PAPERWORK REDUCTION ACT SUBMISSION SUPPORTING STATEMENT

March 2014

Attachment D

Highly Qualified Teacher 

Collection through EDFacts

Response to Public Comment
Attachment D – Response to Public Comment

Highly Qualified Teacher Collection through EDFacts

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TABLE	OF	CONTENTS

Introduction..................................................................................................................................................................3

Availability of Data..............................................................................................................................................................3

Capacity................. ..............................................................................................................................................................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................................................................................................................................................................16
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INTRODUCTION

This attachment contains the responses to public comments on the proposed Highly Qualified 

Teacher (HQT) Collection through EDFacts.

The 60-day comment period for the HQT Collection clearance package closed on November 18, 

2013. The U.S. Department of Education (ED) received a total of 29 comments from 26

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 sections:

 Availability of Data

 Capacity

 Burden

 Collection Level and Method

 Timeliness

 Data Quality

 Definition

 Effectiveness

 Transparency and Use

 Utility

 Charter Schools

 Sample

 General Comments

Each section provides a summary of the public comments received, ED’s response to those 

comments, and any resulting changes being made to the proposed data collection package. In 

addressing the public comments and making revisions to the package, ED focused on 

recommendations from the public comments that continue to move EDFacts forward in

achieving the goals of consolidating collections, obtaining high quality data, and reducing burden 

on data suppliers.

ED appreciates the time and attention the public spent on reviewing the HQT Collection 

clearance package and in composing thoughtful comments. ED reviewed, summarized and 

documented each comment prior to analyzing all comments. 

AVAILABILITY OF DATA

Public Comments

Seven commenters had varying viewpoints on the availability of the data to the submitters of the 

HQT data proposed for collection. 
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 Four states noted that the data, as proposed are not currently collected by 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 required HQT data. 

 One commenter said the data are available through a district web portal that is locally

managed, rather than in a state system; 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 

systems and that this is a new federal reporting 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 requires LEAs that receive Title I funds 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

This 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 only, and only 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 currently 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 systems, 

necessitating a new data collection to provide information responsive to the report requirement.

To date, the only highly 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 highly qualified

 the count of elementary classes in core academic subjects that are taught by teachers who 

are not highly qualified
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 the count of secondary classes in core academic subjects that are taught by teachers who 

are highly qualified

 the count of secondary classes in core academic subjects that are taught by teachers who 

are not highly qualified

 the count of special education teachers who are highly 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 highly qualified teacher data, as listed 

above, are currently collected with the unit of “classes.” This means the data as collected by ED

cannot be used for individual teacher counts or analyses 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 their capacity to provide the data being required via the proposed HQT 

data collection. Two states said they could not submit the required HQT data because their 

statewide data collection for the school year (SY) 2013-14 EDFacts Data Set was already 

underway, or they were unable to change their data collection system for this year. Five

commenters said it would be difficult to collect and submit the required data given the major 

changes to their data collection systems that would be required and a lack of resources to make 

such changes. One state estimates it would take two to three years to modify its data system to 

include the newly required HQT data. Time and resources would be required to redesign the data 

system, implement the modifications, and train school districts to switch from reporting courses 

to identifying individual teachers as highly qualified. Another state said that changes to its 

collection system are made a year in advance and that all changes for SY 2013-14 were finalized 

in February 2013. States stated the challenges to completing the collection include a lack of 

funding for the new collection; contract and state data system 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 systematically plan and 

implement new collections (e.g., training; building requirements; modifying contracts; modifying 

programming of state data systems; validation of the data; technical assistance support). From 
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working with States on the EDFacts collection, we understand that some states must modify

contracts or 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 year that is currently underway, the data collection 

efforts will involve staff members at all reporting levels (SEA, LEA, and school), and that the 

submission date will be soon after the collection date, ED recommends a state consider all 

methods of data collection 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 burden estimate, the cost of the collection is $0.10 per 

child, a reasonable amount given the value that would be provided by 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. Specifically, 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 required 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 reporting requirement is 

not tied to specific program funds, and that the collection is mandated for all schools yet only 

pertains to a small subset of all teachers. However, ED must collect and use these data, in order 

to meet the requirements within 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 standardized 
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reporting 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 be reported to the SEA or ED. The CR cites the PRTK provision of 

ESEA (section 1111(h)(6)(A)) enacted in 2002 that requires LEAs receiving Title I funds to have 

teacher 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 meet the CR reporting requirements.

This one year data collection is needed to inform policy makers of the prevalence of students 

being taught by highly 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 questions 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 package the reference to metadata.
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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 equitable distribution of teachers in alternate routes to certification.

One commenter noted that the proposed method 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 commenters 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 highly qualified teachers teaching in Title I schools

 # of highly qualified teachers teaching in Title I schools who are currently enrolled in an 

alternative route to certification program

 # of highly qualified teachers teaching in rural schools

 # of highly qualified teachers teaching in rural schools who are currently enrolled in an 

alternative route to certification program.

Two commenters stated the Congressional report should include data by 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 to generate high-quality data in response to the CR without 

undertaking a new, highly burdensome data collection.

 ED considered requiring data in which the “student” would be the unit of 

analysis. However, given the 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 
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involve technical challenges likely to result in inaccurate data and substantially 

increase state data collection burden and costs. While the CR provides that LEA- 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 system is not already in 

place, as we understand is often true, the student-based collection would require that 

school-level staff calculate the number of students in each of the four student groups 

(special 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 by 

highly 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 by such teachers. School staff would then have 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 study plainly did not anticipate the enormous 

burden it would place on SEAs and LEAs given the erroneous language stating that 

needed data are already collected under section 1111(h)(6)(A) of the ESEA, As a 

result, ED proposes 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 provides insightful information and meets the objective of the CR – detecting 

any disproportionality of highly 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 likely would be technically challenging, 

include a high level of error, and would be very difficult to undertake. As noted above, 

reporting student counts are highly burdensome and more susceptible to error than 

teacher counts. The reporting of teacher data as set forth in the clearance package can 

effectively show whether groups of students specified in the CR are being taught by 

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 originally considered.

 Districts already have the required data; districts maintain records on the number of highly

qualified teachers in the key categories being required who are, and who are not, in 

alternative route programs.
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 The data provided by districts to states will enable states to provide ED with all of the data 

needed to determine whether a higher proportion of highly qualified special education 

teachers and highly qualified Title III language teachers are enrolled in alternative routes

compared to the proportion of highly 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 were 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 that 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 does 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 highly qualified teachers currently enrolled in alternative route to certification 

programs who teach in rural schools or in high-poverty schools by using 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 students 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 highly qualified teacher data reported for this new requirement to 

estimate the proportion of each district’s highly qualified teachers who teach in rural or highpoverty 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 prudent for this oneyear 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 crossLEA comparisons.

Collecting the required information by teacher count versus student count is particularly more 

feasible for students in rural areas and students from low-income families, given the lack 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 FRPL data, 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 FRPL programs 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 student 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

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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 highly 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 not be created. The Department carefully

deliberated on which data elements were necessary to fulfill the intent of the CR report 

requirement while also trying to limit unnecessary burden; therefore any data elements beyond 

those essential to the report will not be collected.

Changes to the Proposed HQT Data 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 required 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 as 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 required in the CR, it confirmed that the data were not 

readily 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 seeking public input in September 2013. ED plans to submit a report in 

2014. 

Since one state has collected the required 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. The 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 reporting due date of June 30, 2014.
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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 any 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 reliable data. ED will not be able to run its 

typical 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 validate 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 highly qualified status, for example the HQT 

status for a teacher without a specific teaching assignment. One commenter suggested 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 by OMB. ED will provide guidance, including a definitions section, to further address 

the questions raised regarding reporting specifications in the EDFacts File Specification 

associated with this collection. Following is ED’s response to the specific comments about 

definitions. 
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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 has revised the definition for consistency with 

current ED regulations (see 34 CFR 200.56(a)(2)(ii)(A)).

Enrolled

ED considers 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 fully 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 by more than one school district or employed by an 

educational service agency. ED has added a qualification to “special education teachers” so that 

highly 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 highly qualified teachers 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 state-approved teacher preparation program in 

which the participants, who are still actively participating in the program, are concurrently 

deemed highly 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;

 Participating 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 years; and

 Demonstrating satisfactory progress toward full certification as prescribed by the 

State. 
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By the same regulation, the state must have ensured through its certification and licensure 

process that the provisions in the four bullets above have been met.

NOTE: 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 alternative 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 IHE-based”).

EFFECTIVENESS

Public Comments

Two commenters mentioned that the proposed data collection does 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 Learners, students 

in rural areas, and students from low-income families are disproportionately taught by teachers

who are deemed to be Highly 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. Specifically, 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 currently 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.
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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 valuable 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. Therefore 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

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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 only. ED may acknowledge in the report to 

Congress regarding highly qualified teachers that the data provided are from one school year and 

may fluctuate from year to year.

Public Comment

One commenter suggested also collecting the “number of unfilled positions” meant to capture 

long-term substitutes that often skew HQT data for Title I and “HQT students.”

ED’s Response

ED thanks the commenter for the suggestion. ED does not have authority to expand the proposed 

data collection beyond the criteria set forth in the CR.

Public Comment

One commenter stated that more funding and support for English language learners (ELL) is 

needed, particularly in suburban and rural areas. Funding formulas for ELL students should 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 with 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

Highly 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 highly qualified.

ED’s Response

ED thanks the commenter for the suggestion, however, it is beyond the scope of the proposed 

data collection.

Public Comment

One commenter requested that ED specify 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 system 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 collection.

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 of 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.