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ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) 

# FOR PAPERWORK REDUCT ION ACT

SUBMISSION **Mandatory Civil Rights Data Collection**

**June 2013** SUPPORTING STATEMENT , PART A :

JUSTIFICATION ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX

Revised XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable) The Civil Rights Data Collection (CRDC) is a longstanding and critical aspect of the overall enforcement and monitoring strategy used by the Department of Education ’s Office for Civil Rights (OCR) to ensure that recipients of the Department’s federal financial assistance do not discriminate on the basis of race, color, national origin, sex, and disability . OCR relies on CRDC data as it investigates complaints alleging discrimination, determin es whether the federal civil rights laws it enforces have been violated, initiates proactive compliance reviews to focus on particularl y acute or nationwide civil rights compliance problems, and provides policy guidance and technical assistance to educatio nal institutions, parents, students, and others. The Department of Education (the Department) has collected CRDC data on school characteristics, programs, services, and student outcomes on a biennial basis since 1968. For many years, the collection operat ed as the Elementary and Secondary

School Civil Rights Compliance Report ( approved by OMB as control # 1870 - 0500 ) . Recent administrations of the CRDC

—2004, 2006, and 2009 - 10

— were conducted primaril y on - line through a survey tool in partnership with EDFact

s . As such, through 2011, it was cleared under OMB control # 1875 - 0240. However, beginning with the 2013 - 14 CRDC, OCR is submitting this new separate clearance package for the CRDC.2

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) With the exception of two state education agencies (SEAs), e ach Local Education Agenc y (LEA) that is included submits an LEA summary survey and a survey

about each school in the LEA (one SEA provided all the data on behalf of its LEAs and another SEA provided some data on behalf of its LEAs during this time) . Generall y, th e collection has included a sample of about 6,000 - 7,000 LEAs, although the 1976, 2000, and 2011 - 12 collections were universal collections from all LEAs. The CRDC is a mandatory data collection. **1. Explain the circumstances that make the collection of infor**  **mation necessary. Identify any legal or administrative requirements that necessitate the collection.**  **Attach a hard**  **copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information**  **, or**  **you may provide a**  **valid URL**  **link or paste the applicable section .**  **Please limit pasted text to no longer than 3 pages.**  **Specify the review type of the collection (new, revision, extension, reinstatement with change, reinstatement without change)**  **. If revised, briefly specify**  **the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable.**  Section 203(c)(1) of the 1979 Department of Education Organization Act convey s to the Assistant Secretary

for Civil Rights the authority to “collect or coordinate the collection of data necessary to ensure compliance with civil rights laws within the jurisdiction of the Office for Civ il Rights” (20 U.S.C. § 3413(c)(1) , located at http://www.law.cornell.edu/uscode/text/20/3413 ). The civil rights laws enforced b y the OCR include: Title VIof the Civil Rights Act of 1964, which prohibits discrimination based on race, color, and national origin; Title IX of the Education Amendments of 1972, which prohibits discrimination based on sex; and Section 504 of the Rehabilitation Act of 1973, which prohibits discrimination on the bas is of disability . OCR’s implementing regulations for each of these statutes requires recipients of the Department’s federal financial assistance to submit to OCR “complete and accurate compliance reports at such times, and in such form and containing such information” as OCR “may determine to be necessary to enable [OCR] to ascertain whether the recipient has complied or is complying” with these laws and implementing regulations (34 CFR 100.6(b) , 34 CFR 106.71 , and 34 CFR 104.61 , located at http://www2.ed.gov/policy /rights/reg/ocr/index.html ). In addition, pursuant to a delegation by the Attorney

General of the United States, OCR shares in the enforcement of Title II of the Americans with Disabilities Act of 1990, which prohibits discrimination based on disability . An y data collection that OCR has determined to be necessary to ascertain or ensure compliance with these laws is mandatory . OCR also works with Department offices to help them effectivel y carry out programs of Federal financial assistance that the Secretary of Education is responsible for administering. See generally , Sections 201, 202(g), 411(a), and 412 of the Department of Education Organization Act (20 U.S.C. §§ 3411, located at http://www.law.cornell.edu/uscode/text/20/3411 , 3412(g), located at http://www.law.cornell.edu/uscode/text/20/3412 , 3471(a), located at http://www.law.cornell.edu/uscode/text/20/3471 , and 3472, located at http://www.law.cornell.edu/uscode/text/20 /3472 , respectivel y). OCR works with the3

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) Department’s Office of Elementary and Secondary Education, which is responsible for administering the Elementary and Secondary

Education Act of 1965 (ESEA). Section 9533 of the ESEA (20 U.S.C. § 7913 , located at http://www.law.cornell.edu/uscode/text/20/7913 ) prohibits discrimination in the administration of the ESEA in violation of the Fifth or Fourteenth Amendments to the Constitution. In addition, S ection 9534 of the ESEA (20 U.S.C. § 7914 , located at http://www.law.cornell.edu/uscode/text/20/7914 ) prohibits discrimination in funded programs on the basis of race, color, religion, sex (exc ept as otherwise permitted under Title IX), national origin, or disability . Thus, in addition to OCR's authority described above, the ESEA provides authority

for the Department to mandate that LEAs respond to this data collection. As with previous CRDC co llections, the purpose of the 2013 - 14 and 2015 - 16 CRDC is to obtain vital data related to the civil rights laws’ requirement that public LEAs and elementary and secondary schools provide equal educational opportunity . OCR has extensively anal yz ed the uses of every

data element collected in 2011 - 12 and sought advice from experts across the Department to refine, improve, and where appropriate, add or remove data elements from the collection. The 2013 - 14 and 2015 - 16 CRDC redesign effort ensured that, while several new indicators were added to the collection, dat a elements also were removed where appropriate. OCR also made the CRDC data definitions and metrics consistent with other mandatory collections across the Department wherever possible. The proposed additions and changes to the 2013 - 14 and 2015 - 16 CRDC r eflect the need for a deeper understanding of and accurate data about the educational opportunities and school context for our nation’s students. The information in the next few paragraphs summarizes the changes proposed for some general areas of informat ion collected in the CRDC . For a more detailed list of what is proposed for 2013 - 14 and 2015 - 16, including retained elements and proposed additions, see Appendix 1 to this Supporting Statement A. School and District Characteristics The CRDC will continue to cover such topics as the number of magnet and alternative schools, districts operating under desegregation orders or plans, and student membership disaggregated by race, ethnicity , sex, disability , and English learner status . The p roposed changes provi de greater context to deepen OCR’s understanding of the schools and districts in which students receive their education. For example, i tems about civil rights coordinators in each district will measure compliance with civil rights regulations and permit O CR to communicate with coordinators , and n ew items on the educational programs in justice facilities will provide a more accurate account of the educational opportunities available to students. (See attachment A - 5 for a directed question on this topic.) Discipline The 2009 - 10 CRDC made public long - hidden data about indicators of school culture, including: numbers of students, broken down b y demographic characteristics, who were suspended once and multiple times, expelled, and arrested in school; and new i nformation about the use of restraint and seclusion in the classroom. The p roposed changes provide additional information4

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) about the amount of time students are suspended; this reflects the findings of OCR enforcement actions and other reports that have shown that disproportionality in discipline extends beyond the ty pe of punishment (in - or out - of - school suspensions) to length of time out of class. Other proposed changes include additional attention to preschool discipline practices and corporal punishm ent. Proposed refinements to existing expulsion items are intended to make clear that such involuntary

transfers from a student's school for discipline reasons constitute expulsion, regardless of label, and to track where such students are sent to receive educational services (regular or alternative school). Other proposed changes will incorporate into the CRDC critical data elements taken from the NCES School Survey on Crime and Safety to obtain school violence and safety information. Harassment and B ull

ying Safe environments are critical to learning. Since the 2009, the CRDC has provided a lens on school climate and the bullying and harassment that students too often endure on the basis of race, sex, and disability . The p roposed changes add sexual orie ntation and religion to ty pes of allegations of harassment that need to be counted, but the proposal does not extend the reporting requirements about demographic data of the alleged complainant or harasser. (Note that the proposed changes will not authori ze schools to inquire about the sexual orientation or religion of students. Inclassifying the allegations of harassment or bullying, respondents are directed to look to the likely

motives of the alleged harasser/bully , and not the actual status of the al leged victim. See more information in response to question 11.) Early Childhood Education The CRDC continues to cover such topics as children’s access to and participation in LEA operated earl y childhood education programs. In order to deepen OCR’s unde rstanding of services provided to our youngest students, OCR is proposing to expand the collection of earl y childhood experience elements to learn more about how programs serve the youngest children. Pathways to College and Career The CRDC continues to c over topics such as students’ participation in Algebra and other college - preparatory

subjects, grade - level retention, and access to Advanced Placement (AP) courses. The p roposed changes provide a more accurate account of course taking and passing opportun ities. The previous collection allowed masking of important trends including middle school math opportunities and whether or not students have access to dual enrollment and/or credit recovery . Proposed changes also reflect efforts to reduce burden (and be tter focus on STEM opportunities) by

streamlining AP course - taking information. Another proposed change measures which schools have high and low chronic absenteeism rates. Chronic absenteeism can be a sign of serious school climate issues that are driving children out of school. It is also a warning sign of serious problems in the future for the child (e.g., dropping out).5

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) School finance (funded with state and local funds) Since 2009, the CRDC has been a source of information for exploring resource equ ity among schools within a district. The p roposed changes would provide finer - grained data on total personnel expenditures between schools for teachers and instructional aides, administrators, and those who provide critical support services for students and instruction. (See Attachment A - 5 for directed question on this topic.) Teachers (funded with federal, state, and/or local funds) Since 2009, the CRDC has been a resource for data on the number of first - and second - ye ar teachers in schools, the number of high school counselors in schools, and teacher absenteeism. The p roposed changes will add school support and securit y staffing data for every school. OCR also proposes to incorporate into the CRDC critical data elements taken from the NCES Schools and Staffing Survey . These data will deepen our understanding of how to make schools and communities safer and allow OCR to compare resources available to schools of different populations. **2. Indicate how, by whom, and for what purpose the information is to be**  **used. Except for a new collection, indicate the actual use the agency has made of the**  **information received from the current collection.** Since 1968, the CRDC (and its predecessor surveys) have served as the cornerstone for federal enforcement of children’s civil rights in public schools. OCR relies on CRDC data as it investigates complaints alleging discrimination, determines whether the federal civil rights laws it enforces have been violated, initiates proactive compliance reviews to focus on particularl y acute or nationwide civil rights compliance problems, and provides policy guidance and technical assistance to educational institutions, parents, students, and others. In 2009, OCR extensively redesigned the CRDC. It sought input from a wide range of experts within the Department and throughout federal government, and from stakeholders from state and local education agencies and the broader education community , through meetings and two public comment periods. Sources of advice and expertise included th e Education Information Management Advisory

Committee (a committee of the Council of Chief State School Officers), the National Center for Education Statistics Forum, state data coordinators from the Department’s EDFacts data submission sy stem, and a sampl ing of LEAs to ensure coordination among data collections and to minimize the burden on LEAs. OCR attorney s and staff from throughout the country

were heavily involved to ensure the collection’s maximum utility in the investigatory

process. The resulting 2009 - 10 CRDC was more detailed, providing new data on college and career - readiness, discipline, teacher equity , retention, access to pre - K programs, bullying and harassment, and school - level expenditures, and disaggregating data by race, ethnicity , sex, di sability , and English learner status. The transformed 2009 - 10 CRDC has been heralded as a first - of - its - kind opportunity

gap data tool that is allowing citizens and schools nationwide to identify educational equity- related problems and their solutions. Fo r OCR staff across the country , as they launch investigations, the6

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) CRDC is used to prepopulate their data requests so that recipients do not have to make duplicate reports and submissions. This expedites investigations and reduces the reporting burdens. T he 2011 - 12 CRDC built on these efforts by adding more data checks ( to ensure the data’s integrity) , and by

combining the fall snapshot data and spring outcome data collection periods into a single collection period ( to minimize the burden to respondents ) . The CRDC’s utility

reaches far beyond OCR to the entire Department, to other agencies and to researchers and policy

makers across the nation. CRDC data have also been used by other Department offices for purposes such as monitoring compliance with requirem ents for federal professional development funding, monitoring states under ESEA flexibility waivers, defining program requirements on discipline disparities in the Race to the Top district competition , and evaluating the Office of English Language Acquisition’s (OELA) programs and activities. Individual offices also rely on CRDC data to analyze issues and prepare reports on topics such as achievement gaps. State and federal agencies, policy makers, researchers, and many others outside of the Department al so use the CRDC data. (Data are available to the public via the Web in privacy protected format.) For each of these constituencies, the CRDC is an invaluable source of information about access to educational opportunities in our nation’s public schools. Researchers, advocacy

organizations, and news media have used CRDC data to identify possible civil rights concerns in our nation’s schools and to find models of success. State legislatures and state boards of education have relied on CRDC data in craftin g and revising educational policies. And for LEAs and schools across the country , the CRDC data is a critical tool for self - anal ys is and a mechanism for highlighting and correcting areas of educational concern. 3. **Describe whether, and to what extent, the collection of information involves the use**  **of automated, electronic, mechanical, or other technological collection techniques or forms of information technology, e.g. permitting electronic submission of**  **responses, and the basis for the decision of adoptin g this means of collection. Also**  **describe any consideration given to using technology to reduce burden.** Like recent collections, the primary collection instrument for the 2013 - 14 and 2015 - 16 CRDC will be a Web - based s ys tem; users will either upload data f iles and/or enter the data in response to questions displayed on the screen; and the data will be transmitted directly into a database. To reduce burden, the Department will utilize a user - friendly interactive tool that ensures schools and LEAs onl y have to answer applicable questions. Guiding questions facilitate this approach and may precede data group tables. For example, if a user indicates the school serves onl y elementary

students, the questions about high schools will not be presented. Similarly , a high school will be asked if the school provided Advanced Placement (AP) courses. If the user answers “No,” then the series of tables about AP will be skipped; if the user answers “Yes,” then the tables about AP will be presented.7

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) Flat file submissions , such as Excel files, are allowed for districts that have the capacity to create them; and paper submissions are allowed for LEAs with no Internet connectivity or limited Web access. States that wish to submit data on behalf of their LEAs are allowed to do so, as they have been in the past. Before 2011 - 12, LEAs had to choose to submit all their data either by flat file submission (FFS) or through the Web - based sy stem. For the 2011 - 12 CRDC, OCR implemented improvements to the web collection tool to allo w LEAs the flexibility to use both methods of submitting their data to the CRDC. As a result, the percentage of LEAs using FFS increased significantly , from 6% in 2009 to 26% in 2011. The flexibility

in submission methods allows LEAs to submit whatever portion of the CRDC is included in their student information sy stem in flat files. These flat files then “pre - populate” the Web - based screens and allow the school (or another department within the school district) to either verify

or complete the remaini ng sections of the CRDC. This option will continue to be availa b le in the 2013 - 14 and 2015 - 16 collections. Through computer control of the data collection process and the monitoring of responses, the computer - based s ys tem offers the capacity for substanti al improvements in data quality and data collection efficiency

over a survey

conducted using paper and pencil. Incidents of missing and inconsistent data are greatly reduced since questionnaire skip patterns are computer controlled. Moreover, invalid entries, contradictory entries, or entries inconsistent with available data on the school or LEA are questioned by the computer and must be resolved or confirmed by the respondent during the self - directed Web instrument data collection. 4. **Describe ef**

**forts to identify duplication.**  **Show specifically why any similar information already available cannot be used or modified for use for the purposes**  **described in Question**  **2 above.**  The CRDC is the unique source of data for the vast majority of data elements collected. Starting with the 2009 - 10 CRDC, OCR leveraged data submitted to the Department by state departments of education to reduce the burden on LEAs. In addition, in planning the 2009 - 10 CRDC, OCR carefully examined all data groups already collected by

EDFacts and dropped several tables previously

in the CRDC because the data are available through the state - based portion of EDFacts , the EDEN Submission Sy stem (ESS). OCR continues to use this approach for the CRDC. For the 2013 - 14 and 2015 - 16 CRDC, OCR also met with program offices across the Department to eliminate any

duplication of data items and, where possible, ensure the CRDC uses definitions consistent with those used by other program offices. For example, OC R worked closel y with the National Center on Educational Statistics (NCES) to align the definitions used for the collection of school - level expenditures with the definitions used by NCES and Census in the collection of district - level expenditures. In order to consolidate and centralize preschool - 12 data collections, definitions need to be standardized. If the same term has multiple definitions, the reporting8

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) burden on LEAs and SEAs increases significantly . Therefore, the same definitions of terms are used whenever possible. To coordinate the definitions used and identify possible duplication of data elements, OCR met with key staff throughout the Department and convened a two - day technical working group, including participants from NCES, the Office of Planning, Evaluation and Policy Development, the Office of English Language Acquisition, the Office of Special Education Programs, and the Correctional Re - Entry

Group, to review the proposed 2013 - 14 and 2015 - 16 CRDC. This cross program office coordination prov ided an opportunity for experts in content areas and survey design to raise potential areas of overlap . **5. If the collection of information impacts small businesses or other small entities,**  **describe any methods used to minimize burden. A small entity may be (1) a small**  **business which is deemed to be one that is independently owned and operated and that is not dominant in its field of operation; (2) a small organization that is any**  **not -**  **for -**  **profit enterprise that is independently owned and operated and is n ot**  **dominant in its field; or (3) a small government jurisdiction, which is a government of a city, county, town, township, school district, or special district with a**  **population of less than 50,000.** The CRDC allows small districts with limited or no Web ac cess to submit via a paper form. For the 2011 - 12 CRDC, 0.1% (16 out of nearl y 17,000) of LEAs submitted the CRDC through a paper form. Additionally , smaller LEAs often face additional challenges with the timing of the CRDC collection. At the close of the school ye ar, small and rural LEAs “roll over” their data sy stems, effectivel y closing out one school year and beginning the next. The end of year “roll over” can make accessing data from the prior school year challenging. With advice from the CRDC workgroup, which includes representatives from geographicall y diverse LEAs and SEAs, OCR created a set of pre - collection tools to allow smaller LEAs to collect and store their CRDC data in a format that could be easil y uploaded into the CRDC submission system. With these tools, smaller LEAs could store their CRDC data in ready - to - use flat files once the survey submission website opened in the fall of the next school year. These pre - collection tools were widely used and OCR received man y positive comments regarding their ease of use. As a result, OCR plans to continue to provide these tools for the 2013 - 14 and 2015 - 16 CRDC. **6. Describe the consequences to Federal program or policy activities if the collection is**  **not conducted or is conducted less frequently, as w ell as any technical or legal**  **obstacles to reducing burden.** Education in this nation is on an annual cycle where success and failure are measured and reported annuall y and civil rights complaints must be investigated and resolved on an ongoing basis. The most recent CRDC contained data from the fall and spring of school year 2011 - 12. It is critical that more recent information be available so that the Department can carry out its mandate to ensure civil rights under the applicable laws. Further, OCR enfo rcement offices rel y9

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) on data in the CRDC to prepopulate data requests to districts and schools when conducting investigations and compliance reviews. It is important that OCR have recent data to conduct these investigations. **7. Explain any special circums**  **tances that would cause an information collection to be conducted in a manner:**   **requiring respondents to report information to the agency more often than quarterly;**   **requiring respondents to prepare a written response to a collection of information in fewer**  **than 30 days after receipt of it;**  **requiring respondents to submit more than an original and two copies of any document;**   **requiring respondents to retain records, other than health, medical, government contract, grant**  **- in**  **- aid, or tax records for more than thr**  **ee years;**  **in connection with a statistical survey, that is not designed to produce valid and reliable results than can be generalized to the universe of study;**   **requiring the use of a statistical data classification that has not been reviewed and approved b**  **y OMB;**  **that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data**  **security policies that are consistent with the pledge, or that unnecessarily impedes shar**  **ing of data with other agencies for compatible confidential use; or**  **requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures**  **to protect the information’ s confidentiality to the extent permitted by law.**  This information collection activity does not have special circumstances that would include any of the requirements listed above. **8. As**  **applicable, state that the Department has published the 60 and 30 Federal**  **Register notices as required by 5 CFR 1320.8(d), soliciting comments on the**  **information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in**  **response to these com ments. Specifically address comments received on cost and**  **hour burden. Describe efforts to consult with persons outside the agency to obtain their views on**  **the availability of data, frequency of collection, the clarity of instruction and record keeping,**  **disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.** 10

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) **Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once ever** **y 3 years –**  **even if the collection of information activity is the same as in prior periods. There may be**  **circumstances that may preclude consultation in a specific situation. These circumstances should be explained.**  The Department will provide the public an opportunity to comment through both 60 - day and 30 - day notices. Additionally , d

uring the two - day

technical working group (referenced in response to question 4), OCR met with key

staff throughout the Department who offer ed their recommendation s on improv ements to data items. Following the technical working group review of the CRDC data elements, the full list of proposed new data elements and data elements OCR proposed to no longer collect was reviewed and approved b y the Department’s Policy Committee, which sought to ensure the collection of these data elements was necessary , permitted and non - duplicative. In addition to publishing a notice in the F ederal R egister, OCR will conduct outreach to LEAs and SEAs. On a semi - annual basis, OCR convenes a workgro up of representatives from geographically

diverse LEAs and SEAs to provide guidance and advice on way s to improve the CRDC. The CRDC workgroup play s a vital role in understanding the availability of data, within either state or local data systems, and th e burden of reporting new or continuing data items. **9. Explain any decision to provide any payment or gift to respondents, other than**  **remuneration of contractors or grantees with meaningful justification**  **.** There is no current remuneration for any school district or school. **10. Describe any assurance of confidentiality provided to respondents and the basis for**  **the assurance in statute, regulation, or agency policy. If personally identifiable information (PII) is being collected, a Privacy Act statement should b**  **e included on the instrument. Please provide a citation for the Systems of Record Notice and the**  **date a Privacy Impact Assessment was completed as indicated on the IC Data**  **Form . A confidentiality statement with a legal citation that authorizes the**  **pledge o**  **f confidentiality**  **should be provided. Requests for this information are in accordance**  **with the following ED and OMB policies: Privacy Act of 1974, OMB Circular A**   ** 108** **– Privacy Act Implementation**  **– Guidelines and Responsibilities, OMB**  **Circular A -**  **130 Appendix I**  **– Federal Agency Responsibilities for Maintaining**  **Records About Individuals, OMB M -**  **03 -**  **22 –**  **OMB Guidance for Implementing the Privacy Provisions of the E**  **- Government Act of 2002, OMB M**  **- 06**  **- 15**  **– Safeguarding Personally Identifiable Information, OM:6**  **- 104**  **– Privacy Act of 1974**  **(Collection, Use and Protection of Personally Identifiable Information) .**  **If the collection is subject to the Privacy Act, the Privacy Act statement is deemed**  **sufficient with respect to confidentiality. If there is no expectation of** 11

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) **confidentiality, simply state that the Department make s**  **no pledge about the confidentially of the data.**  There has been no assurance of confidentiality provided to the respondents beyond the agreement to protect individual student information under the Federal Educational Rights and Privacy Act. The CRDC does not collect any personally

identifiable information (PII). Confidentiality

issues with the CRDC are specific to the amount of data found in a “cell” that might make the identification of an indivi dual student or staff member possible when combined with other information not collected in the CRDC. OCR is committed to protecting individual privacy by not making public any

data in rows or columns where a single cell is below a certain threshold of si ze. OCR will continue to review the submitted data for any other securit y requirements. 11. **Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are**  **commonl y considered private. The justification should include the reasons why the**  **agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is**  **requested, and any st eps to be taken to obtain their consent.**  As noted above in response to question 1, OCR propose s to collect data about the number of allegations received b y a school of bullying/harassment on the basis of religion and sexual orientation. The questions are not intended or expected to elicit private information about students. The questions are intended to record, for any reported harassment, the school’s understanding about the harasser’s perceived motivation. In classifying the allegations of harassment or bull yi ng, respondents are directed to look to the likely motives of the alleged harasser/bully , and not the actual status of the alleged victim. Because the questions are not focused on students’ sexual behavior or attitudes or religious beliefs, OCR does not believe these questions are of a sensitive nature. Nonetheless, OCR provides the following justification for the proposed addition of these questions. Beginning in 2009, OCR collected data at the school level regarding bull yi ng/harassment on the basis of (1) sex, (2) race/color/national origin, and (3) disability . For each category , the CRDC collected the number of allegations of bull yi ng/harassment received b y a school , the number of students bullied/harassed, and the number of students disciplined f or bullying/harassment. For the “students bullied/harassed” and “students disciplined” items, the CRDC collected disaggregated data b y sex, race/ethnicity, disability, and LEP status. Bullying and harassment of students on the basis of religion and sexu al orientation is reportedly prevalent. The NIH’s Health Behavior in School - Aged Children Survey reported that 8.5% of12

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) s tudents (grades 6 - 10) are bullied about their religion. [ 1 ] Another survey found that, of those who had been subjected to religious slurs and degrading language in school, Jewish and Muslim students were more commonly targeted. [ 2 ] Li kewise, despite the lack of nationally representative or uniform school - level hara ssment data, bull yi ng and harassment in educational settings of those perceived to be lesbian, gay or bisexual is reportedl y common and has a negative impact on those students. For example, one 2011 analy sis of 18 studies found that gay , lesbian, and bise xual youth were more likely to be verball y harassed and teased or ph ys ically and sexually victimized than heterosexual youth, and more likely to experience detrimental outcomes, such as suicidal thoughts and attempts. [ 3 ] In May 2012, the Government Account ability Office noted the "prevalence of bullying of youths in certain vulnerable demographic groups is not known," and specifically highlighted that none of the four government - sponsored bullying - related national survey s collected information about harassm ent of students based on their sexual orientation. The GAO also stated more generall y that collecting additional information about bullying and harassment "would better inform federal efforts to prevent and remedy bull yi ng" and "could aid policy makers in determining whether additional actions are needed to protect vulnerable groups of students who are subjected to bullying. ” [ 4 ] In response to the critical need for national data, OCR is proposing to expand its data collection to address more comprehensively the bull yi ng and harassment in educational settings to include the number of allegations of bullying or harassment on the basis of religion and sexual orientation. Collecting these data would allow OCR to provide technical assistance where there are patte rns of harassment and to assist with investigations in response to complaints. In2010, OCR issued guidance regarding bull yi ng and harassment that indicated that, under some circumstances, harassment against gay and lesbian students would violate Title IX (prohibiting sex discrimination), and that, under some circumstances, harassment against Jewish and Muslim

[ 1 ] GAO, School Bullying: Extent of Legal Protections for Vulnerable Groups Needs to Be More Fully Assessed, at 40, App. IV, tbl. 9 (May 2012), http://www.gao.gov/assets/600/591202.pdf ; see also U.S. Commission on Civil Rights, Peer- to -Peer Violence and Bullying: Examining the Federal Response at 8 - 9 (Sept. 2011), http://www.usccr.gov/pubs/2011statutory.pdf (national survey show s 1.6% of students ages 12 - 18 reported being targeted by hate - related words based on religion; another survey shows 11% of all students in grades 7, 9, and 11 in California reported being subjected to bullying or harassment based on religion). [ 2 ] Stephen L. Wessler and Lelia L. De Andrade, “Slurs, Stereotypes, and Student Interventions: Examining the Dynamics, Impact, and Preventio n of Harassment in Middle and High School,” Journal of Social Issues , vol. 62, no. 3 (2006), http://onlinelibrary.wiley.com/doi/10.1111/j.1540 - 4560.2006.00471.x/full ; see also U.S. Commission on Civil Rights, supra , at 21 (collecting “demonstrative, albeit largely anecdotal, evidence” of harassment of Jewish and Muslim students, as well as those perceived to be Muslim). [ 3 ] Alicia L. Fedewa and Soyeon Ahn , “The Effects of Bullying and Peer Victimization on Sexual - Minority and Heterosexual Youths: A Quantitative Meta - Analysis of the Literature,” Journal of GLBT Family Studies, vol. 7, no. 4 (2011), as described in GAO, supra , at 10. [ 4 ] See GAO , supra , at 27.13

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) students would violate Title VI(prohibiting national origin discrimination). [ 5 ] In addition, these data would further the effective administration of programs under the ESEA. OCR proposes to collect only the number of allegations received b y a school of bullying and harassment on the basis of sexual orientation or religion. OCR is not proposing that schools collect data about students’ sexual ori entation or religion. OCR is not proposing that schools collect counts of students who were harassed or disciplined for harassment on those bases. S chool districts will not be required to include perceived sexual orientation or religious affiliation of s tudents as part of their administrative records. To assess whether even making an inquiry about the number of allegations of harassment received b y a school might cause invasions of privacy , OCR contacted SEAs in some of the 10 states that currently collect such sexual orientation harassment data from their public school districts and none reported any student or parental complaints or known incidents of teachers invading student privacy

in an effort to fill out the state’s data reporting forms. OCR also contacted several school districts (of various sizes and urban/rural mix) in those states to determine whether these data reporting requirements had led to sexual - orientation notations on individual student records or had raised an y complaints or conc erns and none were reported. **12. Provide estimates of the hour burden of the collection of information. The**  **statement should:**  **Indicate the number of respondents by affected public type (federal government, individuals or households, private sector**  **– businesses or other for**  **- profit, private**  **sector –**  **not -**  **for -**  **profit institutions, farms, state, local or tribal governments), frequency of response, annual hour burden, and an explanation of how the**  **burden was estimated, including identification of burden type : recordkeeping,**  **reporting or third party disclosure. All narr ative should be included in Question**  **12. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a**  **sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size,**  **or complexity, show the range of estimated hour burden, and explain the reasons for the v**  **ariance. Generally, estimates should not include burden hours for customary and usual business practices.**  [ 5 ] See Guidance Letter from OCR regarding Bullying , at 8 (Oct. 26, 2010) (“When students are subjected to harassment on the basis of their LGBT status, they may also ... be subjected to forms of sex discrimination prohibited under Title IX.”), http://www.ed.gov/ocr/letters/colleague - 201010.pdf ; id . at 5 (“[A]nti - Semitic harassment can trigger responsibilities under Title VI. ... These principles apply not just to Jewish students, but als o to students from any discrete religious group that shares, or is perceived to share, ancestry or ethnic characteristics (e.g., Muslims or Sikhs). Thus, harassment against students who are members of any religious group triggers a school’s Title VI resp onsibilities when the harassment is based on the group’s actual or perceived shared ancestry or ethnic characteristics, rather than solely on its members’ religious practices.”).14

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable)  **If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in the**  **RO CIS**  **IC Burden Analysis Table. (The table should at**  **minimum include Respondent**  **types, IC activity, Respondent and Responses, Hours/Response, and Total Hours)**   **Provide estimates of annualized cost to respondents of the hour burdens for collections of informa**  **tion, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information**  **collection activities should not be included here. Instead, this cost should be included in**  **Question 14.**  For the CRDC , the respondent is the LEA; the LEA must complete one LEA - level survey plus one school - level survey

for each of its schools. For the 2011 - 12 CRDC , the burden was estimated to be 1,282,492 hours across 16,785 LEA respondents and their approximately 96,523 scho ols with students in membership, based on an estimated 12.8 hours per school survey and 2.8 hours per LEA survey on average. For elementary schools, the burden was estimated to be 8.1 hours per school survey since several of the data elements are onl y app licable to high schools. For high schools, the burden was estimated to be 14.9 hours per school survey . The SY 2013 - 14 CRDC survey content will increase b y approximately 17% percent for PS - 12 schools. Approximately 17,620 LEAs will respond for themsel ves and their 101,849 schools to the request for data. This results in a total burden estimate of 1,499,890 hours. For elementary schools, the burden is estimated to be 8.9 hours per school survey since several of the data elements are only

applicable to high schools. For high schools, the burden was estimated to be 15.8 hours per school survey . Since the number of schools per LEA varies so widely it should be noted that a district with only one school would, on the average, take 4.2 hours for the LEA survey and 14 hours for the school survey , for a total of 18.2 hours. An LEA with 10 schools would take 4.8 hours on the LEA survey and average 14 hours on each of the school survey s, for a total of 144.8 hours.15

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) Respondents Hours/Response Total Hours Previous

– CRDC (2011) Schools: 96,523 LEAs: 16,785 Schools: 12.8 LEAs: 2.8 Schools:1,235,494

LEAs:46,998 Total: 1,282,492 New

– CRDC (2013) Schools:101,849 LEAs: 17,620 Schools: 14 LEAs: 4.2 Schools:

1,425,886 LEAs: 74,004 Total: 1,499,890 **New Burden**  Schools:+1.2hrs/survey LEAs: +1.4hrs/survey Schools:190,392 LEAs: 27,006 The total respondent cost for the SY 2013 - 14 CRDC is estimated to be $67,495,050 (1,499,890 hours multiplied by

an average wage of $45 per hour). There is a wide range of hourl y salaries associated with the professionals that will provide this data, but $45/hour is a reasonable average. **13. Provide an estimate of the total annual cost burden to respondents or record**  **keepers resulting from the collection of information. (Do not include the cost o**  **f any hour burden shown in Questions**  **12 and 14.)**  **The cost estimate should be split into two components: (a) a total capital and start**  **- up cost component (annualized over its expected useful life); and (b) a total**  **operation and mainten ance and purchase of services component. The estimates**  **should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to**  **estimate major cost factors including syst em and technology acquisition,**  **expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start**  **- up costs include,**  **among other items, preparations for collecting information such as p urchasing**  **computers and software; monitoring, sampling, drilling and testing equipment; and acquiring and maintaining record storage facilities.**   **If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the r**  **easons for the variance. The cost of contracting out information collection services should be a part of this cost burden estimate.**  **In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60**  **- day**  **pre -**  **OMB submission public**16

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) **comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as**  **appropriate.**  **Generally, estimates should not include purchases of equipment or servi ces, or**  **portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3)**  **for reasons other than to provide information or keep records for the government**  **or (4) as part of customary and usual business or private practices.**  **Also, these estimates should not include the hourly costs (i.e., the monetization of t**  **he hours) captured above in Question 12**  **. Total Annualized Capital/Startup Cost:**  **Total Annual Costs (O&M): Total Annualized Costs Requested:**  The collection of CRDC data for the foreseeable future will require no additional sy stems development efforts b y the local agencies. **14. Provide estimates of annualized cost to the Federal government. Also, provide a**  **description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead,**  **printing, and support staff), and any other expense that would not have been incurred without this collection**  **of information. Agencies also may agg regate cost**  **estimates from Questions 12, 13, and 14 in a single table.**  The estimated annual government cost for the next CRDC is $ 4.942 million. This estimate is based on contractual costs to develop a revised survey t ool, provide technical support for all LEAs in the nation, and produce and anal yz e the resulting database of survey responses. **15. Explain the reasons for any program changes or adjustments. Generally,**  **adjustments in burden result from re -**  **estimating burden an d/or from economic**  **phenomenon outside of an agency’s control (e.g., correcting a burden estimate or an organic increase in the size of the reporting universe). Program changes result**  **from a deliberate action that materially changes a collection of informat ion and**  **generally are result of new statute or an agency action (e.g., changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes**  **should be disaggregated by type of change (i.e., adjustment, program change due to new s**  **tatute, and/or program change due to agency discretion), type of collection (new, revision, extension, reinstatement with change, reinstatement without**  **change) and include totals for**  **changes in burden hours , responses**  **and cost s**  **(if applicable)**  **.** The SY 2013 - 14 CRDC survey content will increase b y approximately 17 percent resulting in an estimated 14 hours per school survey and 4.2 hours per LEA survey as a result of program17

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) change due to agency

discretion . Approximately 17,620 LEAs will respond for themselv es and their 101,849 schools to the request for data. This results in a total burden estimate of 1,499,890 hours. The annual government cost is similar to the cost of previous survey s, the last of which was the 2011 - 12 CRDC, conducted in 2012. **16. For collections of information whose results will be published, outline plans for**  **tabulation and publication. Address any complex analytical techniques that will be used.**  The Department presently makes CRDC results available on the Web with privacy pro tections in place. Additionall y, the Department makes available on the Web national and state projections based on the raw data. The Department makes data available through a website that display s a “summary

of select facts” for a district or school, whi ch display s data about key issues through tables and charts. Users then have the option to access additional data for that district or school. The website also contains a Flexible Tables interface, which allows users to select data from more than one district or school, for the current CRDC and/or prior CRDC s. In an effort to make the new CRDC easily usable by

the public and OCR’s investigators and attorney s, OCR designed a new Web - based data reporting tool that allows users to tailor the school - level in dicators and produce visuall y intuitive graphic displays of school - and district level tables, and made it available to the public in a privacy- protected format on OCR’s website, http://ocrdata.ed.gov . The new website is also research - friendly . For example, users have enhanced ability

to search and query

the database for ty

pes of schools as well as schools or districts meeting certain criteria. **17. Provide the time schedule for the entire project, including beginning and**  **ending dates of the collection of information, completion of report, publication dates, and**  **other actions.** There are three distinct phases of the collection of CRDC data from LEAs :  Notification and verification of reporting status,  Collection of data b y L EAs, and  Survey

submission window. The first phase in the CRDC is to notify school districts of their obligation to report, designate a principal point of contact, and verify the reporting status of LEAs and schools. The result of this first phase is a fu ll directory of LEAs and schools and their CRDC reporting status. For the 2013 - 14 collection, this phase will commence in Fall 2013 and for the 2015 - 16 collection, this phase will begin in Fall 2015.18

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) During the second phase of the CRDC, LEAs gather and va lidate the required data to be submitted to OCR. During this time, OCR provides frequent training opportunities for school districts to understand the data elements collected on the CRDC and the survey submission process. A support center is also availa ble to school districts to call or email questions regarding the content of the data to be collected. 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. For the 2013 - 14 collection, this second phase will take place between Fall 2013 and Summer 2014 and for the 2015 - 16 collection, this second phase will take place between Fall 2015 and Summer 2016. During the third phase, the survey submission wi dow opens with email notification to all participating school districts. School districts are typically given a minimum of three months to submit their data to OCR. During the survey submission period, frequent communication occurs with participating scho ol 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. For the 2013 - 14 collection, we anticipate this third phase will take place between Fall 2014 and Winter 2015 and for the 2015 - 16 collection, we anticipate this third phase will take place between Fall 2016 and Winter 2017. Following the close of the survey submission window, OCR reviews the data to identify possible reporting anomalies and offer LEAs an opportunity to amend their CRDC submission as necessary . This process takes approximately three months. Following the data quality review, OCR then works to post the data on its reporting website (ocrdata.ed.gov) to provide the public with easy access and visually

intuitive display s of the data. **18. If seeking approval to not display the expiration date for OMB approval of the**  **information collection, explain the reasons that display would be inappropriate.** This collection will display the OMB approval date in all transmittal documents requesting the information from the state or local agencies and in any written discussion or representation of the collection. The OMB number will be properl y displayed on any Web form and paper form used by the Civil Rights Data Collection. **19. Explain each exception to the certification statement identified in the Certification**  **of Paperwork Reduction Act.** ED is requesting no exemptions from the Certification.19

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) **Appendix: List of New and Continuing CRDC Questions**  Items that OCR is proposing to add are underlined . School & District Characteristics  Number of public schools (LEA)  Grades offered (PS - 12) (PS refers to preschool and excludes birth - 2)  Whether ungraded school has mainly elementary

school age students; middle school age students; high school age students; elementary and middle school age students; middle and high school age students; elementary middle, and high school age students  Number of students (PS through grade 12) served by L EA in LEA and non - LEA facilities (LEA)  Total number of students (preschool through grade 12) enrolled in school (disaggregated by race, sex, disability- IDEA, disability - 504 onl y, LEP)  Number of students with d isabilities (disaggregated by race, sex, LEP)  Number of LEP students and number of students enrolled in LEP programs (disaggregated b y race, sex, disability- ID EA)  Whether the school is operating a magnet program for all students or some students within the school (and if so, whether entire school population participates in the magnet program)  Whether the school is an alternative school (and if so, for academic or discipline or both)  Whether the school is focused primarily on serving students with disabili ties  Whether the school is a charter school  For justice facility

onl y: o Ty pe of facility

(pre - or post - adjudication/conviction or both) o Number of day s that makeup the justice facility ’s regular school ye ar o Total number of hours per week that educational p rogram is offered during regular school ye ar o Number of students who participated in educational program for less than 15 calendar day s; 15 - 30 calendar day s; 31 - 90 calendar day s; 91 - 180 calendar day s; more than 180 calendar day s .  Whether co - educational scho ol has one or more single - sex classes  Number of single - sex academic classes (with males only ; with females only) in the following courses/subject areas: o Algebra I, Geometry , and/or Algebra II o Other mathematics o Science o English/reading/language arts o Other ac ademic subjects  Whether LEA has civil rights coordinators for discrimination against students on basis of sex, race, and disability

(and contact information) (LEA )  Whether LEA is covered by desegregation order or plan (LEA)20

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) Discipline  Students (K - 12) who received one or more in - school suspension: o Number of K - 12 students without disabilities who received one or more in - school suspension (disaggregated by race, sex, LEP) o Number of K - 12 students with disabilities who received one or more in - school suspension (disaggregated by race, sex, disability- 504 only , LEP)  Students who received one out - of - school suspension: o Number of preschool students who received one out - of - school suspension (disaggregated b y race, sex, disability- ID EA, LEP) o Number of K - 12 students w ithout disabilities who received one out - of - school suspension (disaggregated by race, sex, LEP) o Number of K - 12 students with disabilities who received one out - of - school suspension (disaggregated by race, sex, disability- 504 only , LEP)  Students who received more than one out - of - school suspension: o Number of preschool students who received more than one out - of - school suspension (disaggregated by race, sex, disability - IDEA, LEP) o Number of K - 12 students without disabilities who received more than one out - ofschool suspension (disaggregated b y race, sex, LEP) o Number of K - 12 students with disabilities who received more than one out - ofschool suspension (disaggregated b y race, sex, disability- 504 onl y, LEP)  Number of preschool students who were expelled (disaggregated by race, sex, disabilityID EA, LEP)  Students (K - 12) who were expelled (with educational services; without educational services; because of zero - tolerance policies): o Number of K - 12 students without disabilities who were expelled (with educational se rvices; without educational services; because of zero - tolerance policies) (disaggregated by race, sex, LEP) o Number of K - 12 students with disabilities who were expelled (with educational services; without educational services; because of zero - tolerance poli cies) (disaggregated b y race, sex, disability- 504 onl y, LEP)  Students (K - 12) who were removed for disciplinary reasons (to alternative school; to regular school): o Number of K - 12 students without disabilities who were removed for disciplinary reasons (to al ternative school; to regular school) (disaggregated b y race, sex, LEP) o Number of K - 12 students with disabilities who were removed for disciplinary reasons (to alternative school; to regular school) (disaggregated b y race, sex, disability - 504 only , LEP)  Students (K - 12) who were referred to law enforcement agency or official: o Number of K - 12 students without disabilities who were referred to law enforcement agency

or official (disaggregated b y race, sex, LEP) o Number of K - 12 students with disabilities who w ere referred to law enforcement agency or official (disaggregated by race, sex, disability - 504 onl y, LEP)21

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable)  Students (K - 12) who were arrested for school - related activity : o Number of K - 12 students without disabilities who were arrested for school - related activ ity (disaggregated by

race, sex, LEP) o Number of K - 12 students with disabilities who were arrested for school - related activity (disaggregated by

race, sex, disability- 504 only , LEP)  Students who received corporal punishment: o Number of preschool students (ag es 3 - 5) who received corporal punishment (disaggregated b y race, sex, disability- ID EA, LEP) o Number of K - 12 students without disabilities who received corporal punishment (disaggregated b y race, sex, LEP) o Number of K - 12 students with disabilities who received corporal punishment (disaggregated b y race, sex, disability- 504 onl y, LEP)  Number of instances of corporal punishment that students (preschool through grade 12) received (disaggregated by students without disabilities, students with disabilities )  Number of school days missed by students who received out - of - school suspensions (disaggregated b y students without disabilities, students with disabilities (IDEA), students with disabilities (504 only)  Documented incidents that occurred at the school that would trigger discipline, including referrals to law enforcement and arrests: o Number of incidents of robbery with a weapon o Number of incidents of robbery with a firearm or explosive device o Number of incidents of robbery without a weapon o Number of incidents of phy sical attack or fight with a weapon o Number of incidents of phy sical attack or fight with a firearm or explosive device o Number of incidents of phy sical attack or fight without a weapon o Number of incidents of threats of ph ys ical attack with a weapon o Number of incidents of threats of ph ys ical attack with a firearm or explosive device o Number of incidents of threats of ph ys ical attack without a weapon o Number of incidents of rape or attempted rape o Number of incidents of sexual battery (other than rape) o Number of incidents of possession of a firearm or explosive device o Whether an y of the school’s students, faculty, or staff died as a result of a homicide committed at the school o Whether there has been at least one incident at the school that involved a sho oting (regardless of whether anyone was hurt) Harassment and bullying  Number of reported allegations of harassment or bullying of K - 12 students on the basis of: sex; race, color, or national origin; disability ; sexual orientation ; religion  Number of K - 1 2 students reported as harassed or bullied on the basis of: sex; race, color, or national origin; disability (disaggregated b y race, sex, disability- IDEA, disability - 504 only , LEP)22

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable) Number of K - 12 students disciplined for engaging in harassment or bull yi ng on the basis of: sex; race, color, or national origin; disability (disaggregated b y race, sex, disabilityID EA, disability - 504 only , L EP) Restraint and Seclusion  Students (K - 12) subjected to mechanical restraint: o Number of non - IDEA K - 12 students subjected to mechanical restraint (disaggregated b y race, sex, disability- 504 onl y, LEP) o Number of K - 12 students with disabilities (IDEA) subjected to mechanical restraint (disaggregated by race, sex, LEP)  Students (K - 12) subjected to phy sical restraint: o Number of non - IDEA K - 12 students subjected to phy sical restraint (disaggregated by race, sex, disability- 504 only , LEP) o Number of K - 12 students with disabilities (IDEA) subjected to phy sical restraint (disaggregated b y rac e, sex, LEP)  Students (K - 12) subjected to seclusion: o Number of non - IDEA K - 12 students subjected to seclusion (disaggregated by race, sex, disability- 504 only , LEP) o Number of K - 12 students with disabilities (IDEA) subjected to seclusion (disaggregated b y race, sex, LEP)  Number of instances of mechanical restraint, ph ysical restraint, seclusion (disaggregated by students without disabilities, students with disabilities - ID EA, students with disabilities - 504 only) Single Sex Interscholastic Athletics  Whether the school has any students who participate in single - sex interscholastic athletics  Number of single - sex interscholastic athletics high school sports (with males only ; with females onl y)  Number of single - sex interscholastic athletics high school teams (wi th males only ; with females onl y)  Number of student participants on single - sex interscholastic athletics high school sports teams (with males only ; with females onl y) Early Childhood Education  Whether LEA provides early childhood program(s) for children birth - 2 (LEA)  Whether LEA’s earl y childhood program(s) serve non - IDEA children birth - 2 (LEA)

 Preschool length offered (full - day , part - day) and cost (free, partial charge, full charge) (LEA )  Number of students served by L EA in preschool programs in LEA and non - LE A facilities (disaggregated by age – 3, 4, 5) (LEA)23

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable)  Whether preschool is provided to: all students, students with disabilities (IDEA), students in Title Ischools, students from low income families (LEA )  Whether preschool serves non - IDEA student s age 3; age 4; age 5 (LEA)  Number of students ages 3 - 5 enrolled in preschool (disaggregated by race, sex, disabilityID EA, LEP)  Whether the school’s preschool program serves non - IDEA students (disaggregated b y age -- 3, 4, 5)  Whether LEA is required to p rovide full - day or part - day

kindergarten b y state statute or regulation (LEA )  Kindergarten length offered (full - day , part - day) and cost (free, partial charge, full charge) (LEA) Pathways to College and Career  Whether the school has one or more gifted/tal ented programs  Number of students enrolled in gifted & talented programs (disaggregated by race, sex, disability - IDEA, LEP)  Whether students are enrolled in distance education courses (LEA)  Number of students enrolled in distance education courses (disaggregated by race, sex, disability - IDEA, LEP) (LEA)  Whether an y students participate in a dual enrollment/dual credit program  Number of students enrolled in at least one dual enrollment/dual credit program (disaggregated b y race, sex, disability- ID EA, LEP)  Whether the school has any students who participate in at least one credit recovery program that allows them to earn missed credit to graduate from high school  Number of students absent 15 or more school days (disaggregated by race, sex, disabilityID EA, disability - 504 only , L EP)  Whether the school offers the International Baccalaureate Diploma Programme  Number of students enrolled in the International Baccalaureate (IB) Diploma Programme (disaggregated b y race, sex, disability- ID EA, LEP)  Whether students are enrolled in one or more AP courses  Number of different AP courses provided  Whether students are allowed to self - select for participation in AP courses  Number of students enrolled in at least one AP course (disaggregated b y race, sex , disability - IDEA, LEP)  Number of students enrolled in at least one AP course in specific subject area (disaggregated b y race, sex, disability , LEP) o AP math of an y kind o AP science of an y kind o Other AP subjects of an y kind (including foreign language)  Numb er of students who took one or more AP exams for one or more (which may include all) AP courses enrolled in (disaggregated b y race, sex, disability- IDEA, LEP)  Number of students who were enrolled in one or more AP courses but who did not take any AP exams (disaggregated b y race, sex, disability- IDEA, LEP)24

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable)  Number of students who passed one or more AP exams for one or more (which may include all) AP courses enrolled in (disaggregated by race, sex, disability- IDEA, LEP)  Number of students who did not pass any AP exams for the one or more AP courses enrolled in (disaggregated by race, sex, disability- ID EA, LEP)  Number of classes in math and science (Algebra I, Geometry , Algebra II, Advanced Math, Calculus, Biology , Chemistry , Phy sics)  Number of students enrolled in Algebra I in grade 7 (total count)  Number of students enrolled in Algebra I in grades: 8; 9&10; 11&12 (disaggregated b y race, sex, disability- IDEA, LEP)  Number of students who passed Algebra I in grade 7 (total count)  Numbe r of students who passed Algebra I in grades: 8; 9&10; 11&12 (disaggregated b y race, sex, disability- IDEA, LEP)  Number of students enrolled in Geometry in grade 8 (total count)  Number of students enrolled in Geometry in grades 9 - 12 (disaggregated b y race , sex, disability - IDEA, LEP)  Number of students (grades 9 - 12) enrolled in other math and science courses, by subject (Algebra II, Advanced Math, Calculus, Biology, Chemistry, Ph ys ics) (disaggregated b y race, sex, disability- IDEA, LEP)  Number of students wh o took SAT, ACT, or both, any time during school year (disaggregated b y race, sex, disability- ID EA, LEP)  GED preparation program (LEA) : o Whether LEA operated a GED prep program o Number of students ages 16 - 19 who participated in LEA - operated GED prep program (disaggregated by race, sex, disability- IDEA, LEP) o Number of students ages 16 - 19 who participated in LEA - operated GED prep program, succeeded on GED test, and received high school equivalency credential (disaggregated b y race, sex, disability- ID EA, LEP)  Wh ether LEA has policy that allows retention of third grade students who are not proficient in reading (LEA)  Number of students retained in specified grade, by grade (K - 12) (disaggregated by race, sex, disability- IDEA; disability - 504 onl y, LEP) School finance (funded with state and local funds)  K - 12 personnel FTEs and salaries at the school level (funded with state and/or local funds) o Number of FTE teachers and amount of their salaries o Number of FTE instructional staff (teachers & aides) and amount of their salaries o Number of FTE support services staff for pupils and amount of their salaries o Number of FTE support services staff for instructional staff and amount of their salaries o Number of FTE school administration staff and amount of their salaries o Number of FTE non - instructional staff and amount of their salaries25

ICRAS ICR ID and OMB Number: ( 1974.01 ) XXXX - XXXX Revised: XX/XX/XXXX RI N Number: XXXX - XXXX (if applicable)  Total amount of non - personnel expenditures at the school level Teachers (funded with federal, state, and/or local funds)  Number of FTE teachers (preschool through grade 12)  Number of FTE fi rst - ye ar teachers (preschool through grade 12)  Number of FTE second - ye ar teachers (preschool through grade 12)  Number of FTE teachers absent more than 10 school days (excluding professional development) (PS - 12)  Number of FTE school counselors (preschool through grade 12)  Number of FTE ps ychologists (preschool through grade 12)  Number of FTE social workers (preschool through grade 12)  Number of FTE security guards (preschool through grade 12)  Number of FTE sch ool resource officers (preschool through grade 12)  Number of FTE sworn law enforcement officers (preschool through grade 12)