PAPERWORK REDUCTION ACT SUBMISSION SUPPORTING STATEMENT 

### March **201 4**  

# Attachment D 

# Highly Qualified Teacher **Collection through ED**  **Facts Response**  **to Public Comment**Attachment D

– Response to Public Comment Highl y Qualified Teacher Collection through EDFacts

Page	D - 2 

### TABLE OF	CONTENTS Introduction
........................... ................................ ................................ ................................ ................................ ....... 3 Availability of Data
......... ................................ ................................ ................................ ................................ ..................... 3 Capaci ty ................. ................................ ................................ ................................ ................................ .............................. 5 Burden
.................. ................................ ................................ ................................ ................................ ............................... 6 Collection Level and Method ................................ ................................ ................................ ................................ ................. 8 Timeliness
.............. ................................ ................................ ................................ ................................ ............................ 11 Data Quality
............ ................................ ................................ ................................ ................................ ........................... 12 Definition
............... ................................ ................................ ................................ ................................ ........................... 12 Effectiveness
........... ................................ ................................ ................................ ................................ ............................ 14 Transparency and Use ................................ ................................ ................................ ................................ ............................ 14 Utility
... ................ ................................ ................................ ................................ ................................ ............................ 15 Charter Schools
........ ................................ ................................ ................................ ................................ ............................ 15 Sample
.................. ................................ ................................ ................................ ................................ ............................ 15 General Comments
... ................................ ................................ ................................ ................................ ............................. 16Attachment D

– Response to Public Comment Highl y Qualified Teacher Collection through EDFacts

Page	D - 3 

## INTRODUCTION This attachment contains the response s to public comments on the proposed Highl y Qualified Teacher ( HQT) Collection through EDFacts . The 60
- day

comment period for the HQT Collection clearance package closed on November 1 8 , 201 3 . The U.S. Department of Education ( ED ) received a total of 29 comments from 2 6 commenters. Most comments came from state educational agencies (SEAs) and associations , each submitting 9 comments. Four comments were from institutions of higher education, three from individuals, and one from a teacher. This document is organized topically into the following s ections:

 Availability

of Data  Capacity  Burden  Collection L evel and Method  Timeliness  Data Quality  Definition  Effectiveness  Transparency

and Use  Utility  Charter Schools  Sample  G eneral Comments Each section provides a summary of the public comments received, ED’s response to those comments, and an y resulting changes being made to the proposed data collection package. In addressing the public comments and making revisions to the package, ED focuse d on recommendations from the public comments that continue to move EDFacts forward i n achieving the goals of consolidating collections, obtaining high quality data , and reducing burden on data suppliers. ED appreciates the time and attention the public s pent on reviewing the HQT Collection clearance package and in composing thoughtful comments
. ED reviewed, summarized and documented each comment prior to anal yz ing all comments. 

### AVAILABILITY OF DATA **Public Comments** Seven c ommenters had varying viewpoints on the availability of the data to the submitters of the HQT data proposed for collection.Attachment D

– Response to Public Comment Highl y Qualified Teacher Collection through EDFacts

Page	D - 4  Four states not ed that the data, as proposed are not currentl y colle cted b y the SEA ; two of the four states included specific comments that the data are collected by core course counts and not by full
- time equivalents ( FTE )
.  One state commenter said the state can provide the requ ir ed HQT data
.  One commenter said the data are available through a district web portal that is locally managed, rather than in a state s ys tem ; this commenter also said ED should use data already collected from states to meet the new report to Congress requirements.  One commenter said ED should have ensured states and LEAs complied with the Parent Right
- to - Know (PRTK) provision of ESEA so that the data required for the report to Congress would have been available. **ED’s Response** ED understands that many states do not have the proposed data within their existing state data sy stems and that this is a new federal reporti ng requirement. The Fiscal Year 2013 Continuing Resolution (CR) that mandates this study cites , Section 1111(h)(6)(A ) of ESEA , the provision within PRTK which requir es LEAs that receive Title Ifunds to provide a notice to the parents of each student who attends a school receiving Title I funds that upon a parent’s request, the LEA is required to provide the professional qualifications of a student’s classroom teacher. The provision specifies that the qualifications must include:  Whether the teacher meets state certification and qualification requirements for the subject and grade level he or she is teaching;  Whether the teacher is teaching under emergency or provisional credentials;  The teacher’s academic degree ( s ) and certification ( s ) and the major ( s ) or discipline ( s ) for those;  Whether the student receives services from paraprofessionals, and if so, the paraprofessionals ’ qualifications Th is PRTK provision , cited in the CR , does not apply to all LEAs and schools. LEAs and schools that do not receive Title I funds under ESEA are not required to provide teacher qualification information. A qualifying LEA is required to report teacher qualification information to a student’s parents onl y , and onl y at the request of the parents. The PRTK provision does not require a qualifying LEA to report the specified teacher qualifications information to the state or federal government , and SEAs are not currentl y required to collect the HQT data specified in the PRTK provision. Thus, neither ED nor most State Education Agencies have the data to respond to the CR requirement within existing collections or sy stems , necessitating a new data coll ection to provide information responsive to the report requirement. To date, the onl y highl y qualified teacher data reported to ED are those elements summarized below ; the data are submitted by the state at the school, LEA and SEA levels unless noted below :  the count of elementary classes in core academic subjects that are taught by teachers who are highl y qualified  the count of elementary classes in core academic subjects that are taught by teachers who are not highly

qualifiedAttachment D

– Response to Public Comment Highl y Qualified Teacher Collection through EDFacts

Page	D - 5  the count of secondary classes in core academic subjects that are taught by teachers who are highl y qualified  the count of second ary classes in core academic subjects that are taught by teachers who are not highly

qualified  the count of special education teachers who are highl y qualified (SEA and LEA level only)  the count of special education teachers who are not highly qualified (SEA and LEA level only) With the exception of special education teachers, the highl y qualified teacher data, as listed above, are currently

collected with the unit of “classes
. ” This means the data as collected b y ED cannot be used for individual teacher counts or analy ses because an individual teacher may teach multiple classes. Therefore the current ED reporting requirements for highly qualified teachers cannot be used to meet the new requirement in the CR
. ED does not have the data to respond to the new reporting requirement within the CR and states are not currently required to report it, therefore ED must propose a new data collection to meet the report requirement in the CR
. **Changes to the Proposed HQT Data Collection** No change
. 

### CAPACITY **Public Comments** Seven states addressed the ir capacity to provide the data being requ ir ed via the proposed HQT data collection. Two states said the y could not submit the requ ir ed HQT data because their statewide data collection for the school ye ar (SY) 2013
- 14 EDFacts Data Set was already underway , or they

were unable to change their data collection s ys tem for this year. Five commenters said it would be difficult to collect and submit the requir ed data given the major changes to their data collection sy stems that would be required and a lack of resources to make such changes. One state estimates it would take two to three ye ar s to modify its data s ys tem to include the newl y required HQT data. Time and resources would be required to redesign the data sy stem, implement the modifications, and train school districts to switch from reporting courses to identifying individual teacher s as highly qualified. Another state said that changes to its collection sy stem are made a ye ar in advance and that all changes for SY 2013 - 14 were finalized in February

2013. States stated the c hallenges to completing the collection include a lack of funding for the new collection; contract and state data sy stem modifications; and data collection scheduling. **ED’s Response** ED appreciates that this requirement does not follow ED's preferred protocol of notifying states well in advance of data system changes that would allow states to sy stematically plan and implement new collections (e.g., training; building requirements; modifying contracts; modifying programm ing of state data sy stems; validation of the data; technical assistance support). FromAttachment D

– Response to Public Comment Highl y Qualified Teacher Collection through EDFacts

Page	D - 6 working with States on the EDFacts collection, we understand that some states must modify contracts o r renegotiate agreements with LEAs in order to implement collection of new items at this time for SY 2013
- 14. While the data are not complex and the numbers of data elements are limited, ED recognizes that the method the state uses to get the data from LEAs will vary across states and that methods to collect data from LEAs may vary within states. Given that this is a one - year collection for data about a school ye ar that is currentl y underway , the data collection efforts will involve staff members at all reporting levels (SEA, LEA, and school) , and that the submission dat e will be soon after the collection date, ED recommends a state consider all methods of data c ollection available to it when selecting its approach to collecting the data from LEAs . **Changes to the Proposed HQT Data Collection** No change
. 

### BURDEN **Public Comments**  Ten commenters addressed the burden that would result from the proposed HQT data collection. Six commenters said the collection would be burdensome. Some mentioned that it is unfunded, and would require creating new data collection instruments or changing existing tools. Three commenters said there are very few teachers participating in alternate route to certification programs, and one expressed for that reason, the collection was a poor use of resources. Four commenters said , based on ED's burd en estimate, the cost of the collection is $0.10 per child, a reasonable amount given the value that would be provided b y the data collected. Two commenters said the burden should be minimal if ED could use data already collected under PRTK . One commenter requested additional information to be able to comment on ED's burden estimates. Specificall y, the state asked what type and how much metadata is being considered for inclusion in the collection . The commenter noted that FTE data are difficult to derive and asked whether the data requ ir ed in the CR would need to be comparable to other teacher data currently submitted via EDFacts . **ED’s Response** ED recognizes that data collections do create reporting burden, that the reporti ng requirement is not tied to specific program funds , and that the collection is mandated for all schools yet onl y pertains to a small subset of all teachers . H owever, ED must collect and use the se data, in order to meet the requirements with in the CR. In order for ED to meet its reporting requirements and also recognize the challenges noted by the commenters , we are proposing a data collection with clear and implementable guidance about the data elements and a familiar and standardizedAttachment D

– Response to Public Comment Highl y Qualified Teacher Collection through EDFacts

Page	D - 7 reportin g method (EDFacts ). States are encouraged to collect the required data using the means and methods most efficient for the state. Regarding the comments about availability of data as a result of PRTK, as described above, these data are not required to b e reported to the SEA or ED. T he CR cites the PRTK provision of ESEA ( section 1111(h)(6)(A)) enacted in 2002 that requires LEAs receiving Title I funds to have t eacher qualification data available to answer parental requests regarding the credentials of their child's teacher(s) , as described under the “Availability of Data” section of this document
. The PRTK provision does not require LEAs to report teacher qualification data to the SEA or ED. ED must now collect the information from states in order to m eet the CR reporting requirements. This one year data collection is needed to inform policy makers of the prevalence of students being taught b y highl y qualified teachers who are participating in an alternate route to teaching program. The data, FTE counts , do not need to be comparable to other teacher data currently submitted through EDFacts . All counts, whether zero, small or large, will be helpful in informing future education policy
. **Changes to the Proposed HQT Data Collection** No change. **Public Comments**  There were no public comments directly on ED’s proposal to collect metadata in addition to the data elements. However, there were multiple comments regarding concern of overall burden, cost and inadequate time to meet the requirements , and questio ns of how the collection of metadata may

contribute to the burden of reporting the data
. **ED’s Response** ED is not planning to collect metadata related to this collection. **Changes to the Proposed HQT Data Collection** ED will remove from the clearance packag e the reference to metadata
.Attachment D

– Response to Public Comment Highl y Qualified Teacher Collection through EDFacts

Page	D - 8 

### COLLECTION LEVEL AND METHOD **Public Comments** Thirteen commenters addressed the collection methodology including the education levels at which the proposed data would be collected. Twelve commenters expressed concern that the proposed collection was teacher based versus student based which may not fulfill Congress's intent for the data collection , and may limit the ability to examine the equita

ble distribution of teachers in alternate routes to certification. One commenter noted that the proposed m ethod of data collection for teachers of rural students and economically

disadvantaged students is potentially inaccurate and will not show disparities between the teaching of these students versus their peer groups
. Five commenter s said that if student data were not being collected, the teacher data should be collected at the school
- level. Four commenters suggested collecting additional data on teaching in rural and Title I schools :  # of highl y qualified teachers teaching in Title I schools  # of highl y qualified teachers teaching in Title I schools who are currentl y enrolled in an alternative route to certification program  # of highl y qualified teachers teaching in rural schools  # of highl y qualified teachers teaching in rural schoo ls who are currentl y enrolled in an alternative route to certification program. Two commenters stated the Congressional report should include data b y LEA and State. One commenter requested clarification on how certain teachers should be counted , for example what indicates that a teacher should be included in the count for HQT for students with disabilities or limited English proficiency
. **ED’s Response** The U.S. Department of Education (ED) took a number of steps before making a final decision to undertake the proposed approach. Here is a summary of the steps that were taken:  **ED reviewed information collected through ED’s Statewide Longitudinal Data Systems (SLDS) Grant Program and conducted interviews with several SEAs and**  **determined that not many**  **SEAs appeared to have an operational, high -**  **quality teacher**  **- to**  **- course**  **- to**  **- student data system that is linked to reliable teacher licensure**  **data.** Therefore, it was unclear whether more than only a small number of SEAs would likely have the capacity t o generate high
- quality data in response to the CR without undertaking a new, highly burdensome data collection.  **ED considered requ ir**  **ing data in which the “student” would be the unit of analysis.**  **However, given th e**  **indications that most states would need to**  **add new data elements to student level data collection systems for states to have**  **student/course/teacher connections , ED determined that such a collection would** Attachment D

– Response to Public Comment Highl y Qualified Teacher Collection through EDFacts

Page	D - 9 **involve technical ch**  **allenges likely to result in i n**  **accurate data and substantially**  **increase state data collection burden and costs .**  While the CR provides that LE A - and not school
- level data be reported, such LEA - level data are dependent on school level data
. When a high
- quality teacher
- to - course - to - student data s ys tem is not already in place , as we understand is often true, th e student
- based collection would require that school
- level staff calculate the number of students in each of the four student groups ( **spe cial education teachers, teachers who work with English Learners in Title III**  **language instruction educational programs, teachers who work in schools with high percentages of low**  **- income students**  **, and teachers in rural schools**  **)** who are taught b y highl y qualified teachers who are currently enrolled in alternative routes to certification as well as the number of students who are NOT in each of the four student groups but who are taught b y such teachers. School staff would then hav e to report these data to their districts and the districts would need to aggregate the data and report the data to the state. Each state would then compile the district data in order to provide the data to ED.  **Thus, the CR provision requiring this stud y plainly did not anticipate the enormous**  **burden it would place on SEAs and LEAs given the erroneous language stating**  **that needed data are alre**  **a dy collected under**  **section 1111(h)(6)(A) of the ESEA ,**  **As a**  **result , ED**  **propose s**  **to collect data on the number and percentage of**  **teachers who**  **are highly qualified, who are currently enrolled in an alternative certification program and who teach students in each of the four key student groups.**  This approach provide s insightful information and meets the object ive of the CR

– detecting any disproportionality

of highl y qualified teachers who are teaching students in the subgroups while participating in alternative route programs

– without overburdening school
- level staff with a data collection that likel y would be technically challenging, include a high level of error , and would be very difficult to undertake. As noted above, reporting student counts are highl y burdensome and more susceptible to error than teacher counts. The repo rting of teacher data as set forth in the clearance package can effectivel y show whether groups of students specified in the CR are being taught b y teachers who are not highly qualified at a higher rate of prevalence than students outside of the specified student groups. Here are the key

advantages of the proposed approach:  By collecting data on the number of teachers for these four groups of students, ED estimated that the error and burden of this collection on SEAs and LEAs would be substantially lower than for the collection that was originall y considered
.  Districts already have the requ ir ed data; districts maintain records on the number of highly qualified teachers in the key categories being requ ir ed who are, and who are not, in alternative route programs .Attachment D

– Response to Public Comment Highl y Qualified Teacher Collection through EDFacts

Page	D - 10  The data provided b y districts to states will enable states to provide ED with all of the data needed to determine whether a higher proportion of highl y qualified special education teachers and highl y qualified Title III language teachers are enrol led in alternative routes compared to the proportion of highl y qualified general education teachers and non
- Title III teachers. The proposed data collection includes HQT data maintained at the state and LEA levels . Several commenters said that if student data we re not being collected, the teacher data should be collected at the school
- level. ED appreciates the suggestion and has considered collection at the school level. Given th at ED is collecting data about SY 2013
- 14 and that the data will be due a few months after the data collection specifications are finalized, ED determined that better data could be collected at the level of the school district which do es the hiring and therefore maintains the records , rather than at the level of the school(s). ED will then estimate the proportion of each district’s highl y qualified teachers currentl y enrolled in alternative route to certification programs who teach in rural schools or in high
- poverty schools by

usin g data ED already collects and maintains through the Common Core of Data (CCD). First, the CCD contains a designation of each school ’s “locale” as urban, suburban, town or rural . Second, the CCD contains the number of schools where more than 75% of stud ents are eligible for free and reduced price lunch (FRPL) under the National School Lunch Program. ED will use the school locale and FRPL data from CCD along with the highl y qualified teacher data reported for this new requirement to estimate the proport ion of each district’s highl y qualified teachers who teach in rural or high
poverty schools. ED agrees that addressing Title I and rural disproportionality issues will be more difficult with data collected at the district level, but believes it more prude nt for this one
ye ar collection to estimate the figures using already collected school
- level locale and poverty data within each district , rather than significantly increasing burden by expanding this collection to the level of the individual school. ED believes that these data could enable valuable cross
LEA comparisons. Collecting the required information by teacher count versus student count is particularl y more feasible for students in rural areas and students from low
- income families, given the l ack of clear, available and objective indicators that a student be counted “low
- income” or “rural
. ” While ED is aware of the limitations of using both the locale codes and the FRPLdata, we believe this is the most feasible option for collecting and reporting the data required for the CR while also considering state and local reporting burden and likelihood of data limitations with more technically

difficult data collections
. The major limitations to using the CCD data include an awareness that some students who live in rural areas attend schools designated as Town, Suburb, or City

and that some students who attend schools designed as high poverty may not be students who are eligible for FRPL. In addition, eligibility for FRPLprograms varies across states (see http://nces.ed.gov/programs/coe/indicator_clb.asp ). We believe these limitations are better than the limitations if ED substantially increased state and local reporting burden where states and districts would have to address all the nuances of stude nt urbanicity and poverty

status, with little or no benefit to the final data needed for the CR. The proposed collection will allow ED to meet its reporting requirements identified in the CR.Attachment D

– Response to Public Comment Highl y Qualified Teacher Collection through EDFacts

Page	D - 11 States must provide the HQT status of teachers available at the time of the collection for SY 2013 - 14. Attachment C, (pages 4 and 5) of the HQT collection clearance package explains that teachers are counted as Title III HQT when they are highl y qualified in teaching “Title III language instruction educational programs regardless of source of salaries.” Similarly , teachers would be counted in the Special Education HQT count if they are “special education HQTs in the district.” Several commenters recommended the addition of four data points related to teachers in rural schools and Title I schools. This modification to the proposed data collection would result in additional burden that the Department believes should n ot be created
. The Department carefully deliberat ed on which data elements were necessary to fulfill the intent of the CR report requirement while also tryingto limit unnecessary burden; therefore any data elements beyond those essential to the report will not be collected. **Changes to the Proposed HQT Da ta Collection**  No change. 

### TIMELINESS **Public Comments** Ten commenters addressed the timeliness of the proposed HQT data collection
. Five commenters said it was impossible or unlikely for states to meet the proposed collection deadlines for submitting the requir ed HQT data. Six commenters mentioned ED's delay in administering the collection will result in missing the deadline for the report to Congress and may have other adverse effects , such a s states having little time to provide the data
. One commenter said it had already collected the data outside the proposed collection window. **ED’s Response** As ED began working to collect the data requir ed in the CR, it confirm ed that the data were not readil y available within most SEAs
. ED then undertook the steps described in the “Collection Level and Method” section of this document (above), which resulted in ED publishing the notice of the collection and seek ing public input in September 2013 . ED plans to submit a report in 2014. Since one state ha s collected the requ ir ed data prior to the proposed start date of the collection window, and other states noted their usual collection of HQT occurs after January 31, 2014, ED will modify

the dates of the collection window
. T he due date for reporting data will change from May to June 2014 , and the collection window will allow any state - determined count date for the school year (SY) 2013
- 14 HQT data that occurs prior to the reportin g due date of June 30 , 2014 .Attachment D

– Response to Public Comment Highl y Qualified Teacher Collection through EDFacts

Page	D - 12 **Changes to the Proposed HQT Data Collection** The reporting period will be changed from a state
- determined date between October 1, 2013, and January 31, 2014, to an y state - determined count date for SY 2013
- 14 HQT data that occurs prior to the reporting due date of June30 , 2014. 

### DATA QUALITY **Public Comments** Six commenters mentioned concerns about the quality of the data proposed for collection. Three commenters expressed doubt in the quality of the data. One commenter asked if ED would run edit checks on the data. Two commenters requested ED continue providing valuable and reliable data. **ED’s Response** It is the responsibility

of the state to submit valid and rel iable data. ED will not be able to run its ty pical extensive edit checks on the data submitted as there are no comparable data which would be needed for such checks (as there is no prior year data to compare it to, nor other comparable data groups to valid ate consistency)
. ED will be able to conduct a basic data quality review of the file to evaluate timeliness and completeness prior to preparing the required report to Congress. **Changes to the Proposed HQT Data Collection** No changes are proposed at this time
. 

### DEFINITION **Public Comments** Seven commenters made suggestions regarding the definitions of specific terms related to the proposed HQT data collection. Five commenters suggested that "alternate route to certification" be better defined. Several of the commenters suggested revising the explanation for alternate route to certification program given in Attachment B, page 4 to include only criteria (3), so the criteria match the current definition for alternative route to certification program in regulations and guidance
. One commenter asked for clarification on what "enrolled" means. One commenter asked for clarification on determining a teacher's highl y qualified status , for example the HQT status for a teacher without a specific teaching assignment
. One commenter sugge sted adding a qualification to “ special education teachers ” so that special education teachers are counted regardless of the source of salaries
. **ED’s Response** ED’s standard process is to provide specific reporting requirements after data collections are approved b y OMB. ED will provide guidance , including a definitions section, to further address the questions raised regarding reporting specifications in the EDFacts File S pecification associated with this collection
. Following is ED’s response to the specific comments about definitions.Attachment D

– Response to Public Comment Highl y Qualified Teacher Collection through EDFacts

Page	D - 13 **Alternate Route to Certification** ED agrees that the explanation for alternate route to certification program given in the original Attachment B, page 4 needed to be revised and h as revised the definition for consistency with current ED regulations (see 34 CFR 200.56(a)(2)(ii)(A)). **Enrolled** ED consider s someone enrolled in an alternative route to certification program if he or she is participating in such a program that is consistent with 34 CFR 200.56(a)(2)(ii)(A), leading to licensure , and has a bachelor’s degree and the requisite subject
- matter knowledge to be HQT. The regulation cited above makes participation of teachers in alternative route to certification programs full y certified for purposes of the HQT definition
. **HQT Status** All teachers who are HQT in any subject should be included in this data collection. **Special Education Teachers** ED agrees that the current language on special education teachers may result in teachers not being included in counts if they are shared b y more than one school district or employed b y an educational service agency . ED has added a qualification to “special education teachers” so that highl y qualified special education teachers are counted regardless of the source of salaries
. **Changes to the Proposed HQT Data Collection** ED will clarify

that special education highl y qualified teac hers regardless of the source of salary be counted for purposes of this data collection. ED will revise the explanation for alternate route to certification program as included in Attachment B4 to read as follows: An alternative route to certification program is a s tate - approved teacher preparation program in which the participants, who are still activel y participating in the program, are concurrentl y deemed highl y qualified by their state because they are doing the following (according to 34 CFR 200.56(a)(2)(ii)):

 Receiving high
- quality professional development that is sustained, intensive, and classroom
- focused in order to have a positive and lasting impact on classroom instruction, before and while teaching;  Parti cipating in a program of intensive supervision that consists of structured guidance and regular ongoing support for teachers or a teacher mentoring program;  Assuming functions as a teacher only for a specified period of time not to exceed three ye ars; and  Demonstrating satisfactory progress toward full certification as prescribed by the State.Attachment D

– Response to Public Comment Highl y Qualified Teacher Collection through EDFacts

Page	D - 14 By the same regulation, the state must have ensured through its certification and licensure process that the provisions in the fo ur bullets above have been met. N OTE: An alternative route to certification program primarily serves candidates whom states permit to be the teachers of record in a classroom while participating in the teacher preparation program. For purposes of this study , we are interested only in an a lternative route to certification program that meets the definition above. It may be housed within an institution of higher education (IHE) (commonly referred to as “alternative, IHE - based”) or outside an IHE (commonly

referred to as “alternative, not IH E - based”)
.



### EFFECTIVENESS **Public Comments** Two commenters mentioned that the proposed data collection do e s not provide insight into teacher effectiveness. **ED’s Response** The purpose of this collection is not to measure teacher effectiveness. The CR requires the data collection to report on the extent to which students with disabilities, English L earners, students in rural areas, and students from low
- income families are disproportionately taught by teachers who are deemed to be Highl y Qualified Teachers (HQT) while currently enrolled in an alternative route to certification program. **Changes to the Proposed HQT Data Collection** No change. 

### TRANSPARENCY AND USE **Public Comment** Nine commenters stated that the data collected should be transparent, accessible and usable by the public
. Specificall y, it was suggested that ED provide the following data to give context to the HQT data collection:  The data in raw numbers and percentages  The number and percentage of students overall, and by subgroups at the SEA and LEA levels  The number of non
- HQTs currentl y enrolled in alternative route to certification programs **ED’s Response** ED appreciates the suggestion to provide contextual data and will take it into consideration as it is preparing its report to Congress. ED will make every effort to have the HQT data available for public use in addition to the Congressional report.Attachment D

– Response to Public Comment Highl y Qualified Teacher Collection through EDFacts

Page	D - 15 **Changes to the Proposed HQT Data Collection** No change
. 

### UTILITY **Public Comments** Ten commenters addressed the usefulness of the proposed HQT data collection
. Two commenters said, as proposed, the data would be of little use. Eight commenters stated the proposed collection is critical information for policymakers and others. **ED’s Response** ED has and will continue to provide federal education program data that provides insight on the education of our nation's children. Congress has required this report because it believes the data will provide valua

ble information for them and the public. **Changes to the Proposed HQT Data Collection** No change
. 

### CHARTER SCHOOLS **Public Comments** Seven commenters stated that charter schools should be included in the proposed data collection. **ED’s Response** The proposed data collection does not exclude charter schools and LEAs
. T herefore they are included in the data collection. **Changes to the Proposed HQT Data Collection** No change
. 

### SAMPLE **Public Comments** Six commenters addressed ED's proposal to collect HQT from all states and LEAs. One commenter suggested a sampling be done, instead of collecting data from all states and LEAs. Five commenters thanked ED for choosing to collect HQT data from all states and LEAs. **ED’s Response** The CR requires that HQT data be collected from all states. **Changes to the Proposed HQT Data Collection**Attachment D

– Response to Public Comment Highl y Qualified Teacher Collection through EDFacts

Page	D - 16 No change
. 

### GENERAL COMMENTS There were eight comments made that did not clearly fit into the twelve areas listed above. These comments were considered general comments. **Public Comment** One commenter noted that alternate certification figures will fluctuate from year to year. **ED’s Response** The proposed data collection is for one year onl y. ED may acknowledge in the report to Congress regarding h ighly qualified t eachers that the data provid ed are from one school year and may fluctuate from year to year. **Public Comment** One commenter s uggest ed also collecting the “number of unfilled positions” meant to capture long
- term substitutes that often skew HQT data for Title Iand “ HQT students
. ” **ED’s Response**  ED thanks the commenter for the suggestion. ED does not have authority t o expand the proposed data collection beyond the criteria set forth in the CR. **Public Comment** One commenter stated that m ore funding and support for English language learner s (ELL) is needed, particularl y in suburban and rural areas. Funding formulas for ELL students shoul d be comparable to those for students with disabilities. **ED’s Response** ED thanks the commenter for the suggestion, however, it is beyond the scope of the proposed data collection. **Public Comments** One state volunteered to participate in conversations with ED regarding the placement of teachers participating in alternative routes to certification
. **ED’s Response** ED thanks the SEA for its willingness to work wi th ED in better understanding and developing policy regarding the placement of teachers participating in alternative routes to certification programs. **Public Comment**Attachment D

– Response to Public Comment Highl y Qualified Teacher Collection through EDFacts

Page	D - 17 One commenter suggested that a minimum standard for entry into an education program should include completing a preparation program prior to becoming highl y qualified
. **ED’s Response** ED thanks the commenter for the suggestion, however, it is beyond the scope of the proposed data collect ion. **Public Comment** One commente r requested that ED s pecify whether prekindergarten is included in the data collection. **ED’s Response** Counts of prekindergarten teachers are not included in this data collection
. **Public Comment** One commenter noted that ED should consider what changes are needed to its data sy stem to provide data for evidence
- based solutions to the challenges in public schools
. **ED’s Response** ED thanks the commenter for the suggestion, however, it is beyond the scope of the proposed data coll ection. **Public Comment** One commenter stated the data collection should be the same for teachers certified via traditional routes as well as alternative routes. **ED’s Response** ED thanks the commenter for the suggestion , however, it is beyond the scope o f the required data collection. **Changes to the Proposed HQT Data Collection** ED has included a clarification in Attachment B that counts of prekindergarten teachers are not included in this data collection.