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Highly Qualified Teacher Data Collection 

Response to Public Comments 

30-day OMB Comment Period

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

Teacher (HQT) Collection through EDFacts submitted during the 30-day public comment period.

The 30-day comment period for the HQT Collection clearance package closed on April 18, 2014. 

The U.S. Department of Education (ED) received a total of 6 comments from 6 commenters. Three

comments came from state educational agencies (SEAs). Three comments came from associations. 

Four of the six commenters also commented on the 60-day clearance package for the HQT 

Collection. One commenter expressed appreciation for the updates that were made to the clearance 

packaged based on the comments from the 60-day clearance package.

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

package and in composing thoughtful comments. The comments were organized into two sections: 

those generally pertaining to the HQT Collection and those pertaining to guidance on the data to be 

submitted. In addressing the public comments, ED continued its focus on moving EDFacts forward in 

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

data suppliers. No changes to the collection package were made based on the six comments 

submitted.

Section 1 - Comments Pertaining to the HQT Collection

Topic Comment Summary ED Response

Data Quality  The lack of asking for total number of 

teachers in the state and total number of 

non-HQT teachers could result in 

inaccurate results.

 To report the required data, CDE must 

merge data from CDE and California 

Commission on Teacher Credentialing. 

There is a high likelihood that matching

these data will not yield reliable results.

It is the responsibility of the state to submit 

valid and reliable data. The time frame in 

which the report to Congress is due does not 

allow time for states to develop a method to 

collect the data in a way that would yield

more accurate and reliable results. ED will 

conduct a basic data quality review of the data 

files submitted to evaluate timeliness and 

completeness prior to preparing the required 

report to Congress. Any data quality concerns 

detected will be noted in the report to 

Congress.

Burden  Not being able to use the normal data 

collection to provide these data requires 

extra effort.

ED must collect and use these data to meet the 

requirements within the CR. States are 

encouraged to collect the required data using 

the means and methods most efficient for the 

state.

 Supporting Statement A may overestimate 

the burden on states and LEAs. Some 

states, such as California, have the data.

One commenter suggests that burden 

estimates may be high since some states, such 

as California, already have the required HQT 
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Topic Comment Summary ED Response

 The cost of the collection is $0.10/student, 

an acceptable cost to learn the prevalence of 

high-need students being taught by highly 

qualified who are enrolled in an alternative 

route to certification program.

data. As noted in the Availability of Data row, 

below, California establishes that it does not 

have the required data and will have to derive 

it from existing data. The SEAs assessments 

of their capacity is in conflict with some 

organizations’ statements that the data are 

readily available and require little burden to 

collect. 

Availability

of Data

 Colorado will not be able to provide the 

requested data for Title III language 

instruction (question (5) and (6)). This is 

because Colorado does not verify the HQ 

status of ELL teachers unless they are 

providing core content instruction.

 The required data are not readily available. 

California reports its HQT data in the unit 

of core academic classes and will have to 

figure out how to convert that unit into 

FTEs.

 California cannot meet the due date of June 

30, 2014, but plans to submit the data by

September 30, 2014.

 California data for special education HQT 

providing instruction to infants and 

toddlers are not available.

 California data for special education HQT 

providing educational services to private 

schools are not available.

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. States should report to 

the best of their ability the data required.

All states currently report annually the 

number of personnel in FTEs for special 

education teachers, paraprofessionals, and 

related services personnel at the state and 

district level to meet IDEA reporting 

requirements. ED recommends that the state 

consult with the EDFacts Coordinator and 

Special Education program office to review 

current reporting methods for other 

collections using FTEs. 

Collection 

Level and 

Method

 The current criteria for determining 

whether a school or district serves a 

significant sized population of low-income 

students are flawed and will result in an 

under identification of high schools serving 

low-income students. The commenter 

suggests using the provision s of ESEA 

section 1113(a) to identify low-income 

high schools.

 The current poverty threshold of 75 percent 

Free and Reduced Price Lunch (FRPL)

participation will result in an underidentification of high schools serving 

ED understands the importance of including 

in its data analysis high schools that serve 

high-poverty populations, and not underidentifying such high schools. ED will take 

the commenters’ suggestions into 

consideration as it prepares to identify high 

schools serving high-poverty populations for 

purposes of preparing the report to Congress.

ED will not revise its data collection as a 

result of these comments because they relate 

to analyses of existing data, not to the 
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Topic Comment Summary ED Response

significant-sized populations of low-income 

students

 The poverty rate for high schools should be 

determined using the higher of the 

measures included in Section 1113(a)(5) of 

the Elementary and Secondary Education 

Act (ESEA) or the “feeder pattern” 

(determined by applying the average 

percentage of students in low-income 

families of the elementary or middle school 

attendance areas that feed into the 

secondary school to the number of students 

enrolled in such school).

proposed new collection.

 Teacher data should be collected at the 

school-level to give better insight to the 

number of teachers in training in Title I and 

rural schools. To do so, add the following 

data points:

o # of highly qualified teachers teaching 

in Title I schools

o # of highly qualified teachers teaching 

in Title I schools who are currently 

enrolled in an alternative route to 

certification program

o # of highly qualified teachers teaching 

in rural schools

o # of highly qualified teachers teaching 

in rural schools who are currently 

enrolled in an alternative route to 

certification program.

 The proposed collection is for teacher data 

versus the student data requested by

Congress, limiting the ability to examine 

the equitable distribution of teachers-intraining

The proposed data collection includes HQT 

data maintained at the state and LEA levels. 

One commenter 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 shortly 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). 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 

one-year collection to estimate the figures 

using already collected school-level locale 

and poverty data within each district, rather 

than significantly increasing burden by
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Topic Comment Summary ED Response

expanding this collection to the level of the 

individual school. ED believes that these data 

could enable valuable cross-LEA 

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 “lowincome” or “rural.” While ED is aware of the 

limitations of using both the locale codes and 

the FRPL data, ED believes 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 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.

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ED believes 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.

Timeliness  Because of ED’s delay in implementing the 

directives of the CR, the deadline for the 

As ED began working to collect the data 

required in the CR, it confirmed that the data 

 

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See http://nces.ed.gov/programs/coe/indicator_clb.asp for information on how FRPL programs vary.
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Topic Comment Summary ED Response

Congressional report will not be met and 

Congress and the public will have to wait 

an extra year to get the needed data

were not readily available within most SEAs. 

ED has worked steadily to identify a 

collection methodology that will provide 

Congress with relevant information regarding 

the prevalence of students receiving 

instruction from teachers who are highly 

qualified while enrolled in an alternative route 

to certification program, while not being 

overly burdensome to collect. ED plans to 

submit a report to Congress in 2014 instead of 

December 2013.

Transparency

and Use

 The data collection should be made 

available to the public via a searchable 

database containing district- and state-level 

data

 The following data should be provided to 

give context to the HQT data collection:

o The data in raw numbers and 

percentages

o The number and percentage of students 

overall, and by subgroups at the SEA 

and LEA levels

o The total number and percentage of 

teachers not highly qualified

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.

 The collection is limited in its usefulness 

because it doesn’t include data on the 

effectiveness of traditional certification 

programs and alternative route to 

certification programs.

 The collection would be more useful if it 

distinguished between teachers 

participating in high-quality alternative 

routes to teaching programs versus those 

participating in programs that do not 

provide high-quality support.

 It would be insightful to collect data on 

which programs meet the legal 

requirements for providing high-quality

support.

Including data on the effectiveness of 

traditional certification programs, and 

distinguishing programs based on quality goes 

beyond the scope of the requirements of the 

CR. ED does not have the authority to expand 

the scope of this data collection, an action that 

would also increase reporting burden.

Schools to be  Specify that the data collection includes all The proposed data collection does not exclude 
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Topic Comment Summary ED Response

Included charter, alternative, and online schools 

operating within the LEA.

 Specify that online and other alternative 

schools are to be included in the data 

collection.

charter schools and LEAs, alternative schools, 

or online schools operating with an LEA. 

Therefore they are included in the data 

collection. This clarification will be included 

in the file specification used to submit the 

data.

Section 2 - Comments Pertaining to Guidance for the HQT Collection

Topic Comment Summary ED Response

Who is 

HQT?

 Is the data to be reported for teachers 

deemed HQT based on their license or by

their assignment?

 Identify which entity has responsibility

for determining whether a teacher is 

HQT, according to the criteria listed in 

question 4 of Attachment B, and provide 

that entity with guidance on determining 

what is “high-quality professional 

development,” “intensive supervision,” 

and “regular ongoing support.”

The designation of a teacher as highly qualified 

is determined first by licensure and then by 

assignment. A teacher who is licensed but 

teaching outside of his or her subject matter 

expertise would not be designated as highly 

qualified. Report only FTEs for teachers teaching 

a course for which they are highly qualified to 

teach. 

Designations of a teacher as highly qualified are 

to be made by the office within an SEA or LEA 

that currently determines the HQT status of the 

district or state’s educators. In its guidance on 

highly qualified teacher policy, the Department 

answers what is high quality professional 

development: 

The term “high-quality professional 

development” means professional development 

that meets the criteria contained in the 

definition of professional development in Title 

IX, Section 9101(34) of ESEA. Professional 

development includes, but is not limited to, 

activities that:

 Improve and increase teachers’ knowledge 

of academic subjects and enable teachers to 

become highly qualified;

 Are an integral part of broad schoolwide 

and districtwide educational improvement 

plans;

 Give teachers and principals the knowledge 
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Topic Comment Summary ED Response

and skills to help students meet challenging 

State academic standards;

 Improve classroom management skills;

 Are sustained, intensive, and classroomfocused and are not one-day or short-term 

workshops;

 Advance teacher understanding of effective 

instruction strategies that are based on 

scientifically based research; and

 Are developed with extensive participation 

of teachers, principals, parents, and 

administrators.

Data for non 

HQ 

Teachers

 Should information be submitted for 

non-HQ teachers in alternate route to 

certification programs?

No, data for non-HQT teachers do not need to be 

submitted, regardless of the non-HQT teachers’

participation in an alternate route to certification 

program.

HQ Status 

mixed by

assignment

 How do you account for teachers in 

alternate route to certification programs 

who are HQ in some but not all classes 

they teach?

 Are special education teachers counted in 

question 3 (# of special education HQTs) 

regardless of their class assignments for 

which some the teacher may not be 

HQT?

Count and report only teachers who are highly

qualified in a class they teach. If a teacher is 

highly qualified for only a portion of the classes 

he or she teaches, use in the count a partial FTE 

representing that portion. For example, if a 

teacher is highly qualified for half the classes he 

or she teaches, the count would be 0.5 FTE. 

Since ED is not collecting data on non-HQT 

teachers, no reporting is required for the same 

teachers who are not highly qualified for another 

class they teach.

Which 

schools are 

included?

 Specify that the data collection includes 

all charter, alternative, and online 

schools operating within the LEA.

The data collection includes all schools with 

membership.