**GENERAL**

Comment : S everal data tables should be updated to coincide with the budget data tables. Discussion : The data tables as presentl y constituted meet the U.S. Department of Education (Department) guidelines and creating additional tables would increase burden for grantee s without producing any supplemental benefits to the projects. Change : None. Comment : The Department should change the Annual P erformance R eport (APR) due date as April is not an ideal time for submission

. Discussion: While the Department agrees that April is not an ideal due date , the p rogram o ffice needs time to review each report and make non

- competing continuation awards prior to the beginning of the next project year. This could not be accomplished by changing the APR due dat e to the end of the school year . Change: None. **NARRATIVE INFORMATION** Comment : The Department should change the layout of the Program Objectives T able from portrait to landscape to make the table more conducive for reporting data. Discussion : The Program Objectives Table is in Microsoft Word

. Grantees currentl y have the option to change the page layout from portrait to landscape to accommodate their data. Change : None. **DEMOGRAPHIC DATA AND DATA REGARDING SERVICES PROVIDED** Comment : H ow does the Departm ent defines who is a “new” and who is a “continuing” GEAR UP student ? Discussion : GEAR UP grant ee s using the Cohort Model can serve students as earl y as Kindergarten as long as the school s served have a 7 th grade. This also applies to State grant ee s using the Cohort Model. State grant ee s using the Priority Student Model can serve any secondary school student who meets the defined criteria. For State or Partnership grant ee s using the Cohort or Priority Student Model , a new GEAR UP student is defined as a student who is receiving GEAR UP services for the first time during the reporting period. A continuing student is defined as a student who received GEAR UP services in the prior reporting period.Comment : The Department should collect richer information on the number of GEAR UP

students with Limited English Proficiency (LEP) and Individualized Education Programs (I EP) and how those students are being served. Discussion : Completion of the tables that collect data o n services provided to students with LEP and students with IE Ps , although useful, is not required by the Department

. Change : None. Comment : State Grantees should be required to list the ir participating schools. Similarly , National Center for Educational Statistics (NCES) I dentification (ID) Number s for both State and Partnership grantees should be collected as well

. Discussion : The Department agrees and has implemented both of the recommended changes. Change : State grantees are now required to list the ir participating schools. State and Partnership grantees are required to list the NCES ID numbers of participating schools. Comment : The Department APR should provide operational and consistent definitions for services required under the Higher Education Opportunity Act (HEOA). Discussion : The Department will define rigorous academic curricula and comprehensive mentoring in the revised APR , in accordance with the HEOA changes

. The remaining required and recommended services will be deliberately undefined to allow grantees the flexibility in adminis tering the services to students and parents. Change : None. Comment : The heading in a data table should be modified from stating parents to stating “families/guardian(s)” , as many students do not live in a traditional home. Discussion : The Department agrees with the recommendation. The Department realizes that many GEAR UP students currentl y reside in non - traditional family units and the APR should capture their living arrangements. Change : In addition to the word parents, families and guardian ( s ) will b e included.**GEAR UP STUDENT OUTCOMES** 

Comment : The variables listed in the Student Enrollment in Courses by Grade Level Table should be aligned with the variables contained in the Courses Completion Table. Discussion : The Department agrees with the recommendation . Capturing the same variable in both tables will streamline the information listed in the Enrollment and Completion Tables. Change : The Student Enrollment in Courses by Grade Level Table has been revised to correspond with the Courses Completion Table. In addition, the Department will include an additional column for English/Language Arts. Comment : C ourse completion should be defined for consistent data collection. Discussion : GEAR UP grantees are provided with the flexibility to determine how course completion is defined across school districts that they collaborate with. It would be very difficult to create a definition that is applicable to every school district served b y a GEAR UP grant

. Change : None. Comment : Include an additional column for collecting the number of students performing at or above grade level in S cience in the Educational Progress b y Current GEAR UP Students Table to increase consistency

in data reporting. Discussion : The Department agrees and has implemented the recommended change

. Change : An additional column has been added to the Educational Progress by Current GEAR UP Students Table to collect data on the number of students performing at or above grade level in Science. Comment : The columns Number of Students Taking the PSAT or PLAN by end of 10 th Grade and the Number of Students Taking ACT or SAT Exam by the end of 11 th Grade are enabled for data entry for earlier grades. Discussion : The Department requires grantee s to report on the total number of students who have taken the PSAT or P LAN by the end of their 10 th grade year, ACT or SAT by the end of their 11 th grade ye ar. We understand that some students may take these standardize exams in earlier grades; however the Department does not want to create additional burden on the grantees

. Change : None. Comment : The Department should continue to collect data on target school s after the grant ’ s funding has expired.Discussion : The Department cannot require grantees to collect and report on data after funding

has en ded. Change : None. Comment : The Department should revise the data collection method used to calculate baseline high school graduation and college enrollment data

. Itis also recommended that the APR use a 4 ye ar cohort graduation rate which would more acc uratel y reflect the number of graduates. Discussion : The Department utilizes the graduation data to establish a baseline as a comparison measurement between 12 th grade graduation rates before the GEAR UP cohort reaches 12 th grade and current graduation rates once the GEAR UP cohort graduates. Change : None.

**SURVEY DATA** Comment : The Department should mandate when survey s should be administered during the academic year and the ye ars within the grant cycle that survey s need to be administered. Discussion : GEAR UP grantees are required to administer survey s to students and parents at least every

two years. GEAR UP grantees have the flexibility to administer the survey s when they expect to receive an adequate response rate for students and parents. Mandati ng a specific time of the academic ye ar for administering the survey s could reduce the response rate across grantees. Change : None. Comment : The Department should add a mandatory question to the student and parent survey s requesting information on the number of ye ars a student has received GEAR UP services. Discussion : The Department does not want to create additional burden on the survey requirements b y adding an additional mandatory question. Grantees may

include an additional question on their survey pertaining to the number of years a student has received GEAR UP services , if they

choose to do so

. Change : None. Comment : The Department should measure survey response s over the number that responded to a specific APR question, not the total number of respondents.Discussion : Creating response rates for individual survey questions would create additional burden on the grantees without adding any benefits to the pro grams . Change : None. Comment : The Department should address the adequate response rates for the survey s. Discussion : The adequate response rates for surveys have been established by the Department and cannot be altered. Change : None. Comment : One commenter recommended th e Department should develop an electronic form for reporting data that was submitted incorrectl y in the APR which would simplify the current sy stem which requires grantees to submit changes to the original APR in writing

. Discussion : The electronic APR sy stem provides grantees 75 day s to reenter the sy stem and correct data that was incorrectl y reported. Grantees are not required to submit written changes to the Program Officer until this time has elapsed. Further, the electronic reporting s ys tem has built in edit checks that alert grantees to data inconsistencies. Change : None

. Comment : The APR should disable fields which are not applicable to grantees during a reporting period. Discussion : Ty

picall y there are six different cohorts that are required to submit an APR each project year. While most partnership grantees f ollow a single or multiple cohorts, many state grantees using the priority student model are serving students from grades 7

- 12 from the first ye ar of the project. Itwould be extremely costl y t o make the recommended change and the change would not result in improved data collection. Change : None. Comment : The Department should allow grantees to capture student services through an electronic scanning process instead of requiring grantees to use sign

- in sheets Discussion : The commenter’s suggestion is no t applicable to the revision of the APR

. Grantees are permitted to develop their individual data collection sy stems. Change : None. Comment : Grantees who were awarded competitive preference priority points in the 2011 competition should report on each mea surement for the determination of future funding decisions.Discussion : The Narrative Section of the GEAR UP APR provides an opportunity for grantees to discuss the progress they have made in addressing the competitive preference priorit ies for which the grantees received additional points in the 2011 competition. It should be noted that responses to the competitive preference priorities will have no impact on future funding decisions. Change : None. Comment : Th e Department should require grantees to prov ide more comprehensive reporting during the no cost extension period

. Discussion : The Department currentl y requires an Interim Report for grantees who request more than a four month no cost extension. Inaddition, each grantee is required to submit a Fin al Performance Report (FPR) at the end of the extension period. Change : None. Comment : The Department should include a drop down menu on the electronic web reporting site to indicate the specific current year of funding for the grant. Discussion : The Department agrees and will create a field for the grantee to enter the grant’s current ye ar of funding. Change : The APR will be revised to add a funding year field

. Comment : H ow will the APR will measure and report on the Q uality of the P roject evaluation selection criterion that was required in the 2011 application ? Discussion : The Department understands the need for grantees to measure evaluation outcomes. The APR is not the document used for reporting evaluation activities. Grantees are required to rep ort on evaluation outcomes in their Biennial Evaluation Reports which are due every two ye ars. Change : None. Comment : What services will be required for grantees that o pt for a seventh year component and , how will these services be reported on the APR? D iscussion : The Department does not anticipate mandating specific services for the seventh ye ar. The Department is currentl y developing a list of services grantees may opt to use during the seventh year. The APR has been updated to include fields which al low for reporting of a seventh year component. Change : New fields have been added to the APR to accommodate reporting requirement s for grantees that have a seventh year.Comment : H ow will future GEAR UP grantees report on providing services to student s who

have received services under a previous GEAR UP grant but who have not yet completed the 12 th grade ? Discussion : The Higher Education Opportunity Act mandated that future GEAR UP grantees must provide services to students who received services under a previous GEAR UP grant but have not graduated from high school

. The APR will not need to be revised to provide a mechanism for grantees to report on these students. These students will be reported as continuing GEAR UP students. Change : None.