August 18, 2014

Director of the Information Collection Clearance Division 

U.S. Department of Education

Comments Related to ED-2014-ICCD-0090 

These comments are provided in response to the announcement in the Federal Register on 

June 18, 2014 related to the Report of Infants and Toddlers Receiving Early Intervention 

Services. The comments are provided on behalf of the Infant & Toddler Coordinators 

Association (ITCA). ITCA represents state lead agencies that are responsible for 

implementing Part C, Infants and Toddlers with Disabilities, of the Individuals with 

Disabilities Education Act (IDEA) in all 50 states and other eligible jurisdictions. 

ITCA welcomes and supports the proposed change in Table 1, “Report of Children 

Receiving Early Intervention Services in Accordance with Part C,” that would require all 

states to submit a cumulative count of children served under Part C of IDEA. Currently, 

this cumulative count is optional but more than half the states already submit these data. 

ITCA has been consistent in our public statements that the single point-in-time count 

under Table 1 significantly under-represents the number of infants and toddlers who 

benefit from the Part C program. In fact, by most estimates and the data available under 

reported cumulative counts, children served under Part C according to the 12-month 

cumulative count is generally double the number counted on a single-day point-in-time 

count. 

ITCA supports the proposed requirement that these cumulative data be reported 

disaggregated by race/ethnicity and by gender. 

However, ITCA does not support the proposed requirement in Section D that these data 

also be reported by discrete age year “according to the count date.” The concept of 

discrete age works well for a point-in-time count but not for a cumulative count. There is 

“no count date” for cumulative counts. Data are provided according to a year of data, 

with start and end dates of the count. If cumulative data were required to be reported by 

“discrete age years”, the same child would fall in two different “discrete age years”

during the same reporting year, depending on whether it was before or after his/her

birthday. 

The current instructions allow the cumulative count to be reported according to a state’s 

specified start and end dates from “the most recent year data are available.” ITCA 
suggests the proposal requiring a cumulative count by discrete age be eliminated. If the 

Department intends to require this count to be reported by discrete age range, we suggest 

consideration be given to reporting by a child’s “birth year” (i.e., children born in 2010 or 

2011 or 2012). However, it should be noted that this would result in some children being 

counted after they have already turned 3 years. For example, a child born June 30, 2010 

would be included in the 2009-10 count, the 2010-11 count, the 2011-12 count and the 

2012-13 count. 

Additionally, ITCA suggests that states be given the “option” of also reporting child 

count data according to a birth cohort year. At least half the states already collect data on 

how many children participate in Part C at some point in the time between birth and 36 

months. It is our experience in reviewing and analyzing these data, that birth cohort data 

provide the most reliable picture of the role Part C plays in the lives of young children 

and their families. Permitting an optional count to be reported of these birth cohort data 

will provide valuable data to the public, as well as demonstrate the importance of an 

accurate picture of the full implementation of Part C of IDEA across the county. 

In closing, thank you for opportunity to submit comments on this proposed data 

collection. ITCA is available and willing to provide any additional information or 

clarification that may be needed. Feel free to contact us by email at ideaitca@aol.com if 

we may be of further assistance. 

Sincerely,

Donna Noyes, ITCA President

Department of Education Response to Comment 

From: Egnor, David 

Sent: Tuesday, August 26, 2014 2:45 PM

To: ideaitca@aol.com

Cc: Miceli, Meredith; Hoffman, Amanda; Davis, Richelle; Clark, Matthew

Subject: Report of Infants and Toddlers Receiving Early Intervention Services 

and of Program Settings Where Services are Provided in Accordance with Part C 

-- OMB Control Number 1820-0557

Ms. Noyes:

Thank you for your thorough and constructive comments regarding the Report of 

Infants and Toddlers Receiving Early Intervention Services and of Program 

Settings Where Services are Provided in Accordance with Part C (Report) 

provided during the 60-day public comment period.
Your comments consisted of two points related to the proposed changes to the 

Report. First, you supported the requirement for States to report the cumulative 

count of infants and toddlers with disabilities, ages birth through 2, who received 

early intervention services disaggregated by race/ethnicity and by gender.

Second, you expressed concern over the requirement for States to report 

cumulative counts disaggregated by discrete age year because a child could fall 

into two different discrete age years within one 12-month reporting period. 

The Office of Special Education Programs (OSEP) thanks you for your comment 

supporting the cumulative count disaggregated by race/ethnicity and gender, and 

agrees with your concern about reporting the cumulative count by discrete age 

year. OSEP will remove the requirement for States to report the cumulative count 

by discrete age year in Section D of Table 1. 

Thank you once again for your comments.

Sincerely,

David E. Egnor, Ph.D.