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ICRAS	ICR	ID and	OMB	Number:	(XXXX.XXX)	1870-0504

Revised:	XX/XX/XXXX

RIN	Number:	XXXX-XXXX	(if	applicable)

FOR	PAPERWORK	REDUCTION	ACT	

SUBMISSION

Mandatory Civil Rights Data Collection

May 2015

SUPPORTING STATEMENT, PART B: 

COLLECTIONS OF INFORMATION EMPLOYING 

STATISTICAL METHODS 

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870-0504 

Revised XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

1. Describe the potential respondent universe (including a numerical estimate) and any

sampling or other respondent selection method to be used. Data on the number of 

entities (e.g., establishments, state and local government units, households, or 

persons) in the universe covered by the collection and in the corresponding sample 

are to be provided in tabular form for the universe as a whole and for each of the 

strata in the proposed sample. Indicate expected response rates for the proposed 

sample. Indicate expected response rates for the collection as a whole. If the 

collection had been conducted previously, include the actual response rate achieved 

during the last collection.

The 2015–16 Civil Rights Data Collection (CRDC) will be a universe of public schools and school 

districts. Therefore, none of the sampling procedures (i.e., stratification, estimation, etc.) are 

proposed to be used in the 2015–16 CRDC administration. 

However, if budget constraints are such that a universe collection is not possible, the Office for 

Civil Rights (OCR) will select a sample of public school districts. In the event that a sample will 

be selected for the 2015–16 CRDC, OCR will submit an updated sample selection plan to OMB 
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ICRAS	ICR	ID and	OMB	Number:	(XXXX.XXX)	1870-0504

Revised:	XX/XX/XXXX

RIN	Number:	XXXX-XXXX	(if	applicable)

for review and approval. OCR is providing information regarding a potential sampling frame 

and methodology for the 2015–16 CRDC, below.

Respondent Universe

The respondent universe of the 2015–16 CRDC and the potential sampling frame for the 2015–

16 CRDC will be the most recently available data from the Common Core of Data (CCD) National 

Public Education Survey of Local Educational Agencies (LEA). The CCD is designed to be the 

Department of Education’s (ED) comprehensive statistical database of all public schools and 

school districts. Most of the data are obtained from administrative reports maintained by state 

educational agencies (SEA). The CCD survey is collected annually by the National Center for 

Education Statistics (NCES). The frame for the CCD survey includes regular, non-regular (special 

education, alternative, vocational, or technical), and public charter schools. The sample 

selection for the 2015–16 CRDC, if any, should occur before the beginning of the 2015–16

school year, in order to notify school districts of their selection. As a result, OCR will use the 

most recently available CCD data (possibly from the 2014–15 school year) as the basis for the 

CRDC sampling frame. 

For the CRDC and the CCD, an eligible school is defined as an institution that provides 

educational services and:

 has one or more grade groups (PK through grade 12) or is ungraded,

 has one or more teachers,

 is located in one or more buildings,

 has assigned administrator(s),

 receives public funds as its primary support, and

 is operated by an educational agency.

Note - For purposes of this definition, "public funds" includes federal, state, and local 

public funds. “Located in a building" does not preclude virtual schools since the 

administrators and teachers are located in a building somewhere. An “educational

agency" is not limited to the state or local educational agency, but can include other 

agencies (e.g., corrections or health and human services) charged with providing public 

education services.

Frame Additions and Deletions

While the CRDC definition of a school matches that used by the CCD, there are a few 

operational differences. In some instances, schools in the CCD are essentially administrative 

units that may oversee entities that provide classroom instruction, or the school in the CCD may 
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ICRAS	ICR	ID and	OMB	Number:	(XXXX.XXX)	1870-0504

Revised:	XX/XX/XXXX

RIN	Number:	XXXX-XXXX	(if	applicable)

provide funding or oversight only. The CRDC is primarily designed to collect data from public 

school districts about educational entities where students receive educational services for at 

least 50 percent of the school day, regardless of whether students are reported elsewhere for 

funding, accountability, or other reporting purposes. To be eligible to participate in the CRDC, 

schools must serve students at the site for at least 50 percent of the school year. Since the CCD 

and CRDC differ slightly in scope, some records are deleted, added or modified in order to 

provide better coverage and a more efficient sample design for the CRDC. The following types 

of school records are deleted from the CCD during the creation of the sampling frame: 

 District boundary type 2: Agency has closed with no effect on another agency’s 

boundaries

 School status 2: School has closed since the time of the last report

 Nonoperational school districts: School districts that do not operate a school

 Schools and school districts with a Federal Information Processing Standards (FIPS) state 

code of 58 (overseas DoD), 60 (American Samoa), 66 (Guam), 69 (Northern Marianas), 

72 (Puerto Rico), or 78 (U.S. Virgin Islands). 

Districts with no membership or missing membership at the district level are generally 

excluded, except in some special cases, such as where membership data were available for the 

associated schools. 

Note that if the most recent CCD data for use in the sampling frame are from the 2014-15 

school year, the CRDC will continue to include schools that are temporarily closed and may 

reopen in 3 years (status 6) and schools that may be operational within 2 years (status 7). 

Additionally, OCR augments the CRDC frame with justice facilities, which may not be under the 

purview of the SEA or an LEA. In collaboration with the Department of Justice Office for 

Juvenile Justice and Delinquency Prevention (OJJDP), OCR adds justice facilities which may not 

have been otherwise included in the CCD to ensure coverage of all youth in pre- or postadjudication facilities that receive educational services. For the 2015–16 CRDC, OCR plans to 

include the 50 largest juvenile justice detention facilities to further ensure the inclusion of 

these youth. Also, state-operated programs for special populations of students (such as schools 

for the deaf and schools for the blind) are added to the universe, if they are not already 

included in the CCD list. 

It is estimated that the sampling frame for the 2015–16 CRDC will contain approximately 18,000 

school districts. Below is the previous sample selection table used in planning for the 2013–14

CRDC:
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ICRAS	ICR	ID and	OMB	Number:	(XXXX.XXX)	1870-0504

Revised:	XX/XX/XXXX

RIN	Number:	XXXX-XXXX	(if	applicable)

Enrollment 

stratum

2011–12 Universe 

Total

1 – 300 4158

301 – 3,000 8969

3001 – 5,000 1416

5,001-25,000 1678

25,001 + 282

Response Rate

The CRDC has a traditionally high response rate due to the mandatory nature of the data 

collection. The typical response rate is between 98 and 100 percent. For the 2009–10 CRDC, 

100 percent of all participating school districts provided data. This represented 48 percent of 

all school districts serving students in 2009–10. For the 2011–12 CRDC, 98 percent of all 

participating school districts and 99 percent of all schools provided data. The anticipated 

response rate for the 2015–16 CRDC is expected to be no less than 98 percent of all 

participating school districts. 

2. Describe the procedures for the collection of information, including:

 Statistical methodology for stratification and sample selection

 Unusual problems requiring specialized sampling procedures

The 2015–16 CRDC will include a universe of all public schools and school districts. Therefore,

none of the sampling procedures (i.e., stratification, estimation, etc.) are proposed to be used 

in the 2015–16 CRDC administration. However, if budget constraints are such that a universe 

collection in 2015–16 is not possible, OCR will proceed as follows:

Statistical Methodology for Stratification and Sample Selection

The CRDC, which has collected data from school districts since 1968, has generally included a 

sample of approximately 6,000 school districts. For the 1976, 2000, and 2011–12 CRDCs, data 

were collected from a universe of school districts. In 2009–10, the sample size was increased to 

approximately 7,000 school districts, expanding the coverage to include all school districts with 

enrollments of over 3,000 students, long-term secure juvenile justice facilities, and stateoperated programs. The increased sample size provided a significantly more comprehensive 

picture of the access to equal educational opportunities for all students. 

For CRDC sample years since the 1998 CRDC, districts were selected using a rolling stratified 

sampling method that ensured a representative group from each state was included in the data 
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ICRAS	ICR	ID and	OMB	Number:	(XXXX.XXX)	1870-0504

Revised:	XX/XX/XXXX

RIN	Number:	XXXX-XXXX	(if	applicable)

collection. Under this design, each subsequent sample was selected in a way that minimized 

overlap with the preceding samples to the extent feasible. The procedures used to accomplish 

this objective are designed to avoid introducing biases and inefficiencies that would otherwise 

occur by simply excluding prior sample selections from the current sampling process. 

This approach used strata divided by size of district, and sub-strata of high/low minority students. 

For the 1998, 2002, 2004, and 2006 CRDC samples, strata were defined by the following school 

district enrollment sizes: 1-300 students, 301-3,000 students, 3,001-5,000 students, 5,001-25,000 

students, and over 25,001 students. The percentage of districts selected varied by state, 

inversely related to a factor based on the number of districts and the enrollment (i.e., states with 

fewer districts and students generally had a larger percentage selected to ensure adequate 

representation for statistical reliability). For the 2009–10 CRDC, OCR included all districts with 

more than 3,000 students. Additionally, some districts are always in the sample, such as all 

districts in states with fewer than 25 regular public school districts, school districts with more 

than 25,000 students and districts subject to federal court orders that are monitored by the U.S. 

Department of Justice. These “certainty districts” were removed from the sampling frame and 

the sample was drawn from the reduced sampling frame. All schools within selected districts 

were included in the CRDC sample.

In collaboration with NCES, OCR will review the past sample design to determine its adequacy in 

meeting the needs for state and national estimations of school and student counts. For the 

2015–16 CRDC sample, if any, OCR and NCES may consider alternative thresholds for stratum and 

sampling with certainty that are necessary to achieve reliable state and national estimations. 

Additionally, estimated percentages of particular student and school characteristics are an 

important feature of the CRDC. OCR and NCES will also collaborate on whether there is a need to 

oversample specific student populations or school types, such as charter schools, which are of 

interest to ED. The goal of the sample design will be to ensure sufficient numbers for precise 

state and national estimates. 

Based on currently available data for the 2011–12 SY, OCR estimates that the final 2015–16

CRDC sample, if any, will include no more than: 

 9,500 school districts, and

 86,000 schools.

Procedures for the Collection of Information: 

Verification and updates of school lists by selected LEAs: Fall 2015

Once selected for the CRDC, school districts are notified by standard mail of their required 

participation in the collection and asked to verify and update their listing of schools and provide 
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ICRAS	ICR	ID and	OMB	Number:	(XXXX.XXX)	1870-0504

Revised:	XX/XX/XXXX

RIN	Number:	XXXX-XXXX	(if	applicable)

a primary point of contact for the survey (previous letters are available at 

http://crdc.ed.gov/LEA/AdditionalResources.aspx). Links to survey questionnaires and 

supporting documents are also included in the initial mailing to school districts. A Web-based 

system is available to school districts to provide contact information for a principal point of 

contact. School districts may also verify their school list, add new schools that opened at the 

beginning of the 2015–16 school year, collapse schools that have merged, or remove schools 

that have closed. In past surveys, OCR has encountered discrepancies between the definitions 

of a school as held by the school district themselves and as reported by state departments of 

education to the CCD. This issue occurs most often in rural areas or in schools that offer grades 

K-12 in one building with one head principal. The schools often consider themselves one 

cohesive unit while the state does not. For accounting or other administrative purposes, the 

state may artificially split these schools by grade level and report them as two or three separate 

schools. For the purpose of CRDC, the K-12 school with one principal can be collapsed into one 

reporting entity and report all students enrolled in grades K-12. 

Follow-up for non-responding school districts begins approximately three weeks after the initial 

mailing. Telephone follow-up and reminder letters will be sent to school districts that do not 

provide a principal point of contact or verify their school list. 

Data collection by selected LEAs: Fall 2015-Summer 2016

After identifying a principal point of contact and a verified list of participating schools, OCR 

provides frequent training opportunities for school districts to understand the data elements 

collected on the CRDC and the survey submission process. Webinars, frequently asked 

questions and short tip sheets are circulated via email and posted to the CRDC informational 

website (crdc.ed.gov). This correspondence to school districts also serves as a reminder of their 

obligation to collect the required data over the course of the school year. A support center is 

available to school districts to call or email questions regarding the content of the data to be 

collected. During this time, training on preparing files for submission occurs. OCR has also 

provided pre-collection tools for school districts to gather and prepare flat files of the required 

data to prepare for the survey submission opening.

Survey Submission: Summer 2016

The survey submission window opens with email notification to all participating school districts. 

School districts are typically given a minimum of 3 months to submit their data to OCR. In 

anticipation of the survey submission system opening, OCR and its contractors provide webinar 

training on using the survey submission website beginning two weeks prior to opening and 

continuing three weeks after the opening of the survey submission system. These trainings are 

also posted on the CRDC informational website for school districts to access at any point during 
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ICRAS	ICR	ID and	OMB	Number:	(XXXX.XXX)	1870-0504

Revised:	XX/XX/XXXX

RIN	Number:	XXXX-XXXX	(if	applicable)

the data collection cycle. During the survey submission period, frequent communication occurs 

with participating school districts to offer technical assistance and, as the survey due date 

approaches, reminders are sent to school districts that have not yet certified their CRDC 

submission. 

 Estimation procedure.

If a sample is used for the 2015–16 CRDC, OCR will develop state and national estimations. As 

has been done in the past, after the 2015–16 collection, statistical estimations for most items 

will be calculated for the nation and for each state. To yield statistically sound conclusions for 

the universe, OCR will base the calculations on the methodology used for selecting the sample;

in-depth analysis of non-respondent school districts and/or schools; and missing items within 

surveys. Data will be weighted to compensate for schools that did not provide usable data and 

values will be imputed on an item-by-item basis to compensate for item non-response. Final

weighting and estimations procedures will be dependent on the sample selection plan for the 

2015–16 CRDC. 

Calculation of weights 

In past CRDC samples, school districts were weighted by the inverse of the probability of 

selections. School and school district weights were then adjusted based on final item and 

survey response rates and any other sampling considerations that arose after the sample was 

drawn. For the 2015–16 CRDC, if a sample is used, replicate weights will be attached to each 

surveyed school so that the weighted data will represent state and national totals. The final, 

adjusted weights used to estimate state and national student count totals will ensure that the 

sum of the weighted membership data (DG979) matches the number of students derived from 

the 2015–16 CCD public school universe file. 

 Degree of accuracy needed for the purpose described in the justification.

Accuracy

The CRDC is intended to collect information about educational equity and excellence in public 

elementary and secondary education. Although respondents are experts in the educational 

opportunities and participation in their school districts, there are opportunities for potential 

error, either through technical mishap or misinterpretation of the intent of a survey item. Over 

the course of several CRDC administrations, OCR has developed and continues to develop a 

series of checks designed to flag these errors for review by the respondent and OCR. These 

edits rely on internal logic checks, consistency within specific tolerances, and comparisons to 

similar data collected by other program offices within ED.
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ICRAS	ICR	ID and	OMB	Number:	(XXXX.XXX)	1870-0504

Revised:	XX/XX/XXXX

RIN	Number:	XXXX-XXXX	(if	applicable)

Imputations

Because the CRDC is a mandatory collection, respondents are required to provide data for each 

applicable item. (See Attachment A-4 for more details about how directional indicators are 

used to determine item applicability.) In rare cases, a school district may not be able to 

respond with complete and accurate data to a specified item. When there is item nonresponse, 

the item may be imputed for the 2015–16 CRDC reporting of state and national totals.

 Any use of periodic (less frequent than annual) data collection cycles to reduce 

burden.

The Department has historically conducted this survey biennially to reduce burden. 

3. Describe methods to maximize response and to deal with issues of non-response. 

The accuracy and reliability of information collected must be shown to be adequate 

for intended uses. For collections based on sampling, a special justification must be 

provided for any collection that will not yield “reliable” data that can be generalized to 

the universe studied.

Historically, the civil rights survey has had a very high response rate. In 2000, the predecessor 

Elementary and Secondary School Civil Rights Compliance Report (E&S Survey) was sent to a 

universe of all school districts and schools in the United States. The overall response rates were 

97 percent of all school districts and 99 percent of all schools. The overall response rates for 

the 2002 E&S Survey were 98 percent for school districts and 98 percent for schools. For the 

2004 CRDC, the response rates, including partial respondents to the data collection, were 

approximately 97 percent of all districts, and 97 percent of all schools. The 2006 CRDC achieved 

an unprecedented 100 percent response rate for school districts and a 99.6 percent response 

rate for schools. The 2009–10 CRDC achieved a response rate of 100 percent of school districts, 

and 100 percent of schools. The 2011–12 CRDC achieved a response rate of 98 percent of 

school districts and 99 percent of schools.

Methods to maximize response rates

Frequent communications occur with participating school districts over the course of the data 

collection to ensure compliance with this statutorily mandated collection. School districts are 

notified by standard mail of their obligation to report. In addition, frequent email 

correspondence occurs with the school district’s primary point of contact regarding technical 

assistance available to support the school districts submitting the required data, reminders of 

upcoming deadlines, and notifications if the CRDC was not submitted by the due date. If school 

districts fail to respond in a timely manner, the contractor for the data collection, with 
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ICRAS	ICR	ID and	OMB	Number:	(XXXX.XXX)	1870-0504

Revised:	XX/XX/XXXX

RIN	Number:	XXXX-XXXX	(if	applicable)

assistance from OCR and its field offices as necessary, provides extensive outreach and 

assistance to the greatest extent possible until the districts respond, or the final deadline for 

accepting data has passed. The superintendents of non-responding school districts are also 

contacted by phone, email, and standard mail. This has proven to be very successful in past

years.

4. Describe any tests of procedures or methods to be undertaken. Testing is 

encouraged as an effective means of refining collections of information to minimize 

burden and improve utility. Tests must be approved if they call for answers to 

identical questions from 10 or more respondents. A proposed test or set of tests may

be submitted for approval separately or in combination with the main collection of 

information.

OCR plans to test the data collection procedures and data items described in this submission in 

a number of ways. Many of the data elements requested have already been collected in the 

previous 2011–12 CRDC and 2013–14 CRDC. However, data quality is an overriding concern 

that OCR continues to assess and evaluate. OCR and NCES are assessing relevant data from 

CRDC survey years to evaluate the internal and external consistency and reliability of the 

reported data to continuously improve the business rules and edit checks used in the survey 

submission system. Edit checks currently help to identify potential problems and provide 

opportunities for school districts to correct possible mistakes before certifying the accuracy of 

their submission. 

To support continued improvement of data quality in school districts and ensure the 

procedures for the survey are designed to minimize the burden on sampled schools and 

districts, OCR and NCES partnered in the development of an enhanced survey submission 

system for the 2013–14 and 2015–16 data collections. The redesigned submission system will 

build on improvements made in the 2009–10 and 2011–12 collections that enhanced the ability 

of school districts to provide partial flat files and improved data accuracy. OCR and NCES plan 

to test and pilot the survey submission system in a number of ways. 

Content. 

The proposed data elements include: 1) both items that were required for the 2011–12 CRDC 

and 2013–14 CRDC and, 2) new items that were previously approved for as optional items for 

the 2013–14 CRDC and mandatory items for the 2015–16 CRDC. In preparation for the building 

of the redesigned submission system, ED conducted recordkeeping visits with school districts to 

determine whether and how they presently collect data for the new mandatory and optional 

data groups. These sites reflected a diverse set of districts in terms of size, urban/city, level of 

sophistication of SEA and LEA data systems, and programs offered. These site visits were done 

in conjunction with NCES and under a separate OMB clearance package. These visits also 
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ICRAS	ICR	ID and	OMB	Number:	(XXXX.XXX)	1870-0504

Revised:	XX/XX/XXXX

RIN	Number:	XXXX-XXXX	(if	applicable)

gathered information on ways in which the survey collection tool assisted in improving data 

quality through edit checks and other analytical procedures. Additionally, ED explored the 

feasibility of conducting up to 20 one-on-one cognitive interviews with SEA, LEA, and/or school 

respondents to validate proposed item wording. These interviews were conducted by phone 

and in person, as appropriate. 

Survey Tool. 

OCR and NCES developed an enhanced survey collection tool for the 2013–14 CRDC and 2015–

16 CRDC. Testing plans for the tool closely mirror previous CRDC protocols. For the 2009–10 

CRDC, ED invited several members of the CRDC technical working group to participate in some 

of the initial discussions with the contractor about layout and features of the tool. ED also pilot 

tested the online survey tool with LEAs prior to opening the survey tool for submissions by 

LEAs. The pilot LEAs had access to the online survey tool for five business days, during which 

the LEAs responded to the CRDC, entering previous-year or fictitious data, at their choice. For 

the 2013–14 CRDC, ED invited school districts that participated in site visits, several members of

the CRDC technical working group, and SEAs that planned to pre-populate data elements for 

LEAs to participate in some initial discussions with the contractor about various features of the 

tool. ED also pilot tested the online survey tool for data submission with LEAs and SEAs. The 

pilot period lasted about two months.

For the 2015–16 CRDC, ED plans to expand the pilot to include approximately 40-50 LEAs who 

will have access to the survey software for a period of no less than ten business days. ED will 

work with its selected contractor to compile LEA suggestions, categorized by level of criticality 

and feasibility. Based on these results, ED will identify changes, such as text refinements, and 

any critical technical issues for correction and resolution prior to the opening of the survey tool 

for all participating LEAs. 

5. Provide the name and telephone number of individuals consulted on statistical 

aspects of the design and the name of the agency unit, contractor(s), grantee(s), or 

other persons who will actually collect and/or analyze the information for the agency.

OCR has consulted with NCES regarding the preliminary plans for a sample for the 2015–16

CRDC. However, OCR intends the 2015–16 collection to be a universe of public schools and 

school districts. If budget constraints are such that a universe collection for the 2015–16 CRDC

is not possible, OCR will work closely with NCES to finalize the sample selection plan and submit 

it to OMB for review and approval.