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SUPPORTING STATEMENT FOR REQUEST FOR OMB APPROVAL UNDER THE 

PAPERWORK REDUCTION ACT

A. JUSTIFICATION

1. Circumstances necessitating information collection.

Section 618 of the Individuals with Disabilities Education Act (IDEA), Public Law 108-

446, directs the Secretary of Education to obtain data on: (1) the number and percentage 

of infants and toddlers with disabilities, by race, ethnicity, and gender, who are receiving 

early intervention services; (2) the number and percentage of infants and toddlers, by race 

and ethnicity, who are at risk of having substantial developmental delays (as described in 

Section 632), and who are receiving early intervention services under Part C; and (3) the 

number and percentage of children with disabilities, by race, ethnicity, and gender, who, 

from birth through age 2, stopped receiving early intervention services because of program 

completion or for other reasons. The specific legislative authority for these data 

collections may be found in Section 618(a)(1)(B), Section 618(a)(1)(C), Section 618(a)(2) 

and Section 618(a)(3). 

The purposes of such data are: (1) to assess the progress, impact, and effectiveness of 

State and local efforts to implement the legislation and (2) to provide Congress, the public,

and Federal, State, and local educational agencies with relevant information. OSEP also 

uses these data for monitoring activities, planning purposes, congressional reporting, and 

disseminating data to individuals and groups.

Legislative authority in Section 618 of IDEA requires that:

"(a) IN GENERAL- Each State that receives assistance under this part, and the Secretary

of the Interior, shall provide data each year to the Secretary of Education and the public on 

the following: 

(1)(B) The number and percentage of children with disabilities, by race, gender, 

and ethnicity, who are receiving early intervention services. 

(C) The number and percentage of children with disabilities, by race, gender, and 

ethnicity, who, from birth through age 2, stopped receiving early intervention 

services because of program completion or for other reasons. 

(2) The number and percentage of infants and toddlers, by race, and ethnicity, 

who are at risk of having substantial developmental delays (as defined in Section 

632), and who are receiving early intervention services under part C. 

(3) Any other information that may be required by the Secretary”.

In addition to the specific data requirements described in Section 618, other provisions of 

IDEA address the need to examine where services are provided for infants and toddlers 

with disabilities. Section 635(a) specifies that:
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“(a) IN GENERAL-A statewide system described in section 633 shall include, at a 

minimum, the following components:

(16) Policies and procedures to ensure that, consistent with section 636(d)(5)--

(A) to the maximum extent appropriate, early intervention services are 

provided in natural environments;”

An additional provision of IDEA addresses the flexibility of serving children 3 years of 

age until entrance into elementary school. Section 635(c)(3) specifies that: 

“If a statewide system includes a State policy described in paragraph (1), the State 

shall submit to the Secretary, in the State’s report under section 637(b)(4)(A), a 

report on the number and percentage of children with disabilities who are eligible 

for services under section 619 but whose parents choose for such children to 

continue to receive early intervention services under this part.” 

Section 637(b)(4)(A) specifies that:

Each State shall provide for “making such reports in such form and containing such 

information as the Secretary may require to carry out the Secretary’s functions under this 

part.” This clearance package includes three data collection forms. Each form provides 

instructions and information for States when submitting their data. Table 1 provides the 

data required by Section 618(a)(1)(B) and Section 618(a)(2).

 Section A collects the number children with disabilities by the child’s age and 

race/ethnicity. 

 Section B collects the number of children with disabilities by the child’s gender. 

 Section C collects the number of infants and toddlers who are at risk of having 

substantial developmental disabilities, by the child's age and race/ethnicity. This 

count is a subset of the children reported in Section A and is completed only by

States that serve at-risk infants and toddlers. 

 Section D collects the cumulative count of the number of infants and toddlers with 

disabilities who received early intervention services during the most recent 12-

month period by child’s race/ ethnicity.

 Section E collects the cumulative count of the number of infants and toddlers with 

disabilities who received early intervention services during the most recent 12-

month period by child’s gender.

Because IDEA requires each State to report the percentage of children with disabilities, by

race, gender, and ethnicity and the percentage of at-risk infants and toddlers by race and 

ethnicity, Table 1 also includes cells for these percentages. However, to assure cross-state 

comparability and minimize State burden, these percentages will be calculated by the data 

collection software. To accommodate the flexibility of Section 635(c), additional data 

collection elements are included in Table 1 (child count) to collect counts of children age 

3 and older, by age, race/ethnicity, and gender. See sections A2 and B2 of Table 1. 
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Table 2 collects information about the settings in which early intervention services are 

provided to the children reported on Table 1. 

 Section A collects primary setting of infants and toddlers according to the child’s 

age. 

 Section B collects the primary setting according to the child’s race/ethnicity. 

Each child reported in Table 2 is reported in only one setting. To accommodate the 

flexibility of Section 635(c), additional data collection elements are included in Table 2 

(settings) to collect counts of children age 3 and older according to their primary service 

setting, by age and race/ethnicity. See sections A2 and B2 of Table 2.

Table 3 provides the data required by Section 618(a)(1)(C), the number and percentage of 

infants and toddlers with disabilities who, from birth through age 2, stopped receiving 

early intervention services. 

 Section A collects the reason for no longer receiving services according to the 

child's race/ethnicity.

 Section B collects the reason for no longer receiving services according to the 

child's gender.

As in Table 1, Table 3 includes cells for percentages that will be calculated by the data 

collection software. To accommodate the flexibility of Section 635(c), additional data 

collection elements are included in Table 3 to collect counts of the number of families of 

children who chose to take advantage of the flexibility, by race/ethnicity and gender. See 

row 3 of Sections A and B of Table 3.

2. Use for which the information is gathered.

OSEP uses the information collected on these forms to assist in establishing programmatic 

priorities (such as promoting services in the natural environment), to monitor States to 

ensure compliance with the Federal statute and regulations, including the State’s Annual 

Performance Report under each State’s Performance Plan required by Section 616 of 

IDEA, and to disseminate data to Congress and the public. These data are also used to 

measure progress under the performance indicators established by OSEP under the 

Government Performance and Results Act (GPRA; P.L. 103-62) for early intervention 

services. 

3. Use of improved information technology.

OSEP will collect the data electronically through the EDFacts Metadata and Process 

System (EMAPS) from State agencies. EMAPS is an established submission system that 

State agencies have been using to submit information to the Department for several years. 

EMAPS allows each State agency to provide the data in the non-proprietary, electronic 

formats that could be generated through automated processes within the State agency. The 

EMAPS surveys include a number of data edits to improve data entry validity. For 
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example, as States enter their data, the edits flag relationships between the counts reported 

that are impossible (e.g., situations where 150 African American infants and toddlers with 

disabilities are reported in Section A of Table 1 but only a total of 100 infants and toddlers 

with disabilities are reported in Section B of Table 1). The use of a survey with built-in 

edits reduces the number of follow-up contacts with the States after the data are submitted. 

Additionally, the EMAPS surveys auto-calculate totals and subtotals where appropriate to 

minimize reporting burden on the State. Finally, the surveys provide space for States to 

comment on their data, for example providing additional information about how the data 

were aggregated, what changes were made to these procedures since the last data report, 

how changes in state policy or legislation affect the data, or other issues the State believes 

are applicable to the data collection. 

4. Efforts to identify duplication.

The information collected on the forms does not represent any duplication of paperwork, 

content, reporting, or performance requirement beyond that imposed under the statute. 

This information is only available from State agencies. There is currently no other source 

of national information on the number of infants and toddlers receiving early intervention 

services, on the settings in which they receive services, or on infants and toddlers who are 

no longer receiving Part C services.

5 Small businesses.

The information requested does not involve the collection of information from entities 

classified as small organizations.

6. Consequence of less frequent collection.

P.L. 108-446, Section 618(a) requires: "Each State that receives assistance under this part, 

and the Secretary of the Interior, shall provide data each year to the Secretary of Education 

and the public..."

7. Special circumstances.

There are no special circumstances associated with these data collections.

8. Federal Register notice/consultation outside the agency.

Interested persons were invited to comment on this proposed information collection 

request in a notice published in the Federal Register, Volume 79, No. 117 on June 18, 

2014. The Department of Education expressed interest in public comment addressing five 

specific issues including: is this collection necessary to the proper functions of the 

Department; will this information be processed and used in a timely manner; is the 

estimate of burden accurate; how might the Department enhance the quality, utility, and 

clarity of the information to be collected; and how might the Department minimize the 

burden of this collection on the respondents, including through the use of information 

technology. The Parties were informed that their comments would be accepted on or 

before August 18, 2014. 
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In response to this request, the Department of Education received one general comment 

from one commenter relevant to the Table 1 form. The comment is summarized below, 

followed by the Department’s response. 

General comment: The commenter supported the proposed changes to require States to 

report the cumulative count of infants and toddlers with disabilities, ages birth through 2, 

who received early intervention services during a 12-month period by race/ ethnicity and 

by gender. However, the commenter expressed concern over States being required to 

report a cumulative count of infants and toddlers with disabilities by discrete age. The 

commenter noted that it would be difficult for a State to identify a discrete age for a child

when the child falls within two different discrete ages during the same 12-month period. 

The commenter suggested that the Department collect cumulative counts by birth cohorts, 

instead of discrete ages, if we want to capture this information under the cumulative count. 

Discussion: The Department appreciates the commenter’s support for the Department to 

collect the cumulative count of infants and toddlers with disabilities, ages birth through 2, 

who received early intervention services during a 12-month period by race/ethnicity and 

by gender. The Department agrees with the commenter that providing instructions and 

technical assistance on reporting the cumulative count by discrete age would be 

challenging. The Department has removed the discrete ages from section D of Table 1. 

The Department will continue to collect the number of children receiving early

intervention services as of the state-designated child count date by discrete age in section 

A of Table 1. 

Changes: Based on the comment received, OSEP removed the proposed requirement for 

States to report the cumulative count of infants and toddlers with disabilities by discrete 

age in section D of Table 1.

9. Payments of gifts to respondents.

No payments or gifts are provided to respondents for completing this information request.

10. Assurance of confidentiality.

No assurance of confidentiality is provided to respondents. 

11. Questions of a sensitive nature.

There are no questions or requirements of a sensitive nature contained in the forms.

12. Estimate of respondent burden.

Estimating burden is difficult for the Part C program because of variations in the 

availability and sophistication of computerized data collection systems and the difficulty

of collecting information across participating agencies. OSEP developed the burden 

estimates based on previous experience with each data collection, the information 

available about State data collection systems, and through consultation with 
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representatives of several State agencies. In calculating the average burden, we applied 

different burden estimates based on whether or not the State agencies use individual child 

record systems to collect these data. The estimate of total respondent burden is based on 

56 reporting entities1.

The estimated burden for Table 1 (count of infants and toddlers served) is 42 hours per 

State agency or 2,350 hours total.

 

1

56 reporting entities refer to: 50 States, District of Columbia, Puerto Rico, Virgin Islands, American Samoa, Guam, and 

Northern Marianas.

2 Total burden is based on averages rounded to the hour.

Number of

Respondents

Burden 

Hours

Total

Burden 

Hours2

37 States with Individual Child 

Record Systems

34.5 hours 1,276.5 hours

19 States without Individual 

Child Record Systems

56.5 hours 1,073.5 hours

56 States142

(Avg.)

2,350 hours
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The estimated burden for Table 2 (settings) is 23.9 hours per State agency or 1,336 hours 

total. 

Number of

Respondents

Burden 

Hours

Total

Burden 

Hours2

37 States with Individual Child 

Record Systems

13 hours 481 hours

19 States without Individual 

Child Record Systems

45 hours 855 hours

56 States123.9

(Avg.)

1,336 hours

The estimated burden for Table 3 (exiting) is 50.3 hours per State agency or 2,815 hours 

total. 

Number of

Respondents

Burden 

Hours

Total

Burden 

Hours3

37 States with Individual Child 

Record Systems

35 hours 1,295 hours

19 States without Individual 

Child Record System

80 hours 1,520 hours

56 States3 50.3

(Avg.)

2,815 hours

OSEP estimated respondent costs as $20 per hour. The total number of burden hours 

across all three tables is estimated at 6,501. Therefore, the estimated cost to the 

respondents is $130,020.

13. Estimate of cost to respondent.

There are no additional costs other than the cost burden identified in 12. 

14. Estimate of costs to the Federal Government.

OSEP estimates the cost of maintaining and updating the databases for the Part C Child 

 

3

Total burden is based on averages rounded to the hour.

3

56 States and Outlying Areas refer to: 50 States, District of Columbia, Puerto Rico, Virgin Islands, American Samoa, Northern 

Marianas, and Guam.
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Count, Settings, and Exiting data collections to be $82,000 in contractor data services. 

15. Reasons for program changes or adjustments.

There is a program adjustment increase of 514 hours of response burden for respondents. 

This increase is due to the submission of new data elements related to the cumulative 

count of infants and toddlers receiving services under Part C of IDEA in Table 1. This 

cumulative count will provide OSEP with a more accurate count of how many infants and 

toddlers are receiving early intervention services under Part C of IDEA during a 12-month 

reporting period. These data will be used to better understand the number and 

characteristics of infants and toddlers receiving services under Part C of IDEA at anytime 

during a 12-month reporting period for monitoring purposes and to better evaluate the 

impact of the Part C program.

There is an increase in the estimated cost associated with this information collection 

package from $22,310 to $82,000. This increase is due to collecting these data via 

EMAPS. Slight adjustments were made to the instructions of these data collection forms 

to clarify the process for submitting these data via EMAPS. We anticipate no change in 

the response burden associated with these adjustments to the data collections.

Based on a public comment received, OSEP eliminated the requirement for States to 

report the cumulative count of infants and toddlers receiving services under Part C of 

IDEA by discrete age in the data collection instrument. This program change decreases

the reporting burden previously stated in the Supporting Statement published during the 

60-day public comment period by 196 hours.

16. Plans for tabulation and publication.

OSEP will tabulate and display the information submitted by States in a variety of ways. 

The primary vehicles of distribution are through the Secretary's Annual Report to 

Congress (P.L. 108-446, Section 664(d)(2)) and through publication of these data on the 

Internet. OSEP will also use this information for the purposes of monitoring, GPRA 

performance reports, focusing discretionary activities, guiding policy development, and 

suggesting topics for model demonstration projects. Occasionally, the data are 

summarized and presented at conferences, in ad hoc reports or articles submitted for 

publication, and in speeches by senior officials. 

17. Display of OMB expiration date.

The OMB expiration date will be displayed on the forms.

18. Exceptions to the certification statement.

There are no exceptions to the certification statement.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection of information does not permit the use of statistical methods in submission of data 

to the Department of Education.