Responses to Public Comments on the 

Department’s Strategic Plan for Fiscal Years 2011-2014

April 2, 2012 

The U.S. Department of Education (Department) provides an update to its Strategic Plan for Fiscal Years 2011-

2014 (“Plan”). The Plan was updated based on public comments we received in February, 2012. This Plan sets 

forth the Department’s strategy for improving outcomes for all students and focuses on key outcome-oriented 

goals aimed at increasing high school graduation, college completion, and educational attainment. 

RESPONSE TO PUBLIC COMMENT: We posted a draft Strategic Plan on February 13, 2012 and invited comments 

from the general public and from key stakeholders. In response to our request, approximately 70 parties 

submitted comments. The Department made a number of changes to the original Plan based on the comments 

we received. We explain these changes and provide our responses to substantive issues below. The comments 

are organized according to the Plan’s six goals. Where comments pertain to more than one goal, we provide our 

responses to comments under the goal that is most relevant. Generally, we do not address technical and other 

minor changes that are outside the scope of the Plan. 

Goal 1: Postsecondary Education, Career and Technical Education, and Adult 

Education 

Comment: Several commenters recommended that the Department increase its focus on supporting students 

once they graduate from high school including by ensuring that financial aid opportunities enable students from 

low-income families and non-traditional students to access and afford postsecondary education, whether in a 1-, 

2-, or 4-year program. The commenters stated that the Department should also focus on raising the bar on the 

quality and availability of student aid and ensure that postsecondary and adult education opportunities are 

accessible and result in people attending college who otherwise would not. Finally, the commenters stated that 

the Department must work to promote diversity throughout postsecondary education. 

Response: The Department is committed to supporting the President’s call for “every American to commit to at 

least one year or more of higher education or career training.” The Plan focuses on closing the opportunity gap 

by improving the affordability of and access to college and workforce training, especially for students from lowincome families, first-generation college students, individuals with disabilities, and other chronically 

underrepresented populations. In particular, the objective of Sub-Goal 1.1 (Access) is to “close the opportunity 

gap by improving the affordability of and access to college and workforce training, especially for low-income 

students, first-generation college students, individuals with disabilities, and other chronically underrepresented 

populations.” Further, in the introduction to Goal 1 (Postsecondary Education, Career and Technical Education, 

and Adult Education), the indicators of success include increasing the percentage of individuals completing and 

filing the Free Application for Federal Student Aid form (FAFSA) among both low-income households and nontraditional students (25 years and above with no college degree). 

Through enforcement of civil rights statutes and increased civil rights data collection, the Department is 

ensuring that all students have equitable access to courses and opportunities that lead to postsecondary 

education. 

Changes: No changes necessary. 
Responses to Public Comments on the Department’s Strategic Plan for Fiscal Years 2011-2014, 4/2/2012, Page 2 

Comment: Several commenters recommended changes to the Plan that would require legislative changes to 

implement. For example, one commenter stated that the Higher Education Act (HEA) should be amended to 

allow students without a high school diploma or General Educational Development (GED) credential to qualify 

for Pell Grants. Other commenters recommended that certain programs or program elements be continued 

when current laws are reauthorized. For example, two commenters recommended that “programs of study” be 

included in the next reauthorization of the Carl D. Perkins Career and Technical Education Act (CTEA). 

Response: We appreciate the recommendations. As noted in several places in the Plan (e.g., Sub-Goal 1.3, 

Completion), reauthorization of several key federal education and workforce statutes (i.e., the Elementary and 

Secondary Education Act (ESEA), the Workforce Investment Act (WIA), the HEA, and the CTEA are needed to 

support the implementation of more rigorous postsecondary and adult education reforms aimed at increasing 

student achievement and success in the workforce and in life. 

Changes: No changes necessary. 

Comment: In reviewing the Plan, we noted that in addition to increasing degree and certificate completion and 

job placement in high-need areas, there should also be a focus on high-skilled areas. 

Response: We have updated Sub-Goal 1.3 (Completion) accordingly. 

Changes: The phrase “and high-skilled” has been added to the title of Sub-Goal 1.3 and now reads as follows: 

Sub-Goal 1.3: Completion. Increase degree and certificate completion and job placement in high-need 

and high-skilled areas (especially STEM), particularly among underrepresented and economically 

disadvantaged populations. 

 

Comment: Several commenters agreed with the Plan’s focus on transforming the teaching profession and the 

ways in which teachers are recruited and prepared. One commenter suggested that the Department continue 

to invest in federal programs that strengthen the teacher pipeline, and recommended expanding the Teacher 

Quality Partnership Grants program. Multiple commenters suggested that the Plan specifically mention the 

TRIO programs as effectively promoting postsecondary success. Two commenters discussed the key role that 

career and technical education (CTE) can play in improving the affordability of, and access to, college and 

workforce training and argued for a greater federal investment in CTE programs. 

Response: We appreciate the commenters’ recommendations. However, the purpose of the Plan is not to focus 

on specific budget requests or on individual programs, of which there are many that would be worthy of 

mention, but rather to outline the Department’s key outcome-oriented goals for fiscal years 2011 through 2014 

and set forth a strategy that focuses on improving outcomes for all students. 

Changes: No changes necessary. 

Comment: One commenter suggested that the Department expand loan forgiveness programs to cover early 

childhood educators. 

Response: The Public Service Loan Forgiveness program allows early childhood educators to have the remaining 

balance of their federal student loans forgiven after 120 payments under a qualifying repayment plan while 

working in a federal, state, or local government entity; a non-profit organization that has been designated as 

tax-exempt by the Internal Revenue Service (IRS) under Section 501(c)(3) of the Internal Revenue Code (IRC); or 

a private, non-profit organization (that is not a labor union or a partisan political organization) that provides 

eligible public services (including early childhood education), while employed. For further information, visit 

http://studentaid.ed.gov/PORTALSWebApp/students/english/PSF.jsp. 

Changes: No changes necessary. 
Responses to Public Comments on the Department’s Strategic Plan for Fiscal Years 2011-2014, 4/2/2012, Page 3 

Comment: Two commenters stated that CTE data should be better integrated into statewide longitudinal data 

systems (SLDSs) so that states can track students’ progress from secondary to postsecondary education to the 

workforce. The commenters also stated that data systems must take into account the varied ways that students 

access postsecondary education and emphasized the need to develop accurate connections across institutions 

and the workplace in order to ensure programs receive feedback on their students’ performance. One 

commenter recommended that data on adult students be better integrated into SLDSs. Another recommended 

that the Department encourage states to share data from P-12 longitudinal data systems with personnel 

preparation programs. Another commenter suggested that the Department provide support to individuals and 

organizations seeking to access data on student enrollment in postsecondary programs, including students 

enrolled in out-of-state programs. The commenter stated that currently these data are available only on a costper-record basis. 

Response: We agree that CTE data and data on adult students should be better integrated into SLDSs. As 

reflected in Goal 5 (Continuous Improvement of the U.S. Education System), the Department is committed to 

“supporting robust and comprehensive data systems” that provide high-quality data from early learning 

programs through postsecondary institutions and the workforce. As an example of how we are acting on this 

commitment, the Department included CTE data elements that states are required to report to the Department 

in the second version of the Common Education Data Standards (CEDS v2.0). We believe this will make it easier 

for states to work cooperatively to ensure that all areas of education, including CTE, are completely integrated 

into SLDSs, the development of which the Department has supported over the past six years. 

Further, the Department recently promulgated regulations for the Family Educational Rights and Privacy Act 

(FERPA) to ensure that SLDSs are implemented in a way that protects the privacy of education records while 

allowing for the effective use of data. The need for clarity surrounding privacy protections and data security 

continues to grow as SLDSs are built and more education records are digitized and shared electronically. The 

amendments to the FERPA regulations also reduce barriers that have inhibited the effective use of SLDSs as 

envisioned in the America Creating Opportunities to Meaningfully Promote Excellence in Technology, Education, 

and Science Act (the America COMPETES Act) and the American Recovery and Reinvestment Act of 2009 (ARRA) 

(visit http://www.gpo.gov/fdsys/pkg/FR-2011-12-02/pdf/2011-30683.pdf for more information). 

Changes: No changes necessary. 

Comment: Several commenters suggested that the Plan provide further clarity on the role of part-time students 

and certificate programs in improving postsecondary attainment. One commenter stated that part-time 

students would not be able to complete a 2-year degree in three years or a 4-year degree in six years and, 

therefore, would not be counted positively in postsecondary attainment rates. Another commenter requested 

that the Plan include a focus on certificate programs that take less than one year but result in nationally 

recognized industry certification or state or federal licensure. 

Response: We agree that both full- and part-time students seeking postsecondary certificates or degrees must 

be a significant part of the Department’s strategy to increase postsecondary attainment; their inclusion aligns 

with the President’s call for every American to commit to at least one year or more of higher education or career 

training. While certificates are not counted in the educational attainment rate that is commonly used for 

international comparisons and, thus, are not mentioned in reference to that metric, certificates including those 

that take less than one year and result in nationally recognized industry certification or state or federal licensure 

are specifically mentioned throughout the Plan. For example, in the introduction to Goal 1 (Postsecondary 

Education, Career and Technical Education, and Adult Education), the Plan calls for increasing “the number [of 

students] who complete programs of study with a degree or certificate.” The Plan acknowledges in Sub-Goal 1.2 

(Quality) that an “external risk factor” for meeting this Sub-Goal is that current graduation rate formulas do not 

account for part-time students or transfer students. The Department, in response to recommendations from 
Responses to Public Comments on the Department’s Strategic Plan for Fiscal Years 2011-2014, 4/2/2012, Page 4 

the Committee on Measures of Student Success, an external advisory committee authorized under the Higher 

Education Act, is considering how the graduation rate might be improved to provide data on part-time students. 

Changes: No changes necessary. 

Comment: One commenter recommended that the Plan include a statement that all teachers should be trained 

and supported to teach all students, including high-need students. 

Response: We agree that teachers need to be prepared and supported to teach students who come from a 

variety of backgrounds and who have different learning styles and challenges. 

To make this clear, we have added a statement to this effect in the introduction to Sub-Goal 1.2 (Quality).

Changes: The phrase, “including students with high needs” has been added to the second paragraph of the 

introduction to Sub-Goal 1.2 and reads as follows: 

We will continue to support teacher preparation initiatives that will further the transformation already 

underway in how we recruit and prepare teachers in this country to teach all students, including 

students with high needs.

Comment: One commenter supported the Plan’s focus on strengthening teacher preparation programs and 

suggested that the Department provide incentives for states to collaborate with one another to identify 

indicators and assessment procedures for recognizing high-quality teacher preparation programs. Another 

commenter strongly encouraged the Department to enforce the current statutory requirement for states to 

report their low-performing teacher preparation programs and for the Department to articulate a process that 

states must follow in determining which programs are low performing. One commenter recommended that 

Title IV funding under the HEA be available only to teacher preparation programs that are in good standing in 

their state. On the other hand, one commenter disagreed with directing Title IV HEA funding only to topperforming preparation programs stating that this action would curtail efforts to improve the entire preparation 

system and would not help meet the President’s goal of increasing college graduation rates. The commenter 

stated that the Department’s priority should be to identify low-performing educator preparation programs and 

improve them, if possible, or close them if they do not improve. 

Response: As stated in Sub-Goal 1.2 (Quality), the Department is committed to “improving state accountability 

by implementing effective performance-based funding systems in current programs and through planned 

reauthorizations.” And, Sub-Goal 1.2 lists the following as an example of an action step the Department will 

take to improve the quality of postsecondary education: “Provide incentives for institutions and states to 

publish and make transparent their efforts to increase the quality of their educational programs.” Further, the 

Department is working through a negotiated rulemaking process to establish indicators of teacher preparation 

program quality against which states would measure program performance and that they would then use to 

identify high-and low-quality programs. 

Changes: No changes necessary. 

Comment: One commenter encouraged the Department to focus support on the lowest-level adult learners –

those who read, write, and do basic math at a fifth grade level or below. 

Response: The Department is concerned about all adults in the U.S. who are functioning below basic levels of 

literacy and will continue to devote resources to assist these individuals to improve their literacy and access to 

higher levels of education and employment. The Department agrees that including a reference to adults who 

function at the lowest literacy levels is aligned with the mission of the program funded under the Adult 

Education and Family Literacy Act (AEFLA); therefore, we have added language to the Plan to make this point. 
Responses to Public Comments on the Department’s Strategic Plan for Fiscal Years 2011-2014, 4/2/2012, Page 5 

Changes: The following parenthetical has been added to the second “Actions/Means” in Sub-Goal 1.3 

(Completion): “including those with the lowest reading, writing, and math skills, and lowest levels of English 

literacy.” The statement now reads as follows: 

Fund programs and services that meet the educational needs of adult learners (including those with the 

lowest reading, writing, and math skills, and lowest levels of English literacy), transitioning workers, and 

career changers, including immigrant professionals and previously incarcerated individuals; 

Comment: Two commenters made recommendations related to increasing the Plan’s focus on improving and 

promoting excellence in science, technology, engineering, and mathematics (STEM) education. One commenter 

suggested that the Department provide incentives for states and teacher preparation programs to create 

content-based, interdisciplinary teacher preparation programs with a focus on STEM. 

Response: We agree with the commenters that improving the quality of STEM education is crucial to furthering 

the economy and spurring innovation. That is why we have already worked with our colleagues across the 

federal government to establish a goal of producing 1 million well-prepared graduates with STEM degrees within 

the next decade. We believe it is important for the Plan to include this goal and have updated Sub-Goal 1.3 

(Completion), accordingly. We have also added this goal to the “Agency 2012-13 Priority Goals.” As noted in the 

Plan, priority goals will be a particular focus over the next two years and our progress in meeting them will be a 

measure of the success of the Department’s cradle-to-career education strategy. (Further information on the 

priority goals can be found on performance.gov). 

Changes: We have made the following changes: 

The following has been added to Sub-Goal 1.3 as an example of an action the Department will take: 

Collaborate with other federal agencies to improve the quality of STEM education at all levels to help 

increase the number of well-prepared graduates with STEM degrees by one-third over the next 10 years, 

resulting in an additional 1 million graduates with degrees in STEM subjects. 

The table listing the Agency FY 2012-13 Priority Goals in the section of the Plan on “Linking Department 

Performance to National Outcomes” has been updated to include the following:

Improve the quality of science, technology, engineering, and math (STEM) education 

Over the next 10 years, increase the number of well-prepared graduates with STEM degrees by onethird, resulting in an additional 1 million graduates with degrees in STEM subjects. 

Goal 2: Elementary and Secondary 

Comment: One commenter requested that the Plan promote world languages as an important part of a high 

school curriculum. 

Response: The Department strongly believes in the importance of ensuring that all students are prepared for 

college and a career. As part of that goal, it is important that students have the skills necessary to succeed in the 

21st century, which can include having students acquire the language skills necessary to interact with individuals 

from foreign countries. That is why in A Blueprint for Reform (ESEA Blueprint), our plan for reauthorizing the 

ESEA, we proposed to create “Effective Teaching and Learning for a Well-Rounded Education”—a program that 

would provide competitive funds to ensure students have access to a complete education that includes foreign 

language and other subjects such as art, history, and financial literacy. 

We agree that language regarding the importance of a well-rounded education should be included in the Plan 

and have modified the Plan accordingly. 
Responses to Public Comments on the Department’s Strategic Plan for Fiscal Years 2011-2014, 4/2/2012, Page 6 

Changes: The following language has been added to the second paragraph of the introduction to Goal 2 

(Elementary and Secondary):

Ensuring that our students have the critical-thinking skills and other tools to be effective in the 21st 

century economy means improving teaching and learning in all content areas—from literacy to science, 

technology, engineering, and mathematics to history, civics and government, geography, foreign 

languages, the arts, economics and financial literacy, environmental education, health education, and 

other subjects. 

Comment: One commenter suggested that the Department change references to “college and career” in the 

Plan to “college and/or career.”

Response: The Plan, specifically Sub-Goal 2.1 (Standards and Assessments), focuses on college- and careerready standards and assessments because the Department believes that all students should graduate from high 

school with the knowledge and skills they need to be prepared for both college and a career. Nearly 8 in 10 

future job openings in the next decade in the U.S. will require some workforce training or postsecondary 

education. Additionally, research shows that whether preparing for college or career, high school graduates 

need to have the foundational skills to enable them to learn additional academic and job-specific skills, both at 

the entry level and throughout their careers. Therefore, we believe the Plan’s references to “college and 

career” are appropriate. 

Changes: No changes necessary. 

Comment: One commenter suggested that the Plan provide greater clarity on the appropriateness of using 

student achievement test scores as the primary metric in evaluating teachers’ effectiveness.

Response: At various points in the Plan, we state that the Department intends to help improve the quality of 

teaching and learning in America’s schools by supporting efforts to increase the number of districts with 

comprehensive teacher and principal evaluation and support systems based on student growth in significant 

part, as well as other measures. For example, in the introduction to Sub-Goal 2.2 (Great Teachers and Leaders), 

we state that “The Department will help strengthen the profession by supporting efforts that focus on 

actionable feedback, support, and incentives at every stage of a career, based on fair evaluation systems that 

look at multiple measures, including student growth.”

Changes: No changes necessary. 

Comment: One commenter recommended that the Department invest in the development and implementation 

of, and encourage states to develop and implement, valid and reliable performance assessments that measure 

teacher candidates' readiness to teach, including their classroom management skills, ability to work with diverse 

learners, and demonstrated ability to improve student achievement. 

Response: The Department supports state-led efforts to implement performance-based teacher licensure and 

certification requirements. As stated in the examples of the actions the Department will take under Sub-Goal 

2.2 (Great Teachers and Leaders), the Department is committed to supporting “high-quality preparation 

programs that prepare educators to teach and lead in high-need schools and in shortage areas, such as special 

education and teaching of English Learners, and require these programs to track and report on the effectiveness 

of their graduates.” 

Changes: No changes necessary. 

Comment: One commenter recommended that the Plan better reflect the Department’s commitment to 

encouraging and fostering public/private partnerships through grant competitions and policy priorities. 
Responses to Public Comments on the Department’s Strategic Plan for Fiscal Years 2011-2014, 4/2/2012, Page 7 

Response: The Department agrees that partnerships between public and private entities are critical in 

supporting innovation and continuous improvement of the nation’s education system, and the Plan encourages 

such partnerships. For example, a specific example of an action the Department will take to achieve Sub-Goal 

2.3 (School Climate and Community) is to “Provide incentives for programs to establish partnerships with 

families and parent organizations, faith- and community-based organizations, institutions of higher education, or 

other federal, state, and local entities.” In addition, Goal 5 (Continuous Improvement of the U.S. Education 

System) focuses on collaboration among stakeholders and across sectors. 

Changes: No changes necessary. 

Comment: One commenter recommended including family engagement as a Sub-Goal in support of Goal 2 

(Elementary and Secondary). Another commenter recommended that the Plan reflect the important role of 

parent engagement in turning around severely underperforming and struggling schools. 

Response: The Department agrees that engaging families in education is critical to improving outcomes for all 

students, especially in relation to turning around persistently low-achieving schools, and believes that we have 

made this clear in Goal 2. For example, the introduction to Sub-Goal 2.3 (School Climate and Community) 

acknowledges that “Preparing students for success is made easier...with families who are actively engaged in 

their children’s academic life.” Further, Sub-Goal 2.3 outlines the Department’s commitment to “Support 

community-wide approaches and increase the capacity of community-based and other organizations to increase 

success for children from the cradle through college to career.” The Plan also describes the need for family 

involvement and the Department’s commitment to encouraging “opportunities for families to engage actively 

and meaningfully in their children’s education” as an action step in Sub-Goal 2.3. Finally, Sub-Goal 2.4 

(Struggling Schools) emphasizes family and community engagement as an effective turnaround strategy. 

Changes: No changes necessary. 

Comment: One commenter suggested that the Department add a new goal that focuses on expanding learning 

opportunities and helping communities provide better, more comprehensive services to students and families 

through partnerships with providers. Multiple commenters suggested that the Department specifically mention 

the 21st Century Community Learning Centers (CCLC) program as effectively promoting college- and careerreadiness. 

Response: Sub-Goal 2.3 (School Climate and Community) addresses the Department’s support of communitywide approaches to providing comprehensive educational supports, including expanded learning time. The 

Department strongly supports expanding the school day and year, and the Plan acknowledges that communitybased organizations are valuable resources in this effort. For example, the Plan includes the following as an 

indicator of success for Goal 2 (Elementary and Secondary): “Increase in the percentage of schools 

implementing initiatives that increase time for learning during or outside the school day.” In addition, the Plan 

provides the following as specific examples of actions the Department will take: “Fund communities ...to 

comprehensively redesign and expand the school day or year to increase time for academics and enrichment 

activities...”(Sub-Goal 2.3) and “Fund and encourage states and districts to increase their capacity, including 

through partnerships with local employers and industry groups, faith-based and community-based 

organizations, postsecondary institutions, and other state and local entities, to turn around their persistently 

lowest-achieving schools” (Sub-Goal 2.4, Struggling Schools).

With regard to the comments on the 21st CCLC program, the purpose of the Plan is not to focus on individual 

programs, of which there are many that would be worthy of mention, but rather to describe the Department’s 

overall strategy of helping to improve student achievement and prepare our students to compete in the global 

economy. 

Changes: No changes necessary. 
Responses to Public Comments on the Department’s Strategic Plan for Fiscal Years 2011-2014, 4/2/2012, Page 8 

Comment: Two commenters agreed with the Plan’s focus on creating positive conditions for learning, including 

by supporting the provision of positive behavioral interventions and supports, but suggested that the Plan 

provide more emphasis on the important role that specialized instructional support personnel who provide 

emotional, social, behavioral, and mental health supports can have in facilitating systems-level change, including 

multi-tiered systems of support and school climate change. 

Response: The Department agrees that specialized instructional support personnel have a critical role to play in 

facilitating systems-level change, including by improving school climate and implementing multi-tiered systems 

of support and we have added language to make this clear. 

In addition, we note that Sub-Goal 2.3 (School Climate and Community) references positive behavioral supports 

as an example of a multi-tiered system of support that schools can use to improve conditions for learning 

Changes: The following language has been added to the first sentence in the third paragraph in Sub-Goal 2.3: 

“...that include, as appropriate, the services provided by specialized instructional support personnel.” The 

sentence now reads as follows: 

In high-poverty neighborhoods, the Department will support community-wide approaches that address 

interrelated barriers to learning and provide comprehensive supports for students and their families 

that include, as appropriate, the services provided by specialized instructional support personnel. 

Comment: One commenter stated that a more holistic view of student achievement should include other 

essential components of a student’s life, such as economic status, emotional well-being, and cultural/linguistic 

background. The commenter recommended that all the goals in the Plan be structured around these 

dimensions. 

Response: We chose to structure the Plan around six strategic goals that could be used to guide the day-to-day 

work of the Department’s staff in order to accomplish the President’s goal of the U.S. once again having the 

world’s highest proportion of college graduates in the world by 2020. We acknowledge that many factors, such 

as those listed by the commenter, can affect a student’s achievement and that too many students face barriers 

to learning. However, we also know that students can succeed despite being born into the most difficult of 

circumstances. That is why the Plan outlines in Sub-Goal 2.3 (School Climate and Community) how the 

Department will support community-wide approaches that address inter-related barriers to learning and 

provide comprehensive supports for students and their families – building a continuum of academic programs 

and family and community supports from cradle through college to career, with strong schools at the center. 

Changes: No changes necessary. 

Comment: One commenter requested that the Plan provide an additional focus on experiential learning 

activities outside of the school day. 

Response: The Department agrees that it is important for the community to engage students through hands-on, 

experiential learning opportunities. As stated in our ESEA Blueprint, the Department is committed to improving 

student achievement by supporting “in school and out of school strategies that provide students and, where 

appropriate, teachers and family members, with additional time and supports to succeed.” The Plan has been

updated to reference “experiential learning.”

Changes: The following phrase has been added to the first action under Sub-Goal 2.3 (School Climate and 

Community): “which may include opportunities for experiential learning, as well as”. The action now reads as 

follows: 

Fund communities to provide comprehensive supports through full-service school models and to 

comprehensively redesign and expand the school day or year to increase time for academics and 
Responses to Public Comments on the Department’s Strategic Plan for Fiscal Years 2011-2014, 4/2/2012, Page 9 

enrichment activities, which may include opportunities for experiential learning, as well as time for 

teachers to collaborate and to develop and enhance their skills. 

Comment: One commenter suggested that the Department refrain from establishing mandates that would 

require state educational agencies (SEAs) or local educational agencies (LEAs) to redirect resources, instead of 

allowing these decisions to be made at the local level. 

Response: The Department agrees that SEAs and LEAs are generally best positioned to make decisions on how 

to improve educational outcomes for students. By focusing on key outcome measures, the Plan emphasizes the 

goals, rather than the means, that SEAs and LEAs use to achieve those goals. 

Changes: No changes necessary. 

Comment: One commenter recommended that the Plan acknowledge the impact that family literacy and 

parental engagement have in assisting both parents and their children in becoming literate, succeeding in 

school, and gaining employment. 

Response: The Department agrees and is committed to promoting family literacy and parental engagement. As 

noted in the Secretary’s Message, we intend to “provide teachers, administrators, and families with information 

on how young children are learning and how early learning programs can be strengthened, especially through 

family literacy programs.” The Secretary also calls for “an ‘all-hands-on-deck’ approach in communities across 

America—involving local leaders, educators, families, and the students themselves—to build the best-educated 

workforce and citizenry in the world.”

Changes: No changes necessary. 

 

Goal 3: Early Learning 

Comment: Several commenters recommended ways to increase funding to improve the quality of early learning 

programs and services. For example, one commenter suggested that the Plan encourage states, local agencies, 

and schools to use funds under Title I of the ESEA to serve children younger than kindergarten. Another 

commenter recommended changes to the Department’s 2013 budget request. One commenter recommended 

that discretionary grant competitions be designed to support early learning programs and services. 

Response: We appreciate the commenters’ recommendations. However, the purpose of the Plan is not to focus 

on specific budgets or individual programs, of which there are many that would be worthy of mention, but 

rather to outline the Department’s key outcome-oriented goals for FY 2011 through 2014 and set forth a 

strategy that focuses on improving outcomes for all groups of students. We note, however, with regard to the 

suggestion that the Department encourage states, local agencies, and schools to use Title I funds to serve young 

children, that we will soon be releasing non-regulatory guidance for state and local education agencies on the 

use of Title I funds to serve young children. The non-regulatory guidance document will be available on the 

Department’s Web site in the near future.

Changes: No changes necessary. 

Comment: One commenter suggested that the Plan include additional citations that support the need for highquality early learning experiences for all children. 

Response: We agree and have included additional citations that readers of the Plan may find helpful. We also 

believe it is important to note the important role of brain development in early childhood and have added a 

statement to that effect in the introduction to Goal 3, along with corresponding references: 
Responses to Public Comments on the Department’s Strategic Plan for Fiscal Years 2011-2014, 4/2/2012, Page 10

Changes: We have made the following changes to Goal 3 (Early Learning): 

We have added the following phrase (along with corresponding references) to the first paragraph of the 

introduction to Goal 3: “The years from birth through age eight are the most critical for brain development, and 

significant evidence from research and evaluation demonstrate that...” The first paragraph of the introduction 

to Goal 3 now reads as follows: 

The years from birth through age eight are the most critical for brain development, and significant 

evidence from research and evaluation demonstrate that participation in high-quality early learning 

programs will lead to both short- and long-term positive outcomes for all children, especially those with 

high needs, including increased school readiness and success and improved high school graduation and 

college attendance and completion. 

We have added the following reference citations to the introduction to Goal 3: 

Bowman, B. T., Donovan, M. S., & Burns, S. (Eds.). Eager to Learn: Educating Our Preschoolers. 

Washington, DC: National Academy Press, 2001. 

Shonkoff, J. P., & Phillips, D. A. (Eds.). From Neurons to Neighborhoods: The Science of Early Childhood 

Development. Washington, DC: National Academy Press, 2001. 

Pianta, R., Barnett, S., Burchinal, M., & Thornberg, K. The Effects of Preschool Education: What We 

Know, How Public Policy Is or Is Not Aligned With the Evidence Base, and What We Need to Know. 

Psychological Science in the Public Interest, 10, 49-88, 2009. 

Comment: One commenter, who was pleased that the Department included a goal focused on early learning, 

was concerned that the Plan did not emphasize the importance of parenting, parent education programs, and 

parent involvement in their child’s education. 

Response: We agree that parent education and family engagement in their child’s education is critical. As noted 

in the introduction to Sub-Goal 3.3 (Accountability), we want to make sure that information is provided to 

families and the public about the quality of early learning programs so that families can make informed 

decisions. That said, we appreciate the commenter’s concern that the Plan does not emphasize the importance 

of parenting, parent education programs, and parent involvement in their child’s education; therefore, we have 

added language to Goal 3 (Early Learning) to make that point. 

Changes: The following sentence has been added to the second paragraph of the introduction to Goal 3 (Early 

Learning):

And, to achieve successful outcomes for young children it is critical to gain the support of families and 

ensure that family engagement and education activities are of high quality and integrated into early 

learning programs 

Comment: One commenter recommended that the Department award Race to the Top – Early Learning 

Challenge (RTT-ELC) grants to states that propose a high-quality plan to implement effective interventions for all 

students, including children with disabilities and English Learners, that are delivered, monitored, and evaluated 

by qualified professionals. 

Response: We appreciate the commenter’s recommendation and strongly agree that early learning programs 

should be staffed by qualified professionals and available to all children, including children with disabilities and 

English Learners. Our commitment to ensuring that availability is described in the introduction to Goal 3 (Early 

Learning), where we state that, “Early learning programs must meet the needs of all children, including children 

with disabilities and English Learners.” We believe that the Plan would be strengthened by acknowledging the 
Responses to Public Comments on the Department’s Strategic Plan for Fiscal Years 2011-2014, 4/2/2012, Page 11

importance of high-quality, coordinated early learning systems, consistent with the RTT-ELC program. 

Accordingly, we have made the appropriate changes in the introduction to Goal 3. 

Changes: We have made the following changes to Goal 3: 

The following statement has been added to the fourth paragraph of the introduction to Goal 3: 

A high-quality, coordinated early learning system includes program standards, comprehensive 

assessment systems, workforce and professional development, family and community engagement, 

health promotion, and data systems. 

We have added the phrase, “that increase access to high-quality programs” and made corresponding changes to 

the first sentence in the sixth paragraph in the introduction to Goal 3. The paragraph now reads as follows: 

To enhance the quality of these programs and services and improve outcomes for children from birth 

through 3rd grade, including children with disabilities and those who are English Learners, the 

Department will promote initiatives that increase access to high-quality programs, improve the early 

learning workforce, build the capacity of states and programs to develop and implement comprehensive 

early learning assessment systems, and ensure program effectiveness and accountability. 

Comment: One commenter recommended that the Plan describe the connections between early learning and 

the K-12 system. 

Response: The connections between early learning and K-12 are described in Goal 3 (Early Learning). 

Specifically, the introduction to Goal 3 states that “Only by coordinating the patchwork of early learning 

programs and services, and better integrating them with the elementary and secondary education system, can 

an integrated early learning system be built that improves health, social-emotional, and cognitive outcomes for 

children from birth through 3rd grade.” 

Changes: No changes necessary. 

Comment: One commenter applauded the Department for increasing our focus on early learning, but expressed 

concern that the Plan does not emphasize full-day kindergarten. The commenter stated that full-day 

kindergarten is a vital link that ties together equity in educational opportunities, early learning, and elementary 

and secondary education and provided a number of recommendations to amend the Plan to include a focus on 

full-day kindergarten. 

Response: One of the ways the Plan proposes to achieve the overall goal of improving the health, socialemotional, and cognitive outcomes for all children is to “increase access to high-quality early learning programs 

and comprehensive services, especially for children with high needs” (Sub-Goal 3.1, Access). Given the variety of 

early learning programs available, the Plan does not emphasize one type of program (e.g., full-day kindergarten) 

over another; rather, the Plan focuses on improving the quality of all early learning programs and also, on 

increasing the number of children with high needs from birth through kindergarten entry who are in high-quality 

early learning programs. 

Changes: No changes necessary. 

Comment: One commenter urged the Department to continue to collaborate closely with the U.S. Department 

of Health and Human Services (HHS) on creating high-quality early learning experiences. 

Response: The Department is committed to continuing to work closely with HHS to improve the quality of early 

learning programs and services. Coordination and collaboration with HHS are critical to helping states build an 

integrated early learning system from the “patchwork” of early learning programs and services that currently 
Responses to Public Comments on the Department’s Strategic Plan for Fiscal Years 2011-2014, 4/2/2012, Page 12

exist. We note that the Plan already includes a specific example of an action the Department will take with HHS 

to help improve the quality and effectiveness of the early learning workforce. Specifically, the Plan includes, 

under Sub-Goal 3.2 (Workforce), “With the Department of Health and Human Services (HHS), develop a 

coordinated, evidence-based plan for current and future technical assistance and professional development 

investments.” This effort will build on the work that the Department and HHS are already engaged in to jointly 

administer and support the nine winning RTT-ELC states as they improve their systems of early learning. 

Changes: No changes necessary. 

Comment: One commenter recommended encouraging states, local agencies, and schools to provide 

professional development opportunities that bring together staff from schools and community-based early 

learning programs, as well as teachers in kindergarten and first grade. 

Response: We agree. Under Sub-Goal 3.2 (Workforce), we note that the Department can play an important role 

in encouraging states and school districts to focus components of K-3 professional development on “joint 

professional development opportunities for K-3 and preschool teachers, including professionals from 

community-based early learning programs.” The Department will soon be releasing non-regulatory guidance for 

state and local educational agencies on the use of Title I funds to serve preschool children. In the nonregulatory guidance we will clarify how Title I funds may be used to provide joint professional development. 

This non-regulatory guidance will be available on the Department’s Web site.

Changes: No changes necessary. 

Comment: One commenter recommended that the Plan clearly state the need for specialized early childhood 

professional preparation and certification for teachers of children birth through age eight. 

Response: Teacher certification is the responsibility of state and local governments. However, the Department 

recognizes the need for specialized professional preparation for teachers of children birth through age eight. In 

Sub-Goal 3.2 (Workforce), we state that “The federal government can address these workforce challenges by 

supporting more robust teacher preparation and professional development efforts and promoting common, 

statewide workforce knowledge and competency frameworks designed to support children’s learning and 

development and improve outcomes.” We also note that the RTT-ELC grant program supports states in 

developing a common, statewide progression of credentials and degrees aligned with the state’s workforce 

knowledge and competency framework. 

Changes: No changes necessary. 

Comment: One commenter recommended adding an indicator measuring the number of states that use the 

definitions and codes in the Common Data Standards, which include a common definition of “kindergarten.” 

This commenter also recommended adding an action to Sub-Goal 3.3 (Assessment and Accountability) to 

promote the use of Common Data Standards. 

Response: Sub-Goal 5.1 (Data Systems) is focused on assisting states in developing longitudinal data systems 

capable of sharing key data elements across the P-20 education continuum. Specifically, Sub-Goal 5.1 includes 

the following example of an action the Department will take “Collaborate with states, districts, and other 

education data stakeholders to develop, for voluntary adoption, common data standards that will include 

common data definitions and technical specifications.” Further, once states have the infrastructure in place to 

adopt the Common Data Standards, the Department will work to develop appropriate metrics related to states’ 

adoption. 

Changes: No changes necessary. 
Responses to Public Comments on the Department’s Strategic Plan for Fiscal Years 2011-2014, 4/2/2012, Page 13

Goal 4: Equity 

Comment: Several commenters requested that the Department address “identity-based bullying and 

harassment” and explicitly mentioned the need to address the bullying and harassment of lesbian, gay, bisexual, 

transgender, and questioning (LGBTQ) youth. Commenters also asked that sexual orientation and gender 

identity be mentioned in the Plan. One commenter asked that the Department harmonize its approach to 

bullying and harassment with the need to reduce unnecessary exclusionary discipline. Another comment asked 

that priorities of the Office of Safe and Healthy Students be highlighted. 

Response: The Department is committed to addressing the national issue related to the bullying and 

harassment of individuals, including those who are, or are perceived as, LGBTQ. Specifically, as mentioned in 

the introduction to Goal 4 (Equity), the Department is committed to ensuring that “all students are free from 

bullying or harassment.” The Department recently issued a policy letter on the recognition of student-led noncurricular clubs (which may include gay-straight alliances) under the Equal Access Act, and hosted and 

participated in events highlighting the needs of LGBTQ youth. The Department has also issued guidance to 

explain that gender-based harassment and sex-stereotyping are forms of sex discrimination that are covered 

under Title IX of the Education Amendments of 1972, in addition to other forms of sex discrimination. The 

Department is committed to promoting effective educational opportunities for all students, including those who 

are LGBTQ. Therefore, we have changed the title to Goal 4 and the list of enumerated characteristics that is 

included in the introduction to Goal 4 to reference "sexual orientation" and "gender identity." Further, as 

“gender-based harassment and sex-stereotyping” are forms of sex discrimination that are covered by civil rights 

laws, we have updated the Plan accordingly. 

With regard to the comment requesting that priorities of the Office of Safe and Healthy Students be highlighted, 

the Department notes that Sub-Goal 2.3 (School Climate and Community) focuses on increasing the success, 

safety, and health of students and reflects many of the priorities of the Department’s Office of Safe and Healthy 

Students. The Department agrees that promoting safe and healthy learning environments for students should 

be further highlighted in the Plan, and that this is a part of the goal of increasing educational opportunities for 

all students. In response, we have added a reference to safe and healthy learning environments in the title of 

and introduction to Goal 4. 

Changes: Consistent with the response to comments above, we have made the following changes in Goal 4: 

The title of Goal 4, (which is listed several times in the document and similarly updated) reads as follows: 

GOAL 4: EQUITY. Ensure and promote effective educational opportunities and safe and healthy learning 

environments for all students regardless of race, ethnicity, national origin, age, sex, sexual orientation, 

gender identity, disability, language, and socioeconomic status. 

The third sentence in the first paragraph of the introduction to Goal 4 has been revised to read as follows: 

Yet, far too often, the quality of a child’s education and learning environment, and opportunities to 

succeed are determined by his or her race, ethnicity, national origin, age, sex, sexual orientation, gender 

identity, disability, language, socioeconomic status, or ZIP code. 

The second sentence in the first paragraph of Sub-Goal 4.2 (Civil Rights Enforcement) has been revised to read as 

follows: 

The Office for Civil Rights (OCR) is charged with the vitally important task of ensuring that recipients of 

federal funds comply with the federal civil rights laws and that beneficiaries, including students 

participating in education programs offered by federally funded-funded schools and colleges, are free 

from discrimination on the basis of race, color, national origin, sex (including gender-based harassment 

and sex-stereotyping), disability, or age. 
Responses to Public Comments on the Department’s Strategic Plan for Fiscal Years 2011-2014, 4/2/2012, Page 14

Comment: One commenter asked that the Department take a number of steps to advance gender equity and 

access of girls and women to schools, colleges, workforce training programs, and STEM careers. The commenter 

also asked that the Department release guidance related to accommodations for pregnant and parenting 

students and single-sex programs. 

Response: As stated in the introduction to Goal 4 (Equity), the Department is committed to working to change 

the current state of affairs where, “far too often, the quality of a child’s education and the opportunities they 

have to succeed are determined by his or her... sex...” The Department has worked to clarify the requirements 

applicable to educational programs receiving federal financial assistance regarding the prevention and 

redressing of sexual harassment and sexual violence. We have also worked to encourage underrepresented 

groups such as women to pursue STEM careers, for example by including such a focus in the Department’s 

Supplemental Priorities, which are used in the Department’s competitive grant programs (see 

http://www2.ed.gov/legislation/FedRegister/other/2010-4/121510b.html). The Department is considering what 

additional guidance would be helpful to ensure that equal educational opportunities are provided to all 

students, regardless of gender. 

We agree that the Plan would be strengthened by adding information about the number of women earning 

degrees in STEM careers, as well as a specific example of an action the Department will take to ensure that 

equal educational opportunities are provided to all students. 

Changes: We have made the following changes in Goal 4: 

The following sentence and accompanying reference have been added to the list in the first paragraph in the 

introduction to Goal 4: 

In 2008-2009, women earned less than one in five bachelor's degrees in engineering, and less than one 

in eight bachelor's degrees in computer science. (U.S. Department of Education, NCES, 2008–09 IPEDS.) 

The following has been added to Sub-Goal 4.1 (Continue to Increase the Infusion of Equity throughout the 

Department’s Programs and Activities) as an example of the actions the Department will take: 

Monitor and ensure equity and access of girls and women to critical programs and career pathways 

through the Civil Rights Data Collection and other data disaggregated by sex that is already required by 

other specific education- and workforce-related programs. 

Comment: Several commenters recommended that the Plan include specific strategies or programs and 

evaluate the efficacy of such strategies and programs on meeting the needs of all students (including such 

populations of students as English Learners, minorities and students from low-income families, and students 

with disabilities). For example, commenters suggested that the Plan examine the impact of high-stakes testing; 

high-quality assessments for English Learners; early warning systems that track participation and outcomes for 

at-risk youth; greater guidance resources; magnet schools; improving graduation rates; expanded curricula; 

dropout recovery and wraparound systems; teacher training; growth models and evaluation systems sensitive to 

progress of all learners; expanded focus on dimensions of student development; the services provided by 

mental health professionals and specialized instructional support personnel; effective models for turning around 

low-performing schools; and alignment of the Plan's student subgroups in the Equity section with student 

achievement subgroup categories. Further, commenters asked for greater IDEA funding and alignment of the 

IDEA with the ESEA. 

Response: We appreciate the commenters’ suggestions and note that while some of these strategies and 

programs are included in the Plan as illustrative of the Department’s work and plans moving forward, the 

purpose of the Plan is not to focus on specific budgets or individual programs, of which there are many that 

would be worthy of mention in these areas, but rather to outline the Department’s key outcome-oriented goals 

for fiscal years 2011 through 2014 and set forth a strategy that focuses on improving outcomes for all students. 

As stated in the section on Agency FY 2012-13 Priority Goals, “the effective implementation of the Department’s 
Responses to Public Comments on the Department’s Strategic Plan for Fiscal Years 2011-2014, 4/2/2012, Page 15

priority and strategic goals will depend, in part, on the effective use of high-quality and timely data, including 

evaluations and performance measures, throughout the lifecycle of policies and programs.” The Department is 

committed to expanding evidence-based approaches and supporting effective strategies that will improve 

learning outcomes for all students across the spectrum of early childhood, K-12, and postsecondary education 

(including adult education). Such strategies include fostering a culture of innovation (e.g., through the 

groundbreaking Investing in Innovation (i3) program), identifying effective practices (e.g., through its 

independent research arm, the Institute of Education Sciences), and creating incentives for the scaling up 

effective strategies (e.g., through grants to expand charter and magnet schools; improvements in suspension 

and expulsion practices; development of next-generation assessments and assessment strategies). The 

strategies also include a focus on identifying, evaluating, and scaling up practices aimed at turning around 

persistently low-achieving schools and dramatically increasing outcomes in high schools, ensuring that all 

students graduate with the skills and abilities necessary for success in college and career. All of these strategies, 

including those designed to ensure equitable access to effective teachers and other school personnel and 

comparable resources, must be used together to eliminate the achievement gap. 

Through enforcement of civil rights laws, the Department ensures that all students in a community (including 

English Learners, students with disabilities, minority students, and students from low-income families) have 

equitable access to all educational resources – including challenging coursework, and effective teachers and 

other personnel – and do not experience bullying, harassment, or other forms of discrimination that hinder their 

achievement. We believe that the Plan would be strengthened by clarifying that the Department will continue 

its commitment to infusing equity principles throughout our programs and activities by systematically tracking 

the progress made within key priorities and initiatives to foster greater educational equity among students. 

Accordingly, we have added language to the introduction to Goal 4 (Equity) to make this clear. 

Changes: We have made the following changes to the introduction to Goal 4: 

We have added the following language to the third paragraph in the introduction to Goal 4: 

The Department will systematically track the progress made within key priorities and initiatives across 

the agency toward fostering greater educational equity among students. Many of these activities are 

well under way. For example, 

The beginning of the third paragraph in the introduction to Goal 4 now reads as follows: 

The Department will systemically track the progress made within key priorities and initiatives across the 

agency toward fostering greater educational equity among students. Many of these activities are well 

under way. For example, the Department is working to provide a greater focus on equity throughout its 

comprehensive reform initiatives, incorporating the concept of shared responsibility and accountability 

to meet the needs of students, families, and educators. 

Comment: Several commenters recommended that the Department further elaborate on issues pertaining to 

racial segregation and specifically highlight our recent guidance on use of race in fostering diversity in K-12 and 

higher education. 

Commenters specifically asked that the Department's Office for Civil Rights (OCR) address the disproportionately 

low numbers of minority students in gifted education, clarify our procedures, release new guidance, focus more 

specifically on excessive and exclusionary discipline practices, and enhance coordination among OCR regional 

offices and other stakeholders. 

Response: The Department agrees that fostering diversity in all educational settings and reducing racial 

isolation in K-12 settings is a compelling national interest and that language on this issue warrants inclusion in 

the Plan. As stated in the introduction to Goal 4 (Equity), “Equity is addressed in priorities that include awarding 

competitive grants; reauthorizing statutes designed to increase equity, including ESEA; improving the 

affordability of postsecondary education; ensuring a safe learning environment where students are free from 
Responses to Public Comments on the Department’s Strategic Plan for Fiscal Years 2011-2014, 4/2/2012, Page 16

bullying and harassment; ensuring the equitable distribution of effective teachers and resources in lowperforming, high-poverty, and high-minority schools; increasing traditionally underrepresented students’ access 

to college- and career-ready curricula such as STEM classes, advanced placement, and other high-level courses; 

and increasing access to high-quality early learning programs for high-needs children.” Further, in Sub-Goal 4.1 

(Continue to Increase the Infusion of Equity throughout the Department’s Programs and Activities), we state that 

equity is infused in the priorities for discretionary grants, including “Encouraging diversity initiatives to promote 

cross-racial understanding, break down racial stereotypes, and prepare students for an increasingly diverse 

workforce and society.”

The Department also agrees that significant racial disparities in discipline and the exclusion of minority students 

from advanced, college- and career-ready coursework are substantial concerns that must be investigated and 

addressed. Through the release of a transformed Civil Rights Data Collection, issuance of policy guidance, or the 

initiation and resolution of targeted enforcement efforts, OCR and its regional offices have comprehensively 

addressed the disproportionately low numbers of students enrolled in gifted and talented education programs 

and advanced math and science courses that make students ready for college, and in Advanced Placement (AP) 

courses that can give students a head start at college; disparate discipline rates that lead to the exclusion of 

students from education; and racial and socioeconomic isolation in schools and universities. The Department 

will continue to explore ways to improve communication and coordination with stakeholders, and will continue 

to release policy guidance, conduct investigations, and highlight data that address issues of excessive school 

discipline and other violations of Title VI and other civil rights statutes. This commitment is highlighted in 

multiple places in Goal 4, including in the introduction to Sub-Goal 4.1 (Continue to Increase the Infusion of 

Equity throughout the Department’s Programs and Activities), where we state that the Department is “working 

to ensure students are safe in school, free from bullying and harassment, and not subject to disparate 

discipline.” Further, in Sub-Goal 4.2 (Civil Rights Enforcement), we state that the Department is using an 

integrated approach to civil rights enforcement to address “racial disparities in school discipline.”

Changes: No changes necessary. 

Comment: Several commenters asked the Department to designate a lead person or office to address mental 

health issues among students, and that OCR aggressively pursue complaints regarding students with mental 

health needs. 

Response: As stated in the introduction to Goal 4 (Equity), “the Department is working to provide a greater 

focus on equity throughout its comprehensive reform initiatives.” The education of students with disabilities, 

including students with mental health needs, is an issue that involves all components of the Department and 

cannot be led by a single office. 

Changes: No changes necessary. 

Comment: Several commenters made recommendations related to instructional supports and techniques for 

students, especially students with disabilities. Specifically, commenters asked that the Department highlight the 

importance of pupil and related services professionals and other specialized instructional support personnel 

who assist students with disabilities, among other students. In addition, commenters asked that the 

Department highlight and address the importance of Universal Design for Learning (UDL) and Positive Behavioral 

Intervention and Support (PBIS), especially for children with significant needs. 

Response: Ensuring an appropriate education for each child with a disability in the most inclusive setting 

appropriate is a longstanding goal of the Department, as reflected in our administration of the Individuals with 

Disabilities Education Act and Section 504 of the Rehabilitation Act. This commitment is embodied in the actions 

under Sub-Goal 4.1 of the Plan (Continue to Increase the Infusion of Equity throughout the Department’s 
Responses to Public Comments on the Department’s Strategic Plan for Fiscal Years 2011-2014, 4/2/2012, Page 17

Programs and Activities), where we commit to “Support Individuals with Disabilities Education Act (IDEA) 

programs to increase access to high-quality, inclusive programs and services for students with disabilities.” 

With regard to the request that the Plan highlight the importance of related services professionals and other 

specialized instructional support personnel, we agree that these personnel have a critical role to play in 

supporting all students, including students with disabilities. In response to a comment made on Sub-Goal 2.3 

(School Climate and Community), we have added language to make that clear (see response to comments in 

Goal 2, Elementary and Secondary). We also note that PBIS is specifically referenced in Sub-Goal 2.3 (School 

Climate and Community), but agree that it would be helpful for the Plan to reference UDL. Therefore, we have 

revised the introduction to Sub-Goal 4.1 (Continue to Increase the Infusion of Equity throughout the 

Department’s Programs and Activities) to include language consistent with our ESEA Blueprint. 

Changes: The following has been added to the end of the fourth paragraph in the introduction to Sub-Goal 4.1: 

Further, it seeks to ensure that teachers and leaders are better prepared to meet the needs of diverse 

learners by encouraging more districts and schools to implement high-quality, state- and locally 

determined curricula and instructional supports that incorporate the principles of universal design for 

learning to meet all students’ needs.

Goal 5: Continuous Improvement of the U.S. Education System 

Comment: One commenter suggested that the Department examine its current data collection systems in order 

to reduce redundancy. 

Response: The Department agrees that it is important to reduce redundancy in our data collections and 

administrative requirements. Information on the Department’s ongoing efforts in this area can be found at 

http://www2.ed.gov/policy/gen/reg/retrospective-analysis/index.html. Given the importance that the 

Department places on reducing burden, we believe it is important for the Plan to include a specific reference to 

reducing redundancy in the data that the Department collects, and have made this change to the Plan. 

Changes: The following has been added to the second paragraph of the introduction to Sub-Goal 5.1 (Data 

Systems):

Further, the Department will continue to use the information collection clearance process to gather and 

respond to comments from the public in advance of beginning any new data collection, and to revise 

and refine existing data collections to reduce and remove redundant items. 

Comment: Several commenters recommended that the Department foster improved longitudinal data systems, 

as well as the disaggregation of data by gender and additional ethnic subgroups. One commenter asked that the 

Department expand the Civil Rights Data Collection in its scope and frequency of collection. Another 

commenter requested that school climate data be published in a manner that is accessible and not 

counterproductive. 

Response: The Department strongly agrees that the availability of improved education and workforce data and 

data systems will support efforts to achieve better outcomes for students from cradle through career and is 

committed to working with Congress and other stakeholders to expand the quality, type, and availability of 

these data. As stated in Goal 5 (Continuous Improvement of the U.S. Education System), “Achieving the 

President’s 2020 college attainment goal will require better and stronger systems, powered by information and 

innovation.”

This is why, in the past year, the Department has greatly enhanced our Civil Rights Data Collection with the 

release of groundbreaking data, disaggregated by major racial and ethnic group, gender, disability status under 

IDEA and Section 504 of the Rehabilitation Act, and other categories, on more than 72,000 schools nationwide. 
Responses to Public Comments on the Department’s Strategic Plan for Fiscal Years 2011-2014, 4/2/2012, Page 18

In 2013, the Department intends to collect data from all schools, and not just a sample of districts, while 

coordinating that process with other data collections to assure there is no unnecessary duplication. 

The Department will continue to release additional data to illuminate trends and disparities between 

advantaged and disadvantaged youth in, for example, the use of discipline, access to college-preparatory 

courses, and comparability of resources. To clarify our commitment to promoting the availability and use of 

data and data systems, we have added language to an action in Sub-Goal 5.1 (Data Systems).

With regard to school climate data, the Department agrees that such data should be available to inform states 

and school districts in their efforts to create positive school climates where students feel safe and supported in 

their classrooms and where adults and students can engage in meaningful ways. As we note in the introduction 

to Sub-Goal 2.3 (School Climate and Community), “Equipped with good information on school climate, states 

and school districts can employ strategies with demonstrated success for improving learning conditions, such as 

rethinking the length and structure of the school day, providing time for teachers to collaborate to meet 

academic challenges, and adopting evidence-based programs, such as positive behavior intervention and 

supports (PBIS), that improve student’s behavior while also reducing substance abuse and school violence.” We 

also note that the Plan includes the following action under Sub-Goal 2.3: “Build state, district, and school 

capacity to collect and use school-level climate data and other metrics to tailor approaches that effectively 

address local needs, facilitating partnerships where appropriate to focus on common metrics across sites.”

Changes: Under Sub-Goal 5.1 (Data systems), we have added the following phrase to the first example of an 

action the Department will take: “...especially data disaggregated by student subgroups. The action now reads 

as follows: 

Facilitate the development of the infrastructure necessary to collect and disseminate high-value 

education information for the improvement of child and student outcomes, especially data 

disaggregated by student subgroups. 

Comment: One commenter suggested that the Department elevate Sub-Goal 5.4 (Technology & Innovation) to 

be a goal unto itself. 

Response: It is clear that technology has the potential to bring about truly transformative change in education, 

as it can fundamentally change how we deliver education, tailor instruction to the needs of individual students, 

assess learning, and deal with a host of other issues. At the same time, we think it is crucial that technology be 

incorporated in a way that is thoughtful and integrated so that it is used in ways that most benefit students and 

teachers. Addressing technology in an integrated way ensures it does not become an expensive add-on that 

increases costs but does not help students learn or teachers teach. Accordingly, we believe it is important that 

multiple goals and Sub-Goals within the Plan consider the role of technology, rather than having a separate goal. 

Changes: No changes necessary.