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 rel ated 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 Earl y Interven tion Services in Accordance with Part C,” that would require all states to submit a cumulative count of children served under Part C of IDEA. Currentl y, 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, b y most estimates and the data available under repo rted 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 dis aggregated b y race/ethnicity and b y gender. However, ITCA does not support the proposed requirement in Section D that these data also be reported b y discrete age ye ar “according to the count date .” The concept of discrete age works well for a point
- in
- t ime count but not for a cumulative count. There is “no count date” for cumulative counts. Data are provided according to a ye ar of data, with start and end dates of the count. If cumulative data were required to be reported b y “discrete age ye ars”, the same child would fall in two different “discrete age y ears” during the same reporting ye ar, 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 st art and end dates from “the most recent y ear data are available.” I TCAsuggests 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 cons ideration be given to reporting b y a child’s “birth y ear” (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 ye ars. 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 y ear. At leas t half the states alread y 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 analy zing these data, that birth cohort data provide the most reliable picture of the role Part C play s in the lives of y oung 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 f

ull implementation of Part C of IDEA across the county
. In closing, thank you for o pportunity to submit comments on th is proposed data collection. ITCA is available and willing to provide an y additional information or clarification that may

be needed. F eel free to contact us by email at ideaitca@aol.com if we may be of further assistance. Sincerel y, Donna No yes , 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 Earl y Intervention Services and of Program Settings Where Services are Provided in Accordance with Part C

-- OMB Control Number 1820
- 0557 Ms. Noy es: Thank you for y our thorough and constructive comments regarding the Report of In fants and Toddlers Receiving Earl y Intervention Services and of Program Sett ings 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 r eport the cumulative count of infants and toddlers with disabilities, ages birth through 2, who received earl y intervention services disaggregated b y race/ethnicity and b y gender. Second, you expressed concern over the requirement for States to report cumulative counts disaggregated b y discrete age year because a child could fall into two different discrete age ye ars within one 12
- month reporting period. The Office of Special Education Programs (OSEP) thanks y ou for y our comment supporting the cumulative count disaggregated b y race/ethnicity and gender, and agrees with your concern about reporting the cumulative count by discrete age ye ar. OSEP will remove the requirement for States to report the cumulative count by discrete age y ear in Section D of Table 1. Thank you once again for y our comments. Sincerel y, David E. Egnor, Ph.D.