accountability system context 

that might be useful for parents.)

E-3. What information must State and local report cards include regarding results of the 

statewide accountability system?

The ESEA requires that State and local report cards (which must include information for each 

school served by the LEA) include the following results of the State accountability system: 

• The number and names of all public schools in the State and LEA, as applicable, identified 

for comprehensive support and improvement and targeted support and improvement (i.e., 

required to implement targeted support and improvement plans). This includes schools that 

require additional targeted support and improvement under ESEA section 1111(d)(2)(C); 

and

• For all students and disaggregated by each subgroup of students, as defined in ESEA section 

1111(c)(2):

o Information on performance on the indicator for public elementary schools and 

secondary schools that are not high schools (i.e., the Other Academic indicator); 

o High school graduation rates, including four-year adjusted cohort graduation rates and, 

at the State’s discretion, extended-year adjusted cohort graduation rates (i.e., if the State, 

at its discretion, chooses to include one or more extended-year rates in its accountability 

system), which must also be disaggregated by homeless status and by status as a child in 

foster care7;

o Information on performance on the School Quality or Student Success indicator or 

indicators; and

o Information on the progress of students toward meeting the State-determined long-term 

goals, including the progress of students against the State’s measurements of interim 

progress. 

(ESEA section 1111(h)(1)(C)(i)(V), (h)(1)(C)(iii), (h)(1)(C)(v)-(vi), (h)(2)(C)).

The table in Appendix A details the accountability system results that the ESEA requires State and 

local report cards to include. 

7 Although the ESEA requires State and local report cards to include graduation rates, it does not require that the report 

cards include information on performance on the Graduation Rate indicator used in the State accountability system. 
27

E-4. What additional information may help parents and other stakeholders understand the 

performance and progress of schools based on the State accountability system? 

In reporting the number and names of all identified public schools, an SEA and its LEAs may wish 

to indicate, for each school identified for comprehensive support and improvement or targeted 

support and improvement (i.e., schools implementing targeted support and improvement plans, 

including schools that require additional targeted support), the reason the school was identified. For 

a school identified as a comprehensive support and improvement school, the reason for 

identification would include one of the following: (1) being among not less than the lowestperforming 5 percent of Title I schools (i.e., lowest-performing school); (2) being a high school with 

a graduation rate of 67 percent of lower (i.e., low graduation rate school); or (3) being a Title I 

school that was previously identified for additional targeted support based on having one or more 

subgroups whose performance, on its own, would result in the school’s identification as a lowestperforming school but failing to meet the exit criteria for such schools within a State-determined 

number of years, specifying which subgroup or subgroups led to such identification. Regarding the 

third reason for which a school may be identified, an SEA or LEA may wish to specify the subgroup 

or subgroups in the school that are underperforming. Doing so may increase transparency about the 

needs of these students.

For a school identified as a targeted support and improvement school, the reason for identification 

would include one of the following, including the subgroup or subgroups that led to the school’s 

identification: (1) having one or more consistently underperforming subgroups; or (2) receiving 

additional targeted support based on having one or more subgroups whose performance, on its own, 

would result in the school’s identification as a lowest-performing school. An SEA or LEA may wish 

to specify for which subgroup or subgroups the school is underperforming. Doing so may support 

the school in addressing the needs of these students.

In reporting information on an indicator, such as the Other Academic indicator or the School 

Quality or Student Success indicator, an SEA and LEA may, as applicable, report on the individual 

measures or components within the indicator as well as the indicator overall. 

SEAs and LEAs may also report information on the Academic Achievement indicator used in the 

State accountability system (in addition to the information on student performance on the 

assessments required under ESEA section 1111(h)(1)(C)(ii) and (h)(2)(C)), the Graduation Rate 

indicator used in the State accountability system (in addition to the information on the graduation 

rate required under ESEA section 1111(h)(1)(C)(iii)(II) and (h)(2)(C)), and the Progress in Achieving 

English Language Proficiency indicator used in the State accountability system (in addition to the 

information on the number and percentage of English learners achieving English language 

proficiency required under ESEA section 1111(h)(1)(C)(iv) and (h)(2)(C)). Providing information on

each indicator within the statewide accountability system may help parents and the public better 

understand school performance based on the system. 

E-5. For which indicators may an SEA and LEA include former English learners in 

reporting the accountability system results for the English learner subgroup?

For not more than four years after a student ceases to be identified as an English learner, an SEA 

and its LEAs may include the reading/language arts and mathematics assessment results of such 

student on State and local report cards for purposes of reporting the results of the English learner 
28

subgroup on any accountability indicator that relies on those assessments, including the Academic 

Achievement indicator (if the SEA or LEA chooses to include results for the Academic 

Achievement indicator on its report card), the Other Academic indicator, if applicable (e.g., if the 

SEA uses growth on the reading/language arts and mathematics assessments as its Other Academic 

indicator), or a School Quality or Student Success indicator, if applicable. An SEA and LEA may

also include the reading/language arts and mathematics assessment results of such students when 

calculating and reporting the progress of the English learner subgroup toward meeting the Statedesigned long-term goals and measurements of interim progress toward those goals.

An SEA and LEA may not include former English learners in reporting any other information 

required under ESEA section 1111(h). For example, an SEA and LEA may not include former 

English learners in reporting student performance on academic assessments, as required by ESEA 

section 1111(h)(1)(C)(ii) (as opposed to reporting on the Academic Achievement indicator, if an 

SEA or LEA chooses to report on that indicator) or for reporting on any other indicator that does 

not rely on results from the State’s reading/language arts or mathematics assessments (e.g., the 

Progress in Achieving English Language Proficiency indicator). Note, however, that for purposes of 

calculating and reporting graduation rates for the English learner subgroup, a State may include 

students who were English learners at any time during their graduation cohort period. 

E-6. May an SEA or an LEA include the assessment results for children who were 

formerly identified as children with disabilities in reporting on any accountability 

system results for the children with disabilities subgroup?

No. The ESEA does not allow an SEA or an LEA to include the assessment results for children 

who were formerly identified as children with disabilities in reporting on any accountability system 

results for the children with disabilities subgroup. Note, however, that for purposes of calculating 

and reporting graduation rates for the children with disabilities subgroup, a State may include 

students who were children with disabilities at any time during their graduation cohort period. 

E-7. Must an SEA and LEA include the results for children with disabilities who take an 

AA-AAAS for students with the most significant cognitive disabilities in calculating 

and reporting accountability determinations? 

Yes. The ESEA requires that an SEA and an LEA include all children with disabilities, including 

those who are students with the most significant cognitive disabilities who take an AA-AAAS, in 

each indicator in the State’s accountability system, including achievement on the AA-AAAS in the 

Academic Achievement indicator. 

E-8. How must the performance of recently arrived English learners on reading/language 

arts and mathematics assessments be reported for accountability purposes on State 

and local report cards?

Under ESEA section 1111(b)(3)(A), an SEA has flexibility regarding how it includes recently arrived 

English learners in statewide reading/language arts and mathematics assessments and related 

accountability goals and indicators. Specifically, ESEA section 1111(b)(3)(A) provides two 

exceptions to the general requirement that a recently arrived English learner be assessed and 

included in accountability in the same manner as all other English learners. Under the first 

exception (ESEA section 1111(b)(3)(A)(i)), an SEA may—
29

• Exempt a recently arrived English learner from one administration of the reading/language 

arts assessment required under ESEA section 1111(b)(2)(A); 

• Exclude a recently arrived English learner’s results on the mathematics and English language 

proficiency assessments for accountability purposes (the Academic Achievement indicator;

the Progress in Achieving English Language Proficiency indicator; the academic achievement 

long-term goals and measurements of interim progress; the progress in achieving English 

language proficiency long-term goal and measurement of interim progress; and any other 

indicator or long-term goal and measurement of interim progress that relies on the results of 

the mathematics or English language proficiency assessment) in the first year of the student’s 

enrollment in a school in one of the 50 States in the United States or the District of 

Columbia; and 

• Include the results on the reading/language arts, mathematics, and English language 

proficiency assessment for accountability purposes (the Academic Achievement indicator;

the Progress in Achieving English Language Proficiency indicator; the academic achievement 

long-term goals and measurements of interim progress; the progress in achieving English

language proficiency long-term goal and measurement of interim progress; and any other 

indicator or long-term goal and measurement of interim progress that relies on the results of 

the reading/language arts, mathematics, or English language proficiency assessment) in the 

second year of enrollment and thereafter.

Under this exception, neither the SEA nor its LEAs are required to include the assessment results of 

recently arrived English language learners in reporting results of the State’s accountability system 

(e.g., whether a school met or did not meet long-term goals and measurement of interim progress) 

on report cards. If an SEA exempts recently arrived English learners from one administration of the 

State’s reading/language arts assessment under this exception, State and local report cards must 

include the number of such English learners exempted. (34 CFR § 200.6(i)(1)(iii)). 

Under the second exception (ESEA section 1111(b)(3)(A)(ii)), an SEA may—

• Assess and report a recently arrived English learner’s results on the reading/language arts 

and mathematics assessments, but exclude those results for accountability purposes (e.g., the 

Academic Achievement indicator and the academic achievement long-term goals and 

measurements of interim progress) in the student’s first year of enrollment in a school in one 

of the 50 States in the United States or the District of Columbia; 

• Include a measure of such student’s growth on the reading/language arts and mathematics 

assessments for accountability purposes in the second year of the student’s enrollment in 

such a school; and 

• Include a measure of such student’s proficiency on the reading/language arts and 

mathematics assessments for accountability purposes (e.g., the Academic Achievement 

indicator and the academic achievement long-term goals and measurements of interim 

progress) in the third and each succeeding year of the student’s enrollment.

Under this exception, the ESEA requires an SEA and its LEAs to report recently arrived English 

learners’ performance on the reading/language arts and mathematics assessments in their first year 

of schooling in the United States under ESEA section 1111(h)(1)(C)(ii) and (h)(2)(C). An SEA and 

its LEAs may, however, exclude recently arrived English learners’ results in calculating the Academic 

Achievement indicator or other indicators that use data from the assessments required under ESEA 

section 1111(b) in these students’ first year of enrollment in a school in one of the 50 States in the 
30

United States or the District of Columbia as well as from the reporting of whether a school met or 

did not meet the long-term goals and measurements of interim progress for academic achievement 

in mathematics and reading/language arts established under ESEA section 1111(c)(4)(A)(i). 

Finally, under either exception, because an SEA must assess all recently arrived English learners on 

the State’s mathematics and science assessments and the State’s English language proficiency 

assessments annually, an SEA and each LEA must include their results on these assessments in 

reporting on student achievement under ESEA section 1111(h)(1)(C)(ii) and (h)(2)(C), respectively, 

every year.

F. REPORTING DATA FROM THE CIVIL RIGHTS DATA 

COLLECTION (CRDC)

F-1. What is the data collected under section 203(c)(1) of the Department of Education 

Organization Act that SEAs and LEAs must include on report cards?

The data collected pursuant to section 203(c)(1) of the Department of Education Organization Act 

(20 U.S.C. 3413(c)(1)) is the Civil Rights Data Collection (CRDC). The CRDC is a biennial (i.e., 

every other school year) survey required by OCR. Since 1968, through the CRDC, OCR has 

collected data on key education and civil rights issues in the nation’s public schools for use by OCR 

in its enforcement and monitoring efforts regarding equal educational opportunity. The CRDC is 

also a resource for other Department offices and Federal agencies, policymakers and researchers, 

educators and school officials, and the public to analyze student equity and opportunity. 

The ESEA requires that State and local report cards include data from certain CRDC categories. 

The ESEA specifies that these data must be provided for all students and disaggregated by the same 

student subgroups as required to be reported under the CRDC, but only to the extent those 

subgroups align with the subgroups required under ESEA section 1111(b)(2)(B)(xi). (ESEA section 

1111(h)(1)(C)(viii), (h)(1)(D)). That is, the ESEA requires that State and local report cards include 

the CRDC data disaggregated by any subgroup that is also required under the ESEA (i.e., major 

racial and ethnic groups, English learners, gender, and children with disabilities). The ESEA 

requires that State and local report cards include information published through the CRDC on rates 

of the following:

• In-school suspensions; 

• Out-of-school suspensions;

• Expulsions;

• School-related arrests; 

• Referrals to law enforcement;

• Chronic absenteeism, including both excused and unexcused absences; and 

• Incidents of violence, including bullying and harassment.

In addition, the ESEA requires that State and local report cards use CRDC data to report the 

number of students enrolled in preschool programs and the number and percentage of students 

enrolled in accelerated coursework to earn postsecondary credit while still in high school for all 
31

students and each student subgroup. Table 3 below shows the CRDC measures that SEAs must 

select from to meet these State and local report card requirements. 

F-2. What information regarding the categories of CRDC data required under the ESEA 

can SEAs and LEAs include on report cards to meet this requirement?

The CRDC collects and reports on several measures from which an SEA and LEA must select to

include on State and local report cards to meet the reporting requirement described in question F-1. 

The following table lists these measures, including the description(s) and corresponding survey item 

code(s) for the 2015-2016 CRDC.

8

 Due to the way the CRDC data are reported, some measures 

may be comprised of more than one survey item in order to capture data on all students. For 

example, the CRDC uses separate survey items to report the number of students with disabilities and 

the number of students without disabilities who received one out-of-school suspension. Therefore, to 

report on the measure of all students who received one out-of-school suspension, data for both 

survey items would be added together. An SEA and LEA may include multiple measures within 

each category listed in the table, but the ESEA requires that report cards include at least one 

measure within each category. Each measure is listed as a separate bullet in the table and includes 

the corresponding survey items that comprise each measure. The State report card and report cards 

for each LEA in the State should include the same measures(s) within each category.

8 The descriptions and survey codes are for the 2015-2016 CRDC and are subject to change in future years. 
32

Table 3. Measures in the CRDC that may be used to meet State and local report card 

requirements

CRDC Data Categories 

Required under ESEA

Available CRDC Measures

and Corresponding CRDC Survey Items (2015-2016)

In-school suspensions

• Number of students with disabilities (P2Q21T2*) and 

without disabilities (P2Q19T2*) who received one or 

more in-school suspensions 

Out-of-school suspensions

• Number of instances of out-of-school suspensions 

(P2Q24T1†);

• Number of students with disabilities (P2Q21T3*) and 

without disabilities (P2Q19T3*) who received one out-ofschool suspension; and

• Number of students with disabilities (P2Q21T4*) and

without disabilities (P2Q19T4*) who received more than 

one out-of-school suspension.

Report cards may include one or more of the following 

associated measures only in addition to at least one of the 

measures above: 

• Number of instances of preschool out-of-school 

suspensions (P2Q18T1†);

• Number of preschool children who received one out-ofschool suspension (P2Q17T1*†); and 

• Number of preschool children who received more than 

one out-of-school suspension (P2Q17T2*†).

Expulsions 

• Number of students with disabilities (P2Q21T5*) and 

without disabilities (P2Q19T5*) who received an 

expulsion with educational services

• Number of students with disabilities (P2Q21T6*) and 

without disabilities (P2Q19T6*) who received an 

expulsion without educational services

• Number of students with disabilities (P2Q21T7*) and 

without disabilities (P2Q19T7*) who received an 

expulsion under zero tolerance policies

Report cards may include the following associated measure 

only in addition to at least one of the measures above: 

• Number of preschool children who received an expulsion 

(P2Q17T3*†)

School-related arrests

• Number of students with disabilities (P2Q21T9*) and 

without disabilities (P2Q19T9*) who received a schoolrelated arrest

Referrals to law enforcement • Number of students with disabilities (P2Q21T8*) and 

without disabilities (P2Q19T8*) who were referred to a 

law enforcement agency or official

Chronic (student) absenteeism

(including both excused and 

unexcused absences)

• Number of students absent 15 or more days during the 

school year (P2Q09T1*†)
33

Incidents of harassment or 

bullying

• Number of allegations of harassment or bullying on the 

basis of (1) sex; (2) race, color, or national origin; (3) 

disability; (4) sexual orientation; or (5) religion (P2Q29T1)

Report cards may include one or more of the following 

associated measures only in addition to the measures above: 

• Number of students reported as harassed or bullied on the 

basis of sex (P2Q30T1*†)

• Number of students reported as harassed or bullied on the 

basis of race, color, or national origin (P2Q30T2*†)

• Number of students reported as harassed or bullied on the 

basis of disability (P2Q30T3*†)

Incidents of violent offenses

• Number of incidents of the following offenses: (1) rape or 

attempted rape; (2) sexual assault other than rape; (3) 

robbery with a weapon; (4) robbery with a firearm or 

explosive device; (5) robbery without a weapon; (6) 

physical attack or fight with a weapon; (7) physical attack 

or fight with a firearm or explosive device; (8) physical 

attack or fight without a weapon; (9) threats of physical 

attack with a weapon; (10) threats of physical attack with a 

firearm or explosive device; (11) threats of physical attack 

without a weapon; and (12) possession of a firearm or 

explosive device (P2Q26T1)

Report cards may include one or more of the following

associated measures only in addition to the measures above:

• Firearm use: Indicator of at least one incident at a school 

that involved a shooting, regardless of whether anyone 

was hurt (P2Q27T1)

• Homicide: Indicator that any of a school’s students, 

faculty, or staff died as a result of a homicide committed at 

the school (P2Q28T1)

Preschool programs

• Number of children enrolled in preschool programs or 

services (preschool refers to preschool programs and 

services for children ages 3 through 5) (P1Q08T1*†)

Accelerated coursework to earn 

postsecondary credit while still 

in high school

• Number of students enrolled in each of the following: (1) 

at least one Advanced Placement (AP) course 

(P1Q35T1*†); (2) the International Baccalaureate (IB) 

Diploma Programme (P1Q31T1*†); and (3) dual 

enrollment/dual credit programs (P1Q43T1*†)

Notes: *Disaggregated groups include the following: (1) race; (2) sex; and (3) limited English proficient. †Disaggregated 

groups include students served under the IDEA.
34

F-3. What preschool enrollment information is an SEA and LEA required to include on 

report cards?

SEAs and LEAs are only required to report preschool enrollment data that are submitted in 

accordance with the CRDC data collection. (ESEA section 1111(h)(1)(C)(viii); (h)(1)(D)(i); and 

(h)(2)(C)). The CRDC preschool enrollment data, described in Table 3, only include information on 

the number of children served in an LEA’s preschool program(s) or service(s), including programs 

and services that are provided by a non-LEA facility that has been contracted by the LEA. The 

CRDC data collection does not include data necessary to calculate the percentage of students 

enrolled in preschool programs, nor does it include information on children receiving preschool 

services provided under State-administered preschool programs or by other entities, such as 

community-based organizations. Therefore, SEAs and LEAs are not required to include such 

information on report cards. In addition to the required CRDC data on the number of students 

enrolled in preschool programs, an SEA and LEA may choose to include other information related 

to preschool enrollment on report cards, such as the number and percentage of students enrolled in 

preschool programs not included in the CRDC. If an SEA or LEA elects to include such 

information, it should report this information separately. 

F-4. How does an SEA and LEA determine the percentage of students enrolled in 

accelerated coursework to earn post-secondary credit while still in high school?

To determine the percentage of students enrolled in accelerated coursework to earn post-secondary 

credit while still in high school, an SEA and LEA would use a school’s enrollment as reflected on 

the CRDC’s Student Enrollment survey items (P1Q07T1) as the denominator. To the extent that 

using school-wide student enrollment as the denominator would undermine the comparability of 

data for certain schools (e.g., K-12 schools) an SEA or LEA may also determine the percentage

using a denominator from an alternate data source (e.g., based on enrollment in grades 9-12). If an

SEA or LEA elects to include such information, it should report this information separately. 

F-5. Does the ESEA require that the SEA and LEA use the CRDC data described in 

question F-2 to meet the reporting requirements? 

Yes. At a minimum, the ESEA requires that SEAs and LEAs use CRDC data to meet the reporting 

requirements under ESEA section 1111(h)(1)(C)(viii) and (h)(2)(C). To support SEAs and LEAs in 

doing so, the Department will make available to SEAs the CRDC data that the ESEA requires them 

to use to meet this reporting requirement (discussed in the questions above). For an SEA in which 

LEAs produce local report cards (as opposed to instances where the SEA produces the local report 

cards), the SEA would be responsible for providing each LEA with the CRDC data that must be 

used to meet this reporting requirement.

F-6. How can an SEA and LEA meet their privacy obligations while including the CRDC 

data on State and local report cards?

The best way an SEA and LEA can avoid risking a privacy disclosure in the CRDC data included on 

report cards is to use CRDC data files available from the Department. (See question F-11 for how 

data will be made available.) This will ensure that appropriate and consistent methodologies for 

protecting student privacy are uniformly applied to the data that will be used in the report cards.

This also will ensure that information that is provided on State and local report cards is aligned with 
35

what the Department provides in its public release of CRDC data, thus ensuring consistency and 

reducing the risk of disclosure of personally identifiable information. If an SEA or LEA uses data 

submitted to the Department and applies its own privacy protections, instead of the data released by 

the Department to which privacy protection routines have been applied, it will be difficult, if not 

impossible, to avoid an inadvertent disclosure when using the data released by the SEA or LEA in 

combination with data released by the Department.

F-7. Does the ESEA require that the SEA and LEA include CRDC data on report cards 

annually?

Yes. The ESEA requires an SEA and its LEAs to include CRDC data annually on their report 

cards. (ESEA section 1111(h)(1)(C)(viii) and (h)(2)(C)). Since the CRDC is a biennial data 

collection, SEAs and LEAs may include the same information on report cards over consecutive 

years, using the most recently available data provided by the Department, in order to meet this 

reporting requirement.

F-8. What if an SEA or LEA has more recent data than what is available in the CRDC

data file provided by the Department?

The Department recognizes that SEAs and LEAs may have access to data on the items used to 

fulfill this reporting requirement that are more recent than the most recent CRDC data. At a 

minimum, the ESEA requires that an SEA and its LEAs use the data reported through the CRDC

when reporting on school quality, climate, and safety, preschool enrollment, and accelerated 

coursework on State and local report cards. (See question F-2 for a complete list of measures that 

can be used to meet the requirements within these categories of CRDC data.) Using CRDC data, as 

provided by the Department, helps ensure consistency across SEAs and LEAs in how the data items 

are defined, reported, and protected with respect to privacy. 

As noted in questions B-2 and C-2, SEAs and LEAs can include additional information on report 

cards if they wish to do so. Therefore, an SEA or LEA may include on report cards information 

that they collect annually that represents data on the same metric that LEAs submit for the purposes 

of the CRDC biannually during years when new CRDC data are not available. If an SEA or LEA 

elects to include such information, it should report this information separately and specify each 

additional data source. 

F-9. May an SEA or an LEA provide a web link to CRDC data on its report card in lieu of 

including the actual CRDC data?

No. It is not sufficient for an SEA or an LEA to provide a link to the State CRDC data posted on 

the Department website. An SEA and an LEA must include on their report cards the information 

required under ESEA section 1111(h)(1)(C)(viii) and (h)(2)(C). 

F-10. Which school year of data must SEAs and LEAs include on the report cards and how 

can SEAs and LEAs obtain the data file(s)?

State and local report cards must include data on school quality, climate, and safety, preschool 

enrollment, and accelerated coursework from the most recently available CRDC data. For example, 

State and local report cards that include information from the 2017–2018 and 2018–2019 school 
36

years will use the CRDC data from the 2015–2016 school year. Individual State-specific files of the 

CRDC data will be available to States on the ED.gov website. An SEA and LEA do not need to

delay the release of report cards because they are waiting for more recent CRDC data. 

F-11. In what format will the CRDC data be provided?

Each State-specific CRDC data file, which contains data for all schools for which LEAs submitted 

data within the State, will be made available to SEAs in a commonly used open data format, such as 

CSV or XML or JSON.

F-12. Where can an SEA and LEA find documentation about the data file(s)?

The User Guide for the CRDC provides information about the purpose of the data collection, the 

target population and respondents, data anomalies and considerations, data collection procedures, 

the data file structure, and data processing (http://ocrdata.ed.gov/DataFileUsersManual). In 

addition, the CRDC survey forms are also available. All of the data documentation for the CRDC is 

available at: http://crdc.ed.gov/.

F-13. What privacy protections are implemented in the data files?

The Department applies privacy protection routines to the CRDC data that LEAs submit. The 

CRDC data that are derived from personally identifiable information contained within students’ 

education records are protected by FERPA. (20 U.S.C.1232g; 34 CFR Part 99). In the publicly

available data files, statistical disclosure limitation methods have been applied to reduce the risk of 

disclosure of individual student information. The specific rounding methodologies for the privacy 

protection routines are described in the User Guide (http://ocrdata.ed.gov/DataFileUsersManual) 

for the CRDC data file. Non-student information (e.g., teacher counts and dollar figures) is not 

subject to the same privacy provisions and is therefore not rounded. The data documentation 

contains language that an SEA and its LEAs may include on their report cards to describe the 

privacy protection rules and important considerations for interpreting the privacy-protected data.

F-14. What should an SEA do if the data submitted for the CRDC are missing or 

incomplete?

In the case of an SEA in which an LEA is missing from the CRDC data file or in which an LEA is 

missing data on key element(s), the ESEA requires that the SEA still report the required data to 

produce a State report card based on the LEAs that are included in the file that the Department 

provides to SEAs. The SEA may choose to annotate the report card to indicate that data for a 

particular LEA are missing. In such cases, the LEA may choose to report on other data sources that 

measure the same or similar metrics; however, the LEA must note that the CRDC data are missing.

F-15. What level of CRDC data must be included on State and local report cards?

The ESEA requires SEAs and LEAs to report information submitted in accordance with the 

CRDC. (ESEA section 1111(h)(1)(C)(vii) and (h)(2)(C)). Because SEAs and LEAs submit CRDC 

data at the school level, an SEA and its LEAs must report school-level CRDC data on State and 

local report cards. An SEA and its LEAs are not required to aggregate the CRDC data at the State 

or LEA levels. However, an SEA and its LEAs may choose to provide CRDC data aggregated at 
37

the State or LEA levels to provide additional context and to allow for easier comparisions.

Any SEA and LEA interested in publishing SEA or LEA aggregations should be aware of the 

complex privacy risks potentially caused by the interconnection of these aggregations with the 

existing privacy protections applied to the school-level data. SEAs and LEAs interested in 

aggregating the CRDC data to the State or LEA levels are encouraged to contact the Department’s 

PTAC for support in developing a compatible disclosure avoidance plan by emailing 

PrivacyTA@ed.gov. 

G. REPORTING ON EDUCATOR QUALIFICATIONS

G-1. What information must State and local report cards include on educator qualifications?

The ESEA requires that each State and local report card include, in the aggregate and disaggregated 

by high-poverty and low-poverty schools, the number and percentages of (1) inexperienced teachers, 

principals, and other school leaders; (2) teachers teaching with emergency or provisional credentials; 

and (3) teachers who are not teaching in the subject or field for which the teacher is certified or 

licensed (i.e., out-of-field teachers). (ESEA section 1111(h)(1)(C)(ix), (h)(2)(C)).

G-2. What definitions apply to the requirement that each SEA and LEA report on 

educator qualifications? 

Section 8101(44) of the ESEA defines a school leader as a principal, assistant principal, or other 

individual who is: (1) an employee or officer of an elementary school or secondary school, LEA, or 

other entity operating an elementary school or secondary school; and (2) responsible for the daily 

instructional leadership and managerial operations in the elementary school or secondary school 

building. Thus, in the context of State and local report cards, “other school leaders” includes 

individuals other than principals that meet the definition of a school leader.9 

The remaining terms applicable to reporting educator qualifications are not defined by the ESEA for 

reporting purposes. An SEA may, at its discretion, consider adopting a uniform, statewide 

definition of additional terms in order to ensure consistency and comparability across the State with 

respect to reporting on educator qualifications. For example, an SEA may choose to define a “highpoverty school” as a school in the top quartile of poverty in the State and a “low-poverty school” as 

a school in the bottom quartile of poverty in the State. An SEA also may, at its discretion, consider 

adopting a uniform, statewide definition of the term “teachers who are not teaching in the subject or 

field for which the teacher is certified or licensed.” Ensuring that this term has consistent meaning 

when reported could increase public understanding of staffing needs in high-poverty and difficultto-staff schools and could encourage SEAs to target efforts to recruit, support, and retain excellent 

educators in these schools.

9 Please see page 17 of the Department’s non-regulatory guidance for Title II, Part A for additional discussion of 

personnel included in “other school leaders”: http://www2.ed.gov/policy/elsec/leg/essa/essatitleiipartaguidance.pdf. 
38

H. REPORTING PER-PUPIL EXPENDITURES

H-1. What information must State and local report cards include on per-pupil 

expenditures? 

The ESEA requires that State report cards include “[t]he per-pupil expenditures of Federal, State, 

and local funds, including actual personnel expenditures and actual nonpersonnel expenditures of 

Federal, State, and local funds, disaggregated by source of funds, for each local educational agency 

and each school in the State for the preceding fiscal year.” (ESEA section 1111(h)(1)(C)(x)). The 

ESEA also requires that local report cards include per-pupil expenditures of Federal, State, and local 

funds, including actual personnel expenditures and actual nonpersonnel expenditures of Federal, 

State, and local funds, disaggregated by source funds for the LEA and each school served by the 

LEA. (ESEA section 1111(h)(2)(C)).

H-2. Can an SEA and its LEAs follow different procedures when calculating per-pupil 

expenditure data for State and local report cards?

Yes. An SEA has discretion to allow LEAs to establish their own procedures for calculating perpupil expenditures. However, if an SEA wants to ensure that data are uniform, understandable, and 

comparable across each LEA and school in a State, the SEA may establish uniform statewide 

procedures for calculation of per-pupil expenditures. The establishment of a uniform calculation of 

per-pupil expenditures by an SEA facilitates the comparison of the distribution of school funding 

within and across school districts. 

H-3. Can an SEA and LEA report per-pupil expenditures on State and local report cards 

by including average salary costs for school-level staff?

No. The ESEA requires that actual personnel and nonpersonnel expenditures of Federal, State, and 

local funds be used to calculate the per-pupil expenditure figures that must be included on State and 

local report cards. (ESEA section 1111(h)(1)(C)(x)). However, an SEA could include average salary 

costs for school-level staff under the additional information section of its report card, provided the 

State believes including such information will inform parents, students, and other members of the 

public about how resources are allocated in elementary and secondary schools. (ESEA section 

1111(h)(1)(C)(xiv)). See question B-2 for examples of additional information an SEA might include 

on its State report card. In addition, an LEA may include on local report cards any other 

information it determines to be appropriate, whether that information is included on the State report 

card. (ESEA section 1111(h)(2)(D)). (See question C-2 for additional information.)

H-4. What expenditures are included in the numerator and denominator when calculating 

per-pupil expenditures for State and local report cards? 

Numerator: The ESEA requires that per-pupil expenditure calculations include actual personnel and 

nonpersonnel expenditures of all Federal, State, and local funds disaggregated by source of funds. 

(ESEA section 1111(h)(1)(C)(x)). Because some types of expenditures typically are excluded for 

annual reporting purposes from these broad categories (e.g., capital expenditures) an SEA has some 

flexibility in determining the specific categories of expenditures to include. However, this flexibility 

does not negate the responsibility to include all actual personnel and non-personnel expenditures, 
39

absent a compelling reason to exclude them. Generally, an SEA and its LEAs should not include

expenditures that, if reported, would skew expenditures in certain years and thwart comparison from 

year to year. (See the National Center for Education Statistics’ (NCES) procedures below for 

examples.)

To ensure LEAs clearly understand how to collect, report, and calculate expenditure data, an SEA 

may, at its discretion, develop per-pupil expenditure reporting procedures that identify and clearly 

communicate the specific expenditures that must be included in the numerator of per-pupil 

expenditure calculations for each LEA and each school in the State, as well as those expenditures 

that must be excluded. In order to provide full and clear information to parents and the public, 

SEAs may want to make such guidance publicly available on its website and to link to the

information on the State and local report cards, so that parents and the public can better understand 

the data that are included in this section of the report card.

To reduce burden, an SEA and its LEAs have the flexibility to align their procedures with existing 

NCES data collection procedures and to work closely with LEAs when developing guidance on how 

to calculate per-pupil expenditures. Under NCES data collection and publication procedures, the 

numerator for per-pupil expenditures consists of current expenditures (see ESEA section 8101(12)), 

which are comprised of expenditures for the day-to-day operation of schools and LEAs for public 

elementary and secondary education, including expenditures for staff salaries and benefits, supplies,

and purchased services. General administration expenditures and school administration expenditures 

are also included in current expenditures. (See question H-17 for additional details.)

10

Current expenditures include expenditures for the functions of: instruction, instructional staff 

support services, student support services, general administration, school administration, operation 

and maintenance of plant, student transportation, other support services (e.g., business/central 

services), food services, and enterprise operations. For the above functions, this includes 

expenditures for the objects of: salaries, employee benefits, supplies (e.g., physical textbooks, pens 

and pencils, paper, printing and copying supplies, CDs, flash or jump drives, parallel cables, monitor 

stands, etc.), purchased services (e.g., the professional services of medical doctors, lawyers, 

architects, auditors, accountants, bankers, therapists, audiologists, dieticians, editors, negotiations 

specialists, paying agents, systems analysts, or planners; or training provided for teachers or other 

employees by a third-party vendor as part of their professional development). 

Under NCES’ procedures, the following items are excluded from current expenditures: repaying 

debts (e.g., bond retirement and interest on long-term debt), capital outlays (e.g., construction, 

purchases of land, etc.), community services, adult education, payments to private schools, payments 

to other LEAs, and payments to charter schools outside the LEA.

Denominator: An SEA and its LEAs have discretion to determine a student count procedure (e.g., 

membership11 with a fall count date, averaged count of students in membership over the school year, 

membership count with multiple count dates, averaged count of students in attendance over the 

10 NCES’ Data Collection Procedures: The NCES Common Core of Data (CCD) Public Elementary/Secondary Agency 

Universe Survey annually collects a count of students taken on the school day closest to October 1, which includes 

students in the group or classes that are part of a public school program that is taught in the year or years preceding 

kindergarten. This count is used to calculate NCES per-pupil expenditure reports. 

11 Commencing the 2017-18 school year, LEA membership includes students attending a school in the LEA; students 

“tuitioned-out” to private schools by the LEA; and students in pre-kindergarten programs administered by the LEA.
40

school year) to calculate per-pupil expenditures for State and local report cards. SEAs may want to 

make this guidance publicly available on its website and to link to this guidance on the State and 

local report cards so that parents and the public can better understand the data that are included in 

this section of the report card. If an SEA identifies a statewide student count procedure, it should 

also: 

1. Ensure the year for which the student count procedure (denominator) is applied aligns with 

the school year in which expenditures are counted (numerator). 

2. Consider aligning the statewide student count procedure with existing NCES data collection 

procedures to reduce burden on LEAs and schools. 

3. Ensure the student count procedure specifies whether preschool students in a public school 

program are counted and, if they are counted, ensure the procedure outlines how to count 

them and how to identify and include the expenditures that support the counted preschool 

students in the per-pupil expenditures calculation. 

4. Evaluate whether the student count procedure selected systematically under- or over-counts 

students and, if the procedure proves to be biased (e.g., the procedure under-counts students 

in LEAs serving a higher percentage of high-poverty students), consider selecting a more 

unbiased student count procedure to calculate per-pupil expenditures. 

H-5. Should funds received from private sources be included in per-pupil expenditure 

calculations? 

An SEA and its LEAs have the flexibility to determine whether expenditures based on private 

contributions should be included in per-pupil expenditure calculations. An SEA may want to, 

however, clarify how it treats such funds in its per-pupil expenditure reporting procedures. If an 

SEA decides that expenditures paid from funds received from private sources are required to be 

included in the numerator, then the SEA should clarify for LEAs how to categorize such funds. 

H-6. Should Federal funds intended to replace local tax revenues be included in per-pupil 

expenditure calculations as Federal funds or as State and local funds?

An SEA and its LEAs have flexibility with respect to how they treat Federal funds intended to 

replace local tax revenue (see below for examples). An SEA may want to, however, clarify how it 

treats such funds in its per-pupil expenditure reporting procedure. Because some Federal funds are 

treated by LEAs in the same manner as State and local funds, rather than Federal funds, an SEA and 

its LEAs may decide to classify expenditures of Federal funds intended to replace local tax revenues 

as State and local expenditures. Impact Aid is an example of a Federal program that is designed to 

replace lost tax revenue for LEAs that are burdened financially by certain activities of the Federal 

Government. There are other Federal programs that are also intended to replace local tax revenues,

and SEAs should develop procedures for classifying, for the purposes of per-pupil expenditure 

disaggregation, these Federal programs. Although there may be other Federal programs that 

generate Federal funds for LEAs that are also intended to replace lost local tax revenues, provided 

below are some examples: 

• Department of Defense: The Impact Aid for Military Connected School Districts program 

is operated by the Department of Defense Education Activity's (DoDEA) Educational 

Partnership and, like Impact Aid, replaces local tax revenue for military-connected LEAs.
41

• Department of the Interior: “Payments in Lieu of Taxes” (PILT) are payments to local 

governments that help offset losses in property taxes due to non-taxable Federal lands 

within their boundaries. 

H-7. What options exist for reporting particular expenditures at the LEA and school level? 

An SEA and its LEAs have flexibility when determining the entity level (LEA or school) at which to 

report specific expenditures, provided all actual personnel and non-personnel expenditures are 

included and reported where they are actually spent (e.g., the salary of a teacher who is assigned to 

that school). In practice, there are typically three groups of expenditures: those clearly spent at the 

school level and recorded at the school level, those recorded at the central level that impact a 

particular school, and those recorded at the central level for central administrative functions. As 

described below in greater detail, an SEA and its LEAs may elect to:

• Separately display the amount of expenditures directly reported at the school level and 

expenditures that are borne by the central office at the LEA level; or

• Report one summative expenditure figure for each school that includes expenditures that 

can be directly reported at the school level and expenditures that are borne by the central 

office at the LEA level and assigned to each school (including both those that impacted that 

particular school directly and the school’s relative proportion of central office administrative 

expenditures).

An SEA and its LEAs may want to establish business rules that assign costs at the school level 

(which aggregate to the LEA level), or just at the LEA level, depending on the cost. With regard to 

funds spent centrally by an LEA, or for services provided to multiple schools in an LEA, there are a 

number of approaches an SEA and its LEAs could establish, which generally fall into two categories. 

One approach would be to assign expenditures to the school level only if those costs are related to 

instruction and support functions (e.g., teacher salaries or professional development). This 

approach also acknowledges that the benefit of some expenditures (e.g., superintendent salaries) is 

not easily allocated to accurately identify how individual schools benefit from those expenditures 

and, if prorated equally across schools, may conceal inter-school resource inequities. Under this 

approach all costs that are not related to instruction and support functions (e.g., facilities operations, 

maintenance, transportation, or food services) would be reported only at the LEA level. 

This is generally the approach NCES followed with a pilot study of school-level finance survey

(SLFS), which is an expansion of the School District Finance Survey (F-33) in the 2013–2014 and 

2014-2015 school years to include voluntary submission of school-level data on “personnel” and 

“non-personnel” expenditures.12 NCES selected this approach because the personnel and nonpersonnel variables collected matched what SEAs could readily provide for the 2013-2014 school 

year and because it provides an accurate picture of the resources typically accounted for as 

expenditures at the school level. The SLFS collection included four personnel variables 

(instructional staff salaries, student support service salaries, instructional staff support services 

salaries, and school administration salaries) and five non-personnel variables (instructional staff 

support, nontechnology-related supplies and purchased services, technology-related supplies and 

12 In 2016 the Office of Management and Budget (OMB) approved the SLFS to collect data on a volunteer basis from 

50 States and the District of Columbia, commencing with the 2016-2017 school year. 
42

purchased services, nontechnology-related equipment, and technology-related equipment). If an 

SEA elected to align its school-level uniform procedure with the pilot SLFS collection, it would 

require these nine variables to be reported at the school level, in conjunction with the remainder of 

day-to-day expenditures reported at the LEA level. An SEA could also choose to require additional 

variables not collected on pilot SLFS to be reported at the school level, such as expenditures for 

general support services; central services; fiscal services; purchasing, warehousing, and distributing 

services; executive administration; operation and maintenance of plant; printing, publishing, and 

duplicating services; planning, research, development, and evaluation; administrative technology; 

student transportation; security; safety; care and upkeep of grounds and equipment; vehicle service 

and maintenance; and food services. Provided below is an example of expenditure function 

classifications that would follow under this approach.

Table 4. School vs. LEA Expenditure Reporting by Function

School-level current expenditures per pupil LEA-level current expenditures per pupil

Function Function

1000 Instruction 1000 Instruction

2100 Support Services – Students 2100 Support Services – Students

2200 Support Services – Instruction 2200 Support Services – Instruction

2300 Support Services – General 

Administration

2400 Support Services – School 

Administration

2400 Support Services – School 

Administration

2500 Central Services

2600 Operation and Maintenance of 

Plant

2700 Student Transportation

2900 Other Support Services 2900 Other Support Services

3100 Food Services Operations

3200 Enterprise Operations

An alternate approach would be to attribute all of an LEA’s expenditures to individual schools in the 

LEA, including expenditures for things that typically are considered LEA-level functions (e.g., 

superintendent’s salary, facilities operations). These LEA-level expenditures would be prorated to 

each school based on metrics deemed appropriate for each type of expenditure, such as the number 

of students served in the school (e.g., for the superintendent’s salary), the percentage of time 

allocated by LEA personnel to each school (e.g., for staff who serve multiple schools), square 

footage (e.g., for utility costs), or other measures or formulas determined by the SEA. If an SEA 

used this approach it would choose whether to require that personnel expenditures that are often 

paid by an LEA on behalf of employees (e.g., pension and benefits expenditures) are attributed to 

each school on a prorated basis or assigned to a school based on actual individual employee pension 

and benefits expenditures.13 This approach attempts to provide the public with a full accounting of 

13 Consistent with 2 CFR § 200.431, if reporting benefit expenditures, SEAs and LEAs should include the costs of leave 

(vacation, family-related, sick or military), employee insurance, pensions, and unemployment benefit plans in per-pupil 

expenditure calculations, as they are part of the cost of personnel services. However, an SEA may find reporting on 

such expenditures to be more practicable at the LEA level only, consistent with NCES’ procedures for the F-33 and 

SLFS data collections. 
43

all LEA expenditures down to the school level, which may be appropriate because the essential goal 

of all LEA activities, even those that are administrative or recorded centrally, is to provide 

educational services to students. This approach to reporting school-level expenditure data is 

discussed in the Financial Accounting for Local and State School Systems, better known as the 

NCES accounting handbook.14 Using this approach would result in aggregate school-level 

expenditures equaling LEA-level expenditures, as all expenditures would be reported at both the 

school and LEA level. 

Regardless of the approach an SEA and its LEAs select, in order to maximize accurate interpretation 

of the data, the Department suggests that SEA and LEA report cards make clear which expenditures 

are included in which calculations.

H-8. How should per-pupil expenditure information be disaggregated on State and LEA 

report cards? 

The ESEA requires that an SEA and its LEAs report per-pupil expenditures in total (i.e., including 

all Federal, State, and local funds) and disaggregated by fund type consistent with ESEA section 

1111(h)(1)(C)(x). For disaggregation purposes, the ESEA requires that per-pupil expenditures from 

Federal funds be reported separately. However, an SEA has flexibility with respect to disaggregating 

per-pupil expenditures from State and local funds. An SEA and its LEAs may report per-pupil 

expenditures based on State and local revenue sources separately. Alternatively, because LEA 

accounting procedures typically do not require expenditures from State and local funds to be tracked 

separately, SEAs and LEAs may report the combined per-pupil expenditures from State and local 

funds. 

H-9. Do a State’s per-pupil expenditure reporting procedures need to align with existing 

Federal data collections on education spending?

No. An SEA and LEA may decide to report per-pupil expenditures using a different methodology 

than employed under existing Federal data collections. (See question H-17 for additional 

information on Federal data collections.) 

H-10. When should expenditures of funds distributed across multiple State fiscal years be 

reported? 

Expenditures should be reported in the fiscal year they occur regardless of which fiscal year

payments may have generated the funds that are spent. In some years legislative appropriations and 

14 Allison, G.S. (2015). Financial Accounting for Local and State School Systems: 2014 Edition (NCES 2015-347). U.S. 

Department of Education, National Center for Education Statistics. Washington, DC: U.S. Government Printing 

Office. See pp. 151-158. Available at: http://nces.ed.gov/pubs2015/2015347.pdf. The NCES accounting handbook is 

periodically updated and has been incorporated by most States into their uniform financial reporting requirements for 

their public elementary and secondary school systems. The use of the accounting handbook by SEAs facilitates the 

comparability of data across States and LEAs and it describes functions and objects. For reference, a “function” is the 

activity for which a service or material object is acquired. The expenditure functions include instruction, instructional 

staff support services, pupil support services, general administration, school administration, operations and maintenance, 

student transportation, other support services (such as business services), food services, enterprise operations, and total 

current expenditures. An “object” is the service or commodity obtained as a result of a specific expenditure. Objects 

reported within a function include salaries, employee benefits, purchased services, supplies, and equipment. 
44

resulting expenditures will span multiple fiscal years. For example, an LEA might receive and spend 

portions of Impact Aid payments from four different fiscal years during a single fiscal year. If an 

LEA were producing a report card for its State fiscal year 2016 (i.e., school year 2015-2016), then the

LEA should report its total expenditures from Impact Aid during the 2016 State fiscal year, 

regardless of which fiscal year generated the payments spent. 

H-11. How should expenditures be reported if they are consolidated under a schoolwide 

program? 

A Title I schoolwide program school has the flexibility to consolidate funds from Title I and other 

Federal education programs with State and local funds, which means those Federal funds lose their 

individual identity when the schoolwide program is implemented. In such a scenario, a school 

would spend the consolidated funds for any activities included in its schoolwide program plan, but 

would be unable to track expenditures of Federal funds separately from State and local funds. In 

order to report per-pupil expenditures in a schoolwide program school that consolidates funds, an 

LEA would first determine the percentage that Federal funds constitute of the total funds available 

to the schoolwide program school. The LEA would next multiply that percentage by the total 

expenditures in the schoolwide program school, excluding any noncurrent expenditures under SEA 

or LEA per-pupil expenditure reporting procedures (e.g., community services, capital outlay, and 

debt service) to derive total Federal expenditures. The LEA could then subtract the derived Federal 

expenditures from total expenditures to derive State and local expenditures for the schoolwide 

program school. These figures would then be used by the LEA to report per-pupil expenditures for 

the schoolwide program school that consolidates Federal, State, and local funds. 

H-12. Are small and rural LEAs exempted from the per-pupil expenditure reporting 

requirement? 

No. While the ESEA includes special provisions for rural and small LEAs in a number of areas, 

there is no such provision related to the reporting requirement for per-pupil expenditures. 

H-13. May SEAs and LEAs report per-pupil expenditures on a different timeline than other 

report card data?

SEAs and LEAs may want to report per-pupil expenditures as early as possible, ideally at the same 

time as other data. We recognize, however, that some statewide audit and reporting systems may 

not allow for reporting on the preceding school year expenditures until after annual report cards are 

initially disseminated. If such circumstances arise, SEAs and LEAs may update report cards with 

expenditure information as soon as it becomes available, which we would expect to be no later than 

the end of the school year during which the report cards were initially disseminated. If an SEA or 

LEA reports per-pupil expenditures on a different timeline than other data, the Department suggests 

that initially disseminated report cards include a brief description of when such data will be publicly 

available. 

H-14. Are SEAs and LEAs required to report per-pupil expenditures on report cards for the 

2017-18 school year? 

No. The Department recognizes that many SEAs and LEAs face significant technical challenges 

associated with meeting this requirement in a timely manner. Consistent with section 4(b) of the 
45

ESEA, which authorizes the Department to ensure an orderly transition to the new law, an SEA and 

its LEAs may delay, until report cards for the 2018-2019 school year, reporting information on perpupil expenditures of Federal, State, and local funds on annual report cards as required under ESEA 

section 1111(h)(1)(C)(x) and (h)(2)(C). If an SEA elects to delay reporting per-pupil expenditures, 

the SEA and its LEAs must provide on report cards for the 2017-2018 school year a brief 

description of the steps the SEA and LEAs are taking to ensure that information on per-pupil 

expenditures will be included beginning with report cards based on the 2018-2019 school year. If an

SEA and its LEAs are prepared to include per-pupil expenditure information on annual report cards 

for reporting on the 2017-2018 school year, as required under Title I of the ESEA, the Department

encourages those SEAs and LEAs to do so. 

SEAs and LEAs may want to report as early as possible and to apply lessons learned through their 

participation in regular CRDC school-level expenditure submissions, the 2009 American Recovery

and Reinvestment Act (ARRA) data collection, and the pilot SLFS collection. While the publication 

of these reports demonstrates the capacity of local entities to report accurate school-level data, the 

Department recognizes SEA and LEA accounting systems and processes will need to be updated in 

order to report per-pupil expenditures in a more timely manner. In particular, SEAs and LEAs 

should consider aligning expenditure account codes, conducting outreach to stakeholders to prepare 

them for reporting new data items, and budgeting for staff training and updates to existing hardware 

and software systems.

H-15. How may SEAs and LEAs present per-pupil expenditure data on State and local

report cards to ensure the information is understood to parents and other 

stakeholders?

An SEA and its LEAs have flexibility with respect to how they present per-pupil expenditure data 

on report cards, but, under the ESEA, the information must be presented in a format that is 

understandable to parents and other stakeholders. An SEA and its LEAs are accustomed to 

reporting financial data using expenditure classifications of fund, function, and object in annual 

public reports. (See NCES accounting handbook in footnote 15 for additional information.) These 

classifications allow for easy comparisons across districts for financial professionals and academic 

researchers, but are of limited utility to a parent who asks the question, “how much money is spent 

at my child’s school?” Thus, an SEA and its LEAs may want to consider using other formats that 

are more accessible to the public.

Although there are many potential formats through which this information can be presented, 

Appendices C and D provide two sample per-pupil expenditure reports that demonstrate how 

school and LEA information could be presented on annual report cards. In addition, in Appendix B

there is a more concise example of how school and LEA information could be presented on annual 

report cards to ensure the information is understood by parents and other stakeholders.

H-16. What resources are available to an SEA and its LEAs to support their 

implementation of the per-pupil expenditure reporting requirement?

As an SEA and its LEAs move forward with implementation of the per-pupil expenditure reporting 

requirement, there are a number of Department-supported technical assistance efforts to support 
46

their work.15

• The Building State Capacity and Productivity Center (BSCPC), one of seven national content 

centers funded through cooperative agreements with the Department, supported a financial 

transparency working group to provide assistance to States on their financial transparency 

efforts, including reporting on per-pupil expenditures. The resources that resulted from this 

working group can be found at http://www.bscpcenter.org/FinancialTransparency.

• Regional Comprehensive Centers (see list at 

https://www2.ed.gov/programs/newccp/contacts.html) can provide SEAs additional 

assistance in this area.

• The State Support Network, a technical assistance initiative offered by the Department, is 

available to States looking for individualized technical assistance or opportunities to 

participate in communities of practice on topics of interest. Information about the State 

Support Network can be found at https://statesupportnetwork.ed.gov/. 

• The State Support Network supported a District Strategic Planning and Resource Allocation 

Community of Practice in 2017. Resources resulting from this community of practice, 

including a tool to assist LEAs and SEAs in determining which expenditures to account for 

at the school level versus the LEA level, can be found at 

https://statesupportnetwork.ed.gov/resources.

• NCES continues to support State fiscal coordinators with regular, ongoing technical 

assistance, such as the annual Fiscal Coordinators Workshop, the annual Fiscal Coordinators 

Roundtable, the annual New Fiscal Coordinators Training, the School-Level Finance Survey 

Coordinators Training, and periodic webinars for SEA Fiscal Coordinators. 

H-17. Where can an SEA or LEA learn more about public reporting of school financial 

data? 

Reporting on education spending occurs most frequently through regular financial management 

reporting processes, which all public institutions are subject to, in accordance with the Generally 

Accepted Accounting Principles established by the Governmental Accounting Standards Board. 

These requirements ensure financial information such as education spending data and 

comprehensive annual financial reports are comparable and made available to the public in a 

comprehensive and uniform manner. Beyond the standard requirements for government 

accounting systems, which help determine what type of information is made public, local and State 

policymakers often establish varied public reporting requirements on education spending. For 

example, in 2013 the Education Commission of the States found that 11 States included per-pupil 

expenditures on State and LEA report cards even though not required at the time. 

The NCES National Public Education Financial Survey (NPEFS) and the School District Finance 

Survey (F-33) data collections are the primary sources for comparable reporting on education 

spending nationally, although they vary slightly by item type and collection method.16 The NPEFS 

15 The Department does not control or guarantee the accuracy, relevance, timeliness, or completeness of the information 

contained in these materials. This link is being provided for information purposes only. The inclusion of these materials 

is not intended to reflect their importance, nor is it intended to endorse any views expressed, or products or services 

offered. The opinions expressed in any of these materials do not necessarily reflect the positions or policies of the 

Department.

16 NCES and the Economic Reimbursable Surveys Division of the U.S. Census Bureau collaborate to collect public 
47

and F-33 data collections utilize common definitions for detailed account classifications, as 

described in the NCES accounting handbook. The NPEFS survey provides State-level aggregate 

finance data for revenues and expenditures for public elementary and secondary education. The F33 survey provides LEA-level finance data for all LEAs that provide free public elementary and 

secondary (preschool through grade 12) education in the United States. The F-33 data file does not 

include national and State totals. In addition to the annual fiscal LEA and State reports, NCES also 

publishes summaries of trends in elementary and secondary education spending as part of The 

Condition of Education annual report delivered annually to Congress and the White House. The U.S. 

Census Bureau also independently publishes elementary and secondary school system finance data 

from their Annual Survey of School System Finances collection. Additional helpful information can 

be found at the following links:

• NCES District Fiscal Reports: https://nces.ed.gov/ccd/pub_pubdistricts.asp

• NCES State Fiscal Reports: https://nces.ed.gov/ccd/pub_rev_exp.asp

• NCES Conditions of Education: https://nces.ed.gov/programs/coe/

• NCES Digest: https://nces.ed.gov/programs/digest/

• NCES blog: http://nces.ed.gov/blogs/nces

• U.S. Census Bureau School System Finance Report and Data: 

https://www.census.gov/programs-surveys/school-finances.html

• CRDC: http://ocrdata.ed.gov/

• ARRA School-level Expenditures Report and Data:

https://www2.ed.gov/about/offices/list/opepd/ppss/reports.html. 

I. REPORTING STATE PERFORMANCE ON THE NATIONAL 

ASSESSMENT OF EDUCATIONAL PROGRESS (NAEP)

I-1. What is NAEP?

The National Assessment of Educational Progress (NAEP) is developed and administered by IES. 

It is the largest nationally representative and continuing assessment of what America’s students 

know and can do in various subject areas. Assessments are conducted periodically in mathematics, 

reading, science, writing, the arts, civics, economics, geography, and U.S. history. Often called the 

“Nation’s Report Card,” NAEP provides information about trends in State and national student 

achievement over time and allows educational achievement to be compared across States. Since 

2002, the ESEA has required States, and LEAs if selected, to participate in the fourth and eighth 

grade NAEP assessments in reading and mathematics as a condition of receiving Title I funds.

(ESEA sections 1111(g)(2)(D) and 1112(c)(3); 34 CFR § 200.11(a) and (b)). General information 

about NAEP is available at: http://nces.ed.gov/nationsreportcard/.

education finance data, with the Census Bureau acting as the primary collection agent for the NPEFS survey. The 

Census Bureau also acts as the primary collection agent for the F-33 data collection and produces two data files: one for 

distribution and reporting by the Census Bureau; and the other for distribution and reporting by NCES. NCES refers to 

this data collection as the F-33 and the Census Bureau refers to this data collection as the Annual Survey of Local 

Government Finances: School Systems. A full explanation of the key differences between the two surveys can be found 

by reviewing the Forum Guide to Core Finance Data Elements, available at: 

http://nces.ed.gov/pubsearch/pubsinfo.asp?pubid=2007801.
48

I-2. What information from NAEP does the ESEA require on State and local report 

cards?

The ESEA and implementing regulations require that an SEA and its LEAs report the most recent 

available statewide academic achievement results in grades four and eight on the State’s NAEP 

reading and mathematics assessments, compared to the national average of such results. (ESEA 

section 1111(h)(1)(C)(xii), (h)(2)(C); 34 CFR § 200.11(c)). Additionally, an SEA and its LEAs must 

report the statewide NAEP participation rates for children with disabilities and English learners. (34 

CFR § 200.11(c)(2)). This participation rate data is instructive because, although NAEP encourages 

States to assess all students selected as a part of its sampling process, school personnel are permitted 

to make the decision to exclude children with disabilities or English learners from the NAEP 

assessment. For example, if a student would require an accommodation to participate that is not 

allowable under the NAEP administration, such as giving the reading assessment in a language other 

than English, then school personnel may elect not to have that student participate. 

The requirements for reporting State NAEP results differ slightly between State and local report 

cards. The illustration below specifies the NAEP data to be reported on each type of report card.

Table 5. Reporting State NAEP data on State and local report cards

NAEP data State

report cards

Local

report cards

The percentage of students at each NAEP achievement level 

(below basic, basic, proficient, and advanced) in the aggregate

✓ ✓

The percentage of students at each NAEP achievement level 

(below basic, basic, proficient, and advanced) disaggregated by 

the following: 

• Major racial and ethnic groups

• Children with disabilities

• English learners 

• Economically disadvantaged students

✓

(Not 

required)

Participation rate for children with disabilities ✓ ✓

Participation rate for English learners ✓ ✓

Although an SEA must report data on the above subgroups for NAEP, an SEA may also report 

other data it already collects through its statewide data system. For example, an SEA that collects 

data on the gender of students who participate in NAEP may include this information on its report 

card. Additionally, NAEP provides district-level results for a small number of urban districts. While 

an LEA for which district-level NAEP results are available may choose to include that information 

on its local report card, it is not required to do so.

I-3. What are the key differences between State assessments and State NAEP? 

State assessments measure student performance against the State’s own curriculum and academic 

content standards (the standards defined and formally adopted by the State that specify what the 

students should know and be able to do). State assessments allow comparisons of results over time 

within the State and produce individual student scores for each student to provide information to 

parents and educators to inform instruction. With some exceptions, State assessments typically do 
49

not allow comparisons of results with other States (unless the two States administered the same 

assessment) or across the nation. 

The NAEP assessments are administered uniformly across the nation using the same sets of test 

booklets. As a result, NAEP serves as a common metric for all States. NAEP has also given

substantially the same assessment over time so that trend data can be shown. In addition, because 

NAEP over-samples within select urban districts, NAEP provides comparison data for those LEAs. 

However, NAEP is administered to only a sample of students and each student takes only a portion 

of the test to minimize the burden and testing time for selected classes; as a result, it does not 

produce individual student scores. 

I-4. How can an SEA or an LEA clearly articulate the differences between NAEP 

and State assessments in a manner that is easily understandable to parents and the 

public?

Providing parents and the public with information about the differences between NAEP and State 

assessments, in a manner that is easily accessible and understandable, could be helpful to them in 

interpreting the data reported on State and local report cards. Because simple comparisons of 

student performance on NAEP and State assessments cannot be made without some understanding 

of the key differences between the two assessments, SEAs and LEAs may want to provide 

information on interpreting NAEP results. 

NCES has developed web-based informational packets that SEAs and LEAs may use to inform 

parents, students, teachers, and the general public about NAEP. These informational packets also 

discuss the similarities and differences between State assessments and NAEP assessments. 

Additionally, they serve as an excellent resource to SEAs and LEAs in crafting language to discuss 

the relationship between State assessments and NAEP. These informational packets are available at:

http://nces.ed.gov/nationsreportcard/infofor.asp.

I-5. May an SEA or an LEA provide a web link to NAEP results on its report card in lieu 

of reproducing the actual NAEP results?

No. It is not sufficient for an SEA or an LEA to provide a link to the State NAEP results posted on 

the NCES website. The SEA and its LEAs must include on their report cards the information 

required under ESEA section 1111(h)(1)(C)(xii) and (h)(2)(C) and 34 CFR § 200.11(c). Including 

NAEP results on State and local report cards provides greater transparency and gives parents easy 

access to an important tool for assessing the educational performance of students in their State. 

I-6. How can an SEA and LEA ensure the timely release of its report card and still report 

the most current State NAEP results for reading and mathematics?

Typically, State NAEP mathematics and reading results are released six months after the 

administration of the assessment, which is administered biennially in the winter. So, 2017-2018 and 

2018–2019 report cards would likely report the 2017 NAEP data, reported in the spring. If an SEA 

and LEA would normally release its report card before the State NAEP results are available, it does

not need to delay that release to include the most recent NAEP results. However, the SEA and

LEA should update its report card with the more recent NAEP results once they become available.
50

J. REPORTING POSTSECONDARY ENROLLMENT RATES FOR 

EACH HIGH SCHOOL

J-1. What postsecondary data does the ESEA require that an SEA and its LEAs include 

on their report cards?

The ESEA requires that, depending upon the availability of data, report cards include rates of 

postsecondary enrollment at the State, LEA, and school level for the cohort of students that 

enroll in programs of postsecondary education in the first academic year that begins after the 

students’ graduation. (ESEA section 1111(h)(1)(C)(xiii) and (h)(2)(C)). The ESEA requires that 

the SEA and its LEAs report the information: 

• Where available for programs of public postsecondary education in the State; and 

• If available and to the extent practicable for programs of private postsecondary education in the 

State and programs of postsecondary education outside the State.

To the extent postsecondary enrollment data are available, the ESEA requires that the SEA and 

its LEAs report such data for the “all students” group and disaggregated by students in each racial 

and ethnic subgroup, disability status, English learner status, and status as economically

disadvantaged. (ESEA section 1111(h)(1)(C)(xiii) and (h)(2)(C)).

J-2. How does the ESEA define a “cohort” for purposes of reporting on postsecondary 

enrollment?

The ESEA establishes a cohort for the purposes of reporting postsecondary enrollment based on

all students who graduated from high school in a given school year (which includes the regular 

school year and may also include the summer session immediately following the regular school 

year). (ESEA section 1111(h)(1)(C)(xiii) and (2)(C)). Thus, the denominator would include all 

students the State considers graduates.

J-3. How should an SEA and its LEAs calculate a postsecondary enrollment rate?

To calculate the postsecondary enrollment rate, an SEA and its LEAs should divide the number of 

students who enroll in programs of postsecondary education within the first academic year after 

graduation from high school by the cohort of graduates. However, since SEAs may not be able to 

easily track students who go to school out of State or who do not enroll in a postsecondary 

program, an SEA and its LEAs may want to make sure it is clear in the reported data that the 

denominator includes students whom they were unable to track. 

As an SEA determines the method to display these data, it could consider including: (1) a clear data 

note explaining which students are included in the numerator versus the denominator; and (2) 

separate counts for students enrolling in programs of postsecondary education, students not 

enrolling in programs of postsecondary education, and students whose actions the SEA is unable 

to track.
51

J-4. What is a “program of postsecondary education” for the purposes of reporting 

postsecondary enrollment?

The ESEA does not define “program of postsecdondary education.” In order to ensure consistency 

and comparability with respect to reporting, however, an SEA may want to adopt a uniform, 

statewide definition of a “program of postsecondary education.” 

J-5. Where may an SEA obtain postsecondary enrollment data?

Data to meet this requirement could be obtained from a variety of sources. For example, SEAs that 

currently report on postsecondary outcomes obtain data from the National Student Clearinghouse

and data-sharing agreements or memoranda of understanding with other agencies. SEAs engaging in 

data-sharing agreements may contribute data to centralized repositories (centralized model) or store 

data separately and link data on demand (federated model).17 Since 2005, the Department has 

awarded State Longitudinal Data System (SLDS) grants to 47 States, the District of Columbia, and 

Puerto Rico. These grants are designed to increase their capacity to link data systems.18 

The Department understands that it is easier for SEAs to track student enrollment in public, in-state 

institutions than in private institutions and public out-of-state institutions. The ESEA requires that 

SEAs report available data on enrollment in public programs of postsecondary education within the 

State, even if they cannot report on in-state private programs of postsecondary education or 

programs of public and private postsecondary education outside the State.

J-6. Does the ESEA require that an SEA and its LEAs report postsecondary enrollment 

by type of institution (e.g., public, private, two-year, or four year)?

No. An SEA and its LEAs are not required to report postsecondary enrollment by type of 

institution. However, an SEA and its LEAs are free to disaggregate by institution type to improve 

transparency for parents and other stakeholders. Two- and four-year institutions differ in cost, 

course offerings, and degrees granted; making transparent the differences in enrollment in those 

institution types may inform parent choices and program and policy decisions at the SEA or LEA 

level. 

Similarly, it may be helpful to stakeholders (but is not required) to report separately on enrollment in 

public institutions and enrollment in private institutions. An SEA and its LEAs may also want to 

separately report on enrollment in out-of-state institutions to provide the most comprehensive data 

available about student actions after their high school graduation. Providing this disaggregation also 

creates an opportunity for an SEA and its LEAs to document differences in the completeness of 

their data depending on the type of institution, since private and out-of-state enrollment will likely 

be more challenging to track than enrollment in public, in-state institutions. 

J-7. When reporting postsecondary enrollment, what academic terms may be included?

An academic year typically consists of a fall, spring, and summer term (or fall, winter, spring, and 

17 “Centralized vs. Federated – State approaches to P-20W Data Systems.” NCES 2013. Available at: 

http://nces.ed.gov/programs/slds/pdf/federated_centralized_print.pdf.

18 SLDS Map. NCES 2016. Available at: http://nces.ed.gov/programs/slds/stateinfo.asp.
52

summer, if the institution uses a quarter system). As such, for purposes of reporting on 

postsecondary enrollment, States may include students who enroll in any term in the academic year 

that immediately follows their high school graduation. If a student enrolls in a program of 

postsecondary education during the summer of his or her graduation year (i.e., the summer 

preceding the fall term that would start the next academic year), the student may be included in the 

count of students enrolling in programs of postsecondary education.

J-8. Which graduating class does ESEA require an SEA and its LEAs to include on their 

report cards for the purposes of reporting postsecondary data?

The ESEA requires that an SEA and its LEAs report on students who enroll in programs of 

postsecondary education at any time in the first academic year that follows the students’ high school 

graduation. (ESEA section 1111(h)(1)(C)(xiii) and (2)(C)). Annual State and local report cards likely 

will be published before an SEA and its LEAs know the complete number of students who enrolled 

in programs of postsecondary education from the immediately preceding graduating class, since the 

spring and summer semesters will not yet have taken place. To allow an SEA and its LEAs to 

disseminate report cards in a timely manner and still include complete data, an SEA and its LEAs 

may lag the postsecondary enrollment data by one year for its inclusion on State and local report 

cards. The following chart provides an example of the timeline for reporting for a State or LEA that 

chooses to lag the data. 

Table 6. Timeline for reporting postsecondary enrollment data on report cards.

School year of 

graduating cohort

Academic year of 

enrollment in 

programs of 

postsecondary 

education

School year in 

which report card 

is published

Report cards with information 

from the 2017-2018 school year

2016-2017 

graduating cohort

2017-2018 

enrollees

2018-2019 

publication

Report cards with information 

from the 2018-2019 school year

2017-2018 

graduating cohort

2018-2019 

enrollees

2019-2020 

publication

An SEA or LEA does not need to delay the release of report cards because it is waiting for more 

recent postsecondary enrollment data. 

J-9. What should an SEA and its LEAs report if they do not currently collect or have 

postsecondary enrollment data?

If an SEA and its LEAs do not currently collect or have postsecondary enrollment data, or only 

have partial data, they may want to consider including on the report card the school year in which 

they expect the information to be available. If an SEA and its LEAs only have partial data, they may 

want to include sufficient information to allow users to accurately interpret the data. This could 

include providing information on the number of students for whom they do not have data and

guidance for properly interpreting the data. 
53

J-10. May an SEA and its LEAs report on additional indicators related to programs of 

postsecondary education?

Yes. An SEA and its LEAs may report additional indicators related to postsecondary education if 

they are available. States may want to report on postsecondary metrics such as remediation or 

persistence, since they provide additional measures of student readiness for postsecondary 

education, and help ensure that schools and their communities understand how well students are 

prepared to succeed in and persist through postsecondary programs. States may also wish to 

report on students entering career or technical programs or students joining the military, since not 

all high school graduates will enter into a postsecondary institution. 
54

APPENDIX A: SEA AND LEA CHECKLIST FOR REPORT CARD 

ELEMENTS 

To assist SEAs and LEAs in preparing and disseminating report cards, the checklist below identifies

individual report card elements and indicates when disaggregated reporting by student subgroup is 

required.

19

This checklist uses the following abbreviations for student subgroups: 

• ALL = All students

• MREG = Each major racial and ethnic group

• CWD = Children with disabilities

• CWOD = Children without disabilities

• ELL = English learners

• ECD = Economically disadvantaged students

• Non-ECD = Students not economically disadvantaged

• GEN = Gender

• MIG = Migrant students

• HOM = Homeless children and youth

• FOS = Children in foster care

• AFD = Students with a parent who is a member of the Armed Forces on active duty, which 

includes a parent on full-time National Guard duty 

An SEA and its LEAs must also consider the following requirements in creating their report cards: 

(1) Developed in consultation with parents (State report cards only); (2) Concise; (3) Understandable 

and uniform format; (4) Accessible; (5) On a single webpage (or, for an LEA that does not operate a 

website, provided to the public in another manner determined by the LEA).

19 If an SEA uses in its accountability system a student subgroup in addition to those required under ESEA section 

1111(c)(2), the SEA and its LEAs may, but are not required to, include on State and local report cards information 

disaggregated for that subgroup including, for example, student achievement data, information on the percentage of 

students assessed and not assessed, and performance on indicators within the statewide accountability system.
55

How to Read Checklists:

The following checklists show which individual report card elements and student subgroup disaggregation are required at the State, LEA, 

and school levels. The first column indicates the report card element; the second column indicates the disaggregation required for each 

element; and the third column indicates whether an element must be reported at the State, LEA, and/or school levels. Gray boxes in the 

third column indicate elements that are not required at the State, LEA, or school levels. Subsections within the second column indicate 

when disaggregation requirements differ between State, LEA, and individual school report cards. Similarly, bullets within the first column 

indicate when information required at the State, LEA, and school levels vary. 

State and LEA Checklist. Report Card Elements

Element Disaggregation or Reporting 

Level Required

Checklist 

State LEA School

• Student achievement data (i.e., the number and percentage of students 

at each level of achievement on the State mathematics, reading/ 

language arts, and science assessments)

o LEA: Including how achievement in the LEA compares to the State 

as a whole

o Schools: Including how achievement in the school compares to the 

LEA and the State as a whole

ALL, MREG, CWD, CWOD, 

ELL, ECD, Non-ECD, GEN, 

MIG, HOM, FOS, AFD

• Percentages of students assessed and not assessed in each subject (i.e., 

participation rates)

ALL, MREG, CWD, CWOD, 

ELL, ECD, Non-ECD, GEN, 

MIG

• Performance on the Other Academic indicator ALL, MREG, CWD, ELL, ECD

• English language proficiency of English learners (i.e., number and 

percentage of English learners achieving English language proficiency as 

measured by the State’s English proficiency assessment)

Not applicable

• As applicable, number and percentage of recently arrived English 

learners exempted from one administration of the reading/language arts 

assessments or whose results are excluded from certain State 

accountability system indicators

Not applicable

• High school graduation rates

o Four-year adjusted cohort ALL, MREG, CWD, ELL, ECD, 

HOM, FOS
56

Element Disaggregation or Reporting 

Level Required

Checklist 

State LEA School

o Extended-year adjusted cohort (if State chooses) ALL, MREG, CWD, ELL, ECD, 

HOM, FOS

• Performance on the School Quality or Student Success indicator(s) used 

in the State accountability system

ALL, MREG, CWD, ELL, ECD

• Extent of use of AA-AAAS for students with the most significant 

cognitive disabilities (i.e., number and percentage of students assessed 

on AAAA-AS, by grade and subject)

Not applicable

• Postsecondary enrollment rates for each high school (if available)

o Public postsecondary institutions ALL, MREG, CWD, ELL, ECD

o Private and out-of-state postsecondary institutions ALL, MREG, CWD, ELL, ECD

• Data from the CRDC

o School climate

▪ In-school suspensions ALL, MREG, CWD, ELL, GEN

▪ Out-of-school suspensions ALL, MREG, CWD, ELL, GEN

▪ Expulsions ALL, MREG, CWD, ELL, GEN

▪ School-related arrests ALL, MREG, CWD, ELL, GEN

▪ Referral to law enforcement ALL, MREG, CWD, ELL, GEN

▪ Chronic absenteeism (excused and unexcused) ALL, MREG, CWD, ELL, GEN

▪ Incidents of violence (including bullying and harassment) ALL, MREG, CWD, ELL, GEN

o Other CRDC indicators

▪ Number of students enrolled in preschool programs ALL, MREG, CWD, ELL, GEN

▪ Number and percentage of students enrolled in accelerated 

coursework (e.g., AP and IB) ALL, MREG, CWD, ELL, GEN

• Progress toward State-designed long-term goals, including 

measurements of interim progress ALL, MREG, CWD, ELL, ECD
57

Element Disaggregation or Reporting 

Level Required

Checklist 

State LEA School

• Educator qualifications

o Inexperienced High- and low-poverty schools

o With emergency/provisional credentials High- and low-poverty schools

o Not teaching in subject/field of certification/licensure High- and low-poverty schools

• Per-pupil expenditures – actual personnel and actual non-personnel; 

for each LEA and each school

o In aggregate SEA, LEA, and School

o Disaggregated:

▪ Federal

▪ State/local

SEA, LEA, and School

• State performance on the NAEP – mathematics and reading, grades 4 

and 8

SEA LEA

ALL, MREG, 

CWD, ELL, ECD

All Statewide

• Information on school improvement funds under ESEA section 1003 

by LEA and school

o Names of LEAs and schools receiving school improvement funds Not applicable

o Amount of funds received by each school Not applicable

o Types of strategies implemented in each school Not applicable

• Clear and concise description20 of State accountability system

o Minimum number of students (i.e., n-size) for use in accountability 

system

Not applicable

o Long-term goals Not applicable

o Measurements of interim progress Not applicable

20 A SEA or LEA may provide the web address or URL of, or a direct link to, a State plan or other location on the SEA’s website to meet the reporting requirement 

for a description of the State accountability system. 
58

Element Disaggregation or Reporting 

Level Required

Checklist 

State LEA School

o Indicators to meaningfully differentiate all public schools in the 

State

Not applicable

o System for meaningful differentiation among schools Not applicable

▪ Specific weight of the accountability indicators Not applicable

▪ Method of identifying schools as consistently underperforming, 

including time period the State uses to determine consistent 

underperformance 

Not applicable

▪ Method of identifying schools for comprehensive support and 

improvement

Not applicable

o Exit criteria established by the State for (1) schools identified for 

comprehensive support and improvement and (2) schools identified 

for additional targeted support and improvement, including the 

number of years after which, if the exit criteria are not satisfied, in 

the case of Title I schools, such schools will be identified for 

comprehensive support and improvement

Not applicable

o Number and names of all schools identified for comprehensive 

support and improvement 

Not applicable

o Number and names of all schools identified for targeted support 

and improvement, including those identified for additional targeted 

support and improvement (i.e., schools implementing targeted 

support and improvement plans)

Not applicable
59

APPENDIX B: DATA VISUALIZATION EXAMPLES 

The examples provided in this appendix are merely meant to provide illustrations of 

possible approaches a State and district could take to present its information. 

Figure 1. Concise presentation of information.

The example below in Figure 1 organizes data elements into thematic “views,” which can be 

accessed from a sidebar. Filters for student demographics and school year give the user finer control 

over what they see, and a toggle allows them to switch from viewing data in charts to viewing data in 

tables. Finally, a smart search bar at the top allows for easy navigation to another school, district, or 

State profile.
60

Figure 2. Sample display of student performance assessment data.

Figure 2 shows one example of how school and LEA information could be presented on annual 

report cards. In the top graphic, stacked bar charts display the percentage of students at each 

performance level across mathematics, reading/language arts, and science. Tooltips (i.e., information 

that appears when you hover a cursor over a bar) can be used to reveal the number of students at a 

given performance level. The filter, as illustrated in the bottom graphic, provides access to 

assessment data for specific subgroups. In cases where subgroup data is suppressed, the 

visualization is “grayed out.” 
61
62

Figure 3. Sample display of per-pupil expenditure data.

Figure 3 displays stacked bar charts showing per-pupil expenditures by funding source for schools in 

a LEA. Tooltips (i.e., information that appears when you hover a cursor over a bar) demonstrate 

how to reveal additional information for each data point. An “Add a School” button makes it 

simple for a user to add more schools to the visualization. 
63

APPENDIX C: PER-PUPIL EXPENDITURE EXAMPLE – All Expenditures Reported at the School Level 

The following tables present detailed examples of per-pupil expenditure reporting. Please note that while an SEA or LEA could consider including the 

additional information reflected in this example, it is only required to provide the total per-pupil expenditure, disaggregated by Federal and State/local 

funds. (See figures in the last column of each table highlighted in gray.)

School Report

Expenditure Report by Revenue Source, Year Ending June 30, 2019

School Direct instruction costs

Salaries Benefits 

Purchased 

services

Materials 

and 

supplies

Other 

expenses

School 

indirect

LEA

indirect Total 

Membership 

Count

Per-pupil 

Expenditures

Jefferson - 0001 

(Federal)

$86,786 $24,639 $9,037 $4,942 $1,036 $67,373 $180,000 $373,813 190 $1,967 

Jefferson - 0001 

(State and local)

$781,072 $221,747 $81,332 $44,475 $9,325 $691,684 $484,862 $2,314,497 190 $12,182 

Jefferson - 0001 

(Total)

$867,858 $246,386 $90,369 $49,417 $10,361 $759,057 $664,862 $2,688,310 190 $14,149 

School indirect costs are functionally distributed as reported below:

2100 Student Support Services $108,084 2310 Board of Education $0 2580 Administrative 

Technology

$0 

2220 Library Services $48,294 2320 Executive Administration $0 2610 Operation of Building $218,282 

2212 Instruction & Curriculum 

Development Services

$0 2400 School Administration $177,953 2630 Maintenance $118,450 

2213 Instructional Staff Training $2,671 2510 Fiscal Services $0 2700 Student Transportation $85,323 

3100 Food Service $0

LEA indirect costs are functionally distributed as reported below:

2100 Student Support Services $0 2310 Board of Education $10,230 2580 Administrative 

Technology

$35,317 

2220 Library Services $0 2320 Executive Administration $55,000 2610 Operation of Building $0 

2212 Instruction & Curriculum 

Development Services

$14,862 2400 School Administration $0 2630 Maintenance $0 

2213 Instructional Staff Training $0 2510 Fiscal Services $39,453 2700 Student Transportation $0 

3100 Food Service $510,000
64

LEA Report

Adams Unified Expenditure Report by Revenue Source, Year Ending June 30, 2019

School Direct instruction costs

Salaries Benefits 

Purchased 

services

Materials 

and 

supplies

Other 

expenses

School 

indirect

LEA

indirect Total 

Membership 

Count

Per-pupil 

Expenditures

Washington - 0001 $1,023,451 $284,114 $110,000 $41,021 $35,012 $1,501,221 $154,862 $3,149,681 240 $13,124

Jefferson - 0001 $867,858 $246,386 $90,369 $49,417 $10,361 $759,057 $664,862 $2,688,310 190 $14,149 

Lincoln – 0001 $1,045,333 $286,812 $70,124 $51,123 $5,123 $712,312 $154,862 $2,325,689 173 $13,443 

Adams Unified 

(Federal)

$293,664 $81,731 $27,049 $14,156 $5,050 $263,844 $546,707 $1,232,201 603 $2,043 

Adams Unified 

(State and local)

$2,642,978 $735,581 $243,444 $127,405 $45,446 $2,708,746 $1,472,651 $7,976,251 603 $13,228 

Adams Unified 

(Total)

$2,936,642 $817,312 $270,493 $141,561 $50,496 $2,972,590 $2,019,358 $9,208,452 603 $15,271 

School indirect costs are functionally distributed as reported below:

2100 Student Support Services $423,274 2310 Board of Education $0 2580 Administrative 

Technology

$0 

2220 Library Services $189,127 2320 Executive Administration $0 2610 Operation of Building $854,828 

2212 Instruction & Curriculum 

Development Services

$0 2400 School Administration $696,893 2630 Maintenance $463,869 

2213 Instructional Staff Training $10,460 2510 Fiscal Services $0 2700 Student 

Transportation

$334,139 

3100 Food Service $0 

LEA indirect costs are functionally distributed as reported below:

2100 Student Support Services $0 2310 Board of Education $31,071 2580 Administrative 

Technology

$107,267 

2220 Library Services $0 2320 Executive Administration $167,049 2610 Operation of Building $0 

2212 Instruction & Curriculum 

Development Services

$45,140 2400 School Administration $0 2630 Maintenance $0 

2213 Instructional Staff Training $0 2510 Fiscal Services $119,829 2700 Student 

Transportation

$0 

3100 Food Service $1,549,002 
65

APPENDIX D: PER-PUPIL EXPENDITURE EXAMPLE – Only Direct Instruction Expenditures 

Reported at the School Level

The following tables present detailed examples of per-pupil expenditure reporting. Please note that while an SEA or LEA could consider including the 

additional information reflected in this example, it is only required to provide the total per-pupil expenditure, disaggregated by Federal and State/local 

funds. (See figures in the last column of each table highlighted in gray.)

School Report

Expenditure Report by Revenue Source, Year Ending June 30, 2019

School Direct instruction costs

Salaries Benefits 

Purchased 

services

Materials 

and 

supplies

Other 

expenses

School 

indirect

LEA

indirect Total 

Membership 

Count

Per-pupil 

Expenditures

Jefferson - 0001 

(Federal)

$86,786 $0 $9,037 $4,942 $1,036 $0 $0 $101,801 190 $536 

Jefferson - 0001 

(State and local)

$781,072 $0 $81,332 $44,475 $9,325 $0 $0 $916,204 190 $4,822 

Jefferson - 0001 

(Total)

$867,858 $0 $90,369 $49,417 $10,361 $0 $0 $1,018,005 190 $5,358 
66

LEA Report

Adams Unified Expenditure Report by Revenue Source, Year Ending June 30, 2019

School Direct instruction costs

Salaries Benefits 

Purchased 

services

Materials 

and 

supplies

Other 

expenses

School 

indirect

LEA

indirect Total 

Membership 

Count

Per-pupil 

Expenditures

Washington - 0001 $1,023,451 $0 $110,000 $41,021 $35,012 $0 $0 $1,209,484 240 $5,040

Jefferson - 0001 $867,858 $0 $90,369 $49,417 $10,361 $0 $0 $1,018,005 190 $5,358

Lincoln – 0001 $1,045,333 $0 $70,124 $51,123 $5,123 $0 $0 $1,171,703 173 $6,773

Adams Unified 

(Federal)

$293,664 $81,731 $27,049 $14,156 $5,050 $263,844 $546,707 $1,232,201 603 $2,043 

Adams Unified 

(State and local)

$2,642,978 $735,581 $243,444 $127,405 $45,446 $2,708,746 $1,472,651 $7,976,251 603 $13,228 

Adams Unified 

(Total)

$2,936,642 $817,312 $270,493 $141,561 $50,496 $2,972,590 $2,019,358 $9,208,452 603 $15,271 

School indirect costs are functionally distributed as reported below:

2100 Student Support Services $423,274 2310 Board of Education $0 2580 Administrative 

Technology

$0 

2220 Library Services $189,127 2320 Executive Administration $0 2610 Operation of Building $854,828 

2212 Instruction & Curriculum 

Development Services

$0 2400 School Administration $696,893 2630 Maintenance $463,869 

2213 Instructional Staff Training $10,460 2510 Fiscal Services $0 2700 Student 

Transportation

$334,139 

3100 Food Service $0 

LEA indirect costs are functionally distributed as reported below:

1000-

200

Personal Services –

Employee Benefits

$817,312 2310 Board of Education $31,071 2580 Administrative 

Technology

$107,267 

2100 Student Support Services $0 2320 Executive Administration $167,049 2610 Operation of Building $0 

2220 Library Services $0 2400 School Administration $0 2630 Maintenance $0 

2212 Instruction & Curriculum 

Development Services

$45,140 2510 Fiscal Services $119,829 2700 Student 

Transportation

$0 

2213 Instructional Staff Training $0 3100 Food Service $1,549,002