PAPERWORK REDUCTION ACT SUBMISSION SUPPORTING STATEMENT

Annual Mandatory Collection of Elementary and Secondary

Education Data through EDFacts

December 2012

Attachment E

EDFacts Data Set

Response to Public Comment
Attachment E – Response to Public Comment

EDFacts Data Set for School Years 2013-14, 2014-15, and 2015-16

Page	E-2

Table	of	Contents

Introduction....................................................................................................................................................................................4

Career and Technical Education............................................................................................................................................5

CTE Changes to the Proposed EDFacts Data Set.........................................................5

Charter Schools and Authorizers...........................................................................................................................................5

Charter and Charter Authorizer Changes to the Proposed EDFacts Data Set .................................9

Free and Reduced Price Lunch ..............................................................................................................................................9

GENERAL COMMENTS....................................................................................................................9

NSLP Status .........................................................................................................................................9

NSLP Status Changes to the Proposed EDFacts Data Set..............................................10

FRPL Lunches Served........................................................................................................................11

FRPL Lunches Served Changes to the Proposed EDFacts Data Set.............................................11

Directly Certified Students.................................................................................................................11

Directly Certified Students Changes to the Proposed EDFacts Data Set ......................................12

General Education Provisions Act (GEPA)....................................................................................................................12

Directed Question #2 Reporting through FSRS................................................................................12

Directed Question #3: Reporting Subgrant data via FSRS vs. EDFacts...........................................13

Directed Question #4: Anticipated Impact.........................................................................................14

Directed Question #5: GEPA Burden ................................................................................................15

GEPA Changes to the Proposed EDFacts Data Set......................................................16

Individuals with Disabilities Education Act (IDEA) ...................................................................................................16

Directed Question #6: Creation of a Separate School Level File Specification................................17

Directed Question #7: Auto-calculation of Subtotals.........................................................................17

Directed Question #8: Maintenance of Effort/Continuing Early Intervening Services.....................18

IDEA Discipline Data ........................................................................................................................20

IDEA Changes to the Proposed EDFacts Data Set......................................................20

Limited English Proficient ...................................................................................................................................................20

LEP Changes to the Proposed EDFacts Data Set.........................................................21

Membership (including Tuition-in/out)............................................................................................................................21

Grade 13 .............................................................................................................................................22

Grade 13 Changes to the Proposed EDFacts Data Set..................................................27

Tuition-in / Tuition-out ......................................................................................................................27

Tuition-in / Tuition-out Changes to the Proposed EDFacts Data Set............................................31
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Military Connected Student Identifier................................................................................................31

Military Connected Student Identifier Changes to the Proposed EDFacts Data Set.....................32

Migrant Education.......................................................................................................................................32

General Response to All Comments from the Office of Migrant Education .....................................33

Revision of DG102: MEP students served 12-month table................................................................33

Revision of DG634: Migrant student eligible 12-month table...........................................................33

Deletion of DG636 & DG637: MEP students served regular & summer/intersession ......................34

Revision of DG684: MEP services ....................................................................................................35

Revision of staff category: Qualified or Not Qualified Paraprofessionals........................................35

Migrant Changes to the Proposed EDFacts Data Set...................................................36

Neglected or Delinquent........................................................................................................................................................36

N or D Changes to the Proposed EDFacts Data Set.....................................................36

Virtual Schools............................................................................................................................................36

Virtual School Changes to the Proposed EDFacts Data Set..........................................................37

General Comments......................................................................................................................................38

General Comment Changes to the Proposed EDFacts Data Set....................................................40
Attachment E – Response to Public Comment

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INTRODUCTION

This attachment contains the responses to public comments on the Annual Mandatory Collection 

of Elementary and Secondary Education Data through EDFacts.

The 60-day comment period for the EDFacts package closed on November 13, 2012. ED

received a total of 280 comments from 25 commenters. Most (a total of 278) comments came 

from a total of 23 state educational agencies (SEAs), one from a non-profit, and one from a state 

agency that was not the SEA. 

ED received comments on the nine directed questions, specific areas of data collection that were 

shown in the B attachments, and the information clearance process. This document is organized 

topically into the following sections:

 Career and Technical Education

 Charter Schools and Authorizers

 Free and Reduced Price Lunch

 General Education Provisions Act (GEPA)

 IDEA

 Limited English Proficient

 Membership (including Tuition-in/out)

 Migrant Education

 Neglected or Delinquent

 Virtual Schools

 General Comments

Each section provides a summary of the public comments received, ED’s response to those 

comments, and any resulting changes being made to the proposed data collection package. In 

addressing the public comments and making revisions to the package, ED focused on 

recommendations from the public comments that continue to move EDFacts forward in

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

on data suppliers.

ED appreciates the time and attention the public spent on reviewing the EDFacts package and in 

composing thoughtful comments that shape the final data set, as evidenced in this attachment. 

ED reviewed, summarized and documented each comment prior to analyzing all comments. This 

documentation will aid in the finalization of this data clearance package and will serve to inform 

future policy decisions regarding EDFacts. 
Attachment E – Response to Public Comment

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CAREER AND TECHNICAL EDUCATION

The paperwork clearance package posted during the 60-day public comment period did not 

propose any changes to the Career and Technical Education (CTE) data groups or data 

categories. One reviewer of the package offered a few suggestions.

Public Comments

One state recommended the following changes for FS082 CTE Concentrators Exiting, FS083

CTE Concentrators Graduates, FS142 CTE Concentrators Academic, and FS154 CTE 

Concentrators Graduation Rate.

1. Change the measurement definition in these files to align with the measurement 

definition used for annual measurable objectives (AMOs). For example, the state reports 

AMO measures on students who took the test. Whereas, the Perkins denominator 

definition for these measures are looking at students used in the State’s computation of 

AMO, and who in the reporting year, left secondary education. Meaning that Perkins is 

looking at students’ 10th grade assessment scores.

2. Change the reporting time period for CTE files to a later date to align with the AMO 

reporting timelines.

ED’s Response

The specifications tell states to use the state AMO computation for CTE that is used for other 

students unless the state has negotiated a modified definition with OVAE for use in reporting. 

The state should use the computation method negotiated in the Perkins program that they manage 

and has been agreed to with OVAE even if that definition is different from the computation 

method used for other non-CTE students. 

If the state wants to reopen the negotiation on definitions and computations for CTE students to 

modify it in some manner, that can be done after December 31, 2012, when the current reporting 

period ends. 

The state should coordinate with the State CTE office to determine the computation 

methodology that was negotiated and must be used in reporting this year.

CTE CHANGES TO THE PROPOSED EDFACTS DATA SET

No changes are proposed at this time.

CHARTER SCHOOLS AND AUTHORIZERS

The paperwork clearance package posted during the 60-day public comment period proposed the 

creation of a Charter Authorizer Roster (or directory) through EDFacts that would require the 
Attachment E – Response to Public Comment

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creation of new data groups and changes to existing data groups. Additionally, the package 

included the following directed question:

Directed Question #1: ED has added the collection of directory information on charter school 

authorizers. Identification numbers will be needed to facilitate the collection of this directory

information. Do states assign unique identifiers for charter authorizers that could be used in the 

Charter Authorizer Roster, or would SEAs prefer that ED create a unique ID system for Charter 

Authorizers? 

A total of 17 states commented on the proposed creation of a Charter Authorizer Roster. No state 

expressed opposition to the collection of charter authorizer data. Two states expressed support. 

Two states commented that they do not have charter schools. The specific comments fall into 

three areas:

 Requests for clarification on the proposed collection of Charter Authorizer or other 

charter data

 Expression of ability or support for using unique identifiers assigned by the SEA

 Expression of support for using unique identifiers assigned by ED 

The comments are summarized below, along with ED’s responses.

Requests for Clarification on the Collection of Charter and Charter Authorizer Data

A total of 5 SEAs requested additional information to understand the proposed change to 

collection of charter school and charter authorizer data and how it will impact states. 

Public Comments

One SEA asked if the intent of giving charter authorizers a unique identifier is to be able to 

distinguish them from other districts.

ED’s Response

The intent of collecting a unique identifier on charter authorizers is to be able to link charter 

schools reported in the EDFacts directory to the appropriate entity serving as a charter 

authorizer. As public interest in charter schools continues to grow, ED is seeking to collect 

information that will promote better use and analysis of charter school data. In some states, the 

charter authorizer may also be the local educational agency in which the charter school is 

located, but this is not true for all states. We expect to collect the charter authorizer data in a

new file, and we will add a field to the school-level directory file that will allow states to report 

the charter authorizer ID for schools flagged as charter schools. 

Public Comments

Several SEAs asked for guidance in determining which entity is the charter school authorizer. 

One state asked if the entity submitting a charter would be considered the charter authorizer. One 

state uses a two-fold authorization in which the local board of education authorizes a charter 

school in the district and the State Board of Education gives final authorization. In this instance, 

which would be considered charter authorizers and would they need identifiers separate from 

those which already exist for the local educational agency (LEA) and the SEA?

ED’s Response
Attachment E – Response to Public Comment

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The charter authorizer is the entity under state law that can authorize or create a charter school. 

Depending on the state, the charter authorizer may be the entity that is a party to the charter 

contract, oversees the application process, performs oversight and monitoring, and/or reviews 

charters for renewal/non-renewal. Whichever entity is primarily responsible for those duties 

would be the entity that SEAs should submit as the authorizer. In the two-fold situation stated 

above, if the local board of education isn’t an actual entity per se, then the school district the 

local board of education governs will be the authorizer. ED will provide guidance in the file 

specification for how to determine which entity to report as the charter authorizer in cases where

there may be multiple entities involved in authorizing charter schools. 

For ED’s Response to whether existing LEAs would need new identifiers, please see discussion 

of Unique Identifiers on Page E-8.

Public Comments

One state requested clarification on how a single district SEA that is not a charter district would 

indicate a charter authorizer.

ED’s Response

If the district is not the authorizer, then the charter schools within the district must have some 

type of authorizing entity. The entity that authorizes and oversees the charter schools would be 

the charter authorizer.

Public Comments

One state suggested that the changes to the directory file FS029 be limited, and requested 

additional information on how the file will change as proposed in the package.

ED’s Response

ED expects that the authorizer roster will be a separate file from FS029. Starting in SY 2012-13, 

ED will begin collecting DG653 Charter school LEA status (permitted values provided below) in 

FS168. This data group will be moved to the LEA level directory starting in SY 2013-14. At the 

LEA level, instead of the yes/no for charter status, there will be options for 

 NA – State does not have charters or state does not permit charter LEAs

 Not a charter district – State has charter LEAs but this LEA is not a charter LEA.

 Charter district which is an LEA for programs authorized under IDEA, ESEA and Perkins 

 Charter district which is an LEA for programs authorized under ESEA and Perkins but not 

under IDEA

 Charter district which is an LEA for programs authorized under IDEA but not under ESEA

and Perkins

 Charter district which is not an LEA for any federal program

The only other addition to the directory file would be a requirement for SEAs with charter 

schools to submit the unique charter authorizer identifier for each charter school. 
Attachment E – Response to Public Comment

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Page	E-8

Public Comments

One state asked if the listing of DG27 in Attachment B-1 is the same as DG29 Charter Status.

ED’s Response

Please excuse the error. The correct reference is DG27 Charter Status. This correction has been 

made in the current package.

Expression of Ability or Support for Using Unique Identifiers Assigned by the SEA 

Public Comments

A total of seven SEAs commented that they have a unique identifier for charter authorizers. Six 

of the SEAs expressed a preference to continue using the identifier they assign versus an NCES 

ID for charter authorizers. One state did not express a preference for using a state-assigned 

identifier or one assigned by NCES.

Two states have charter authorizers that are education entities that already have a unique 

identifier assigned by ED via NCES or IPEDS. Three states use a state-created unique identifier. 

One state suggested prefacing the unique identifiers with its FIPS code to identify the charter 

authorizers with that state. 

Changing the charter authorizer unique identifier for these states would result in additional 

burden to states by requiring them to create a new element in their data systems.

ED’s Response

See below.

Expression of Support for Using Unique Identifiers Assigned by ED

Public Comments

A total of three SEAs expressed support for NCES creating and maintaining a charter authorizer 

identifier. One state shared its preference that the unique identifier be based on existing NCES 

codes. Two of the SEAs said the addition of a unique identifier for charter authorizers would 

result in little to no added burden.

ED’s Response

Given state responses, ED will use SEA-assigned unique identifiers for charter authorizers. If 

the authorizer is a LEA, the NCES-assigned LEA ID may be used as the charter authorizer 

identifier. ED will preface the submittedidentifiers that are not the NCES-assigned LEA ID with 

the state’s two-digit ANSI code to ensure that the identifiers in the charter authorizer roster are 

unique.
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CHARTER AND CHARTER AUTHORIZER CHANGES 

TO THE PROPOSED EDFACTS DATA SET

ED will not collect the proposed data group named Charter school authorizer identifier (NCES). 

Instead, it will collect the data group for the state-assigned charter authorizer ID. There are no 

other edits to the proposed changes to the charter related data.

FREE AND REDUCED PRICE LUNCH

ED proposed the addition of three new Free and Reduced-Price Lunch-related data groups that 

measure: 1) whether a school is working under a school lunch program and, if so, which 

provision (NSLP Status), 2) how many lunches are actually served to free and reduced-price 

lunch eligible students (Lunches Served), and 3) the number of students who are directly 

certified to be eligible for free and reduced-priced lunches (Directly Certified). Eighteen states 

submitted approximately 45 comments on these new data groups.

GENERAL COMMENTS

Public Comments

Four states provided general comments concerning the changes in the National School Lunch 

Program (NSLP) and the impact of those changes on Free and Reduced Lunch Eligibility data. 

One state noted that the state’s department of agriculture administers the school lunch program 

rather than the SEA; however, the data requested for the new data groups would be available 

from that department. All three states commented on the additional burden on states for 

submitting these new data, and expressed concerns about the continued use of free and reduced 

price lunch data as a measure for economically disadvantaged students. 

ED’s Response

ED appreciates all of the comments received. As noted below, two of the three new proposed 

data groups will not be collected based on public comments received. In addition, ED will 

continue to research alternatives to free and reduced price lunch data as a measure for 

economically disadvantaged students. 

NSLP STATUS

Ten states submitted comments regarding the NSLP status. One state commented that these data 

were available and could be reported. Other comments fell into the general categories listed 

below.

Permitted Values

Public Comments
Attachment E – Response to Public Comment

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Three states requested further clarification on “traditional requirements” within the permitted 

value “Yes, participating using traditional requirements for annual determinations of eligibility

for free and reduced-price lunch.”

ED’s Response

“Traditional requirements” refers to schools’ annual determinations of individual students’ 

eligibility for FRPL, typically by means of a letter or questionnaire sent to the students’ homes. 

ED will be changing the wording of the proposed permitted values to provide greater clarity.

Reporting Period

Public Comments

Two states expressed concern about the reporting period of October 1st for this data group, due to 

eligibility verification taking place during the month of October. 

ED’s Response

ED understands this concern and agrees that the reporting period should be moved to a later date, 

which will be October 31st.

Qualifying FRPL Programs

Public Comments

Two states inquired about the breakfast program, which can cause schools to have multiple 

provisions, one for lunch and one for breakfast. Also, one state asked whether feeding sites 

would be included.

ED’s Response

ED is only concerned about the lunch program and what provision (if any) is based on the lunch 

program. These data will only be collected for entities that fit the definition of a “school” and 

are listed in the EDFacts directory and have membership. 

Justification

Public Comments

One state requested an explanation of the benefit to ED in collecting this information.

ED’s Response

This information will provide a better understanding of the reliability and accuracy of the 

submitted data for DG565, Free and reduced price lunch table, by understanding how students in 

the schools are deemed eligible. 

NSLP STATUS CHANGES TO THE PROPOSED EDFACTS DATA SET

The proposed permitted value “Yes, participating using traditional requirements for annual 

determinations of eligibility for free and reduced-price lunch,” is replaced with “Yes, participating 

without using any Provision or the CEO,” where “the provisions below” refers to Provisions 1, 2, and 3
Attachment E – Response to Public Comment

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and “CEO” is the Community Eligibility Option of the NSLP. The reporting period will be changed to 

October 31st.

FRPL LUNCHES SERVED

Fourteen states submitted comments regarding the proposed collection of number of free or 

reduced-price lunches served.

Public Comments

Public comments submitted on this proposed data group mentioned the following concerns and 

recommendations: 

 The general unavailability of these data in state data systems resulting in significant 

burden on states as well as the questionable quality of any data that would be reported.

 Requests for clarification and/or suggestions made on the definition for this new data 

group. In particular, one state suggested the definition provide clarity on whether it is 

measuring all students eligible or only students eligible due to direct certification. 

Another state suggested the definition be broadened to include any student eligible, 

regardless of direct certification. 

 Recommendations to change the reporting period to a later date (and one that is not an 

entire month) so as to obtain more accurate and reliable counts. 

 Requests for an explanation of the purpose of collecting these data. It was noted that if 

schools are operating their school lunch program under the CEO, then all students would

be given a free meal even though not all students are eligible for free meals, thus these 

counts will not accurately reflect the true number of students in poverty.

ED’s Response

Based on public comments received, ED has decided not to collect this data group as it appears 

the collection would place a significant burden on states and would not result in consistent data 

reported by states,

FRPL LUNCHES SERVED CHANGES TO THE PROPOSED EDFACTS DATA SET

This proposed data group will not be included in the EDFacts data set.

DIRECTLY CERTIFIED STUDENTS

Fifteen states submitted comments regarding the proposed collection of number of students who 

have been directly certified to be eligible for free and reduced-price lunches.

Public Comments
Attachment E – Response to Public Comment

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Several states requested clarification on which students should be included in these counts. For 

example, one state has access to the count of students who have been directly certified via 

SNAP, but not for TANF. Other states inquired whether migrant students, homeless students, or 

students with medical assistance whose income meets the criteria for free meals are included. 

Another state indicated it is not able to determine any student who is eligible as a sibling via the 

extension of direct certification.

States also commented that the reporting period suggested is not appropriate and a later date 

would lead to more accurate and reliable counts. 

Several states indicated they either do not directly certify based on TANF, or their LEAs collect 

direct certification (not the schools), thus it is not in the state’s student information system. 

ED’s Response

Based on public comments received, ED believes that the states do not have sufficiently

consistent data available to report on this data group, and therefore, we will not be adding this 

proposed data group to the EDFacts data set. 

DIRECTLY CERTIFIED STUDENTS CHANGES 

TO THE PROPOSED EDFACTS DATA SET

This proposed data group will not be included in the EDFacts data set.

GENERAL EDUCATION PROVISIONS ACT (GEPA)

The paperwork clearance package posted during the 60-day public comment included four 

directed questions (Directed Questions #2-5) concerning the possibility of discontinuing the 

collection of DG547 Federal programs funding allocation table. ED received responses from 17 

states to these four questions. A summary of states’ comments and ED’s responses follow.

DIRECTED QUESTION #2 REPORTING THROUGH FSRS

The public was invited to respond to the following question:

Directed Question #2: Does your SEA currently report awards of less than $25,000 through the 

FSRS? If not, would there be any barriers to reporting these awards through FSRS if FSRS 

became the sole collection vehicle for data required under GEPA? 

Public Comments
Attachment E – Response to Public Comment

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 Seventeen states submitted a total of 17 comments in response to directed question #2. 

 Fifteen states currently do not report awards of less than $25,000 through the FSRS; one

state reported that it reports awards of less than $25,000 through the FSRS and one state 

reported that some programs report through FSRS while others do not. 

 Twelve states reported there would be no barrier to reporting these awards through FSRS.

 Four states raised the following specific concerns about burden: 

o One state indicated that there would be a burden if the question is interpreted to 

include awards to vendors that are less than $25,000.

o One state noted that small sponsors would have to get a DUNS registration which 

is a challenge and the small sponsors would most likely opt of the program as a 

result. 

o One state pointed out that FSRS requires that each entity have a DUNS number 

with a nine-digit zip code that corresponds to a congressional district, but the data 

the state pulls from the Educational Entity Master is often incomplete. In many

cases, the correct zip code is found by manually searching the US Postal Service 

website. The DUNS/zip code error often persists, resulting in a request for 

assistance on the Federal Service Desk (FSD) website which subsequently results 

in more delays. For a report that requires monthly updates, this level of technical 

support hinders timely reporting. In addition, when submitting a batch upload in 

FSRS, the website frequently shows that an upload is in process, but never gives a 

confirmation that the report has been submitted. This requires staff to check the 

activity log to see if that report was actually submitted successfully. Frequently, 

there is no record (successful OR unsuccessful) of an approval in the activity log, 

even after waiting a reasonable time. As a result, staff have to attempt to resubmit 

the same information again. Once a report actually shows up in the log as being 

submitted successfully, there is no mechanism to actually prove that the system 

accepted the exact data that was submitted. In a reporting system like FSRS, 

there should be e-mail confirmations, and users should be able to pull up a PDF of 

what was submitted. 

ED’s Response

See the response to Directed Question #5.

DIRECTED QUESTION #3: REPORTING SUBGRANT DATA VIA FSRS VS. EDFACTS

The public was invited to respond to the following question:
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Directed Question #3: Are you aware of other differences in how your SEA reports subgrant 

data to FSRS vs. EDFacts that would impact the quality and completeness of the data available 

to ED to meet its statutory obligations under GEPA?

Public Comments

 Seventeen states submitted a total of 17 comments in response to directed question #3. 

 Eight states are not aware of other differences in how their SEA reports subgrant data to 

FSRS vs. EDFacts; nine states are aware of differences that would impact the quality and 

completeness of the data available to ED to meet its statutory obligations under GEPA. 

 Six states commented on the differences in the information collected by FSRS versus 

EDFacts. FSRS collects its data at the beginning of the 27 month award period while 

EDFacts collects its data at the end of that period. As a result, FSRS only contains 

information on the award amount. EDFacts contains information on the actual award 

distribution, as well as information on amounts that went unallocated, distributed to nonLEAs, transferred to other state agencies, and retained. One state felt that due to these 

differences, EDFacts was more accurate. 

 In addition, two states mentioned concern regarding DUNS numbers. One state indicated 

that GEPA does not require DUNS numbers, zip codes, or congressional districts and that 

USED requiring these fields will result in the state modifying their system. One state is 

concerned about how to handle non-LEAs and their lack of DUNS numbers. 

 One state would like to see the FSRS system issues mentioned in the first GEPA directed 

question to be improved prior to expanding reporting on FSRS. 

ED’s Response

See the response to Directed Question #5.

DIRECTED QUESTION #4: ANTICIPATED IMPACT

The public was invited to respond to the following question:

Directed Question #4: Do you anticipate any negative impact on your SEA’s collected and use 

of these subaward data if ED were to eliminate the EDFacts reporting requirement and fulfill its 

GEPA Section 424 obligations through data reported to FSRS? 

Public Comments

 Seventeen states submitted a total of 18 comments in response to directed question 

#4. 

 Twelve states do not anticipate any negative impact on their collected and use of 

subaward data if ED were to eliminate the EDFacts reporting requirement and fulfill 
Attachment E – Response to Public Comment

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Page	E-15

its GEPA Section 424 obligations through data reported to FSRS; three states do 

anticipate negative impact and one state did not know. 

 One state indicated that there will be no issues if the amount awarded is the only

piece of data ED is looking for. In addition, the state is having a very difficult time 

getting and validating the data from their program areas. The file is often submitted 

late and incomplete. Out of all of the EDFacts files, this is the most difficult for a 

state to gather data. It would be helpful if this file was no longer an EDFacts

reporting requirement. 

 One state has experienced many challenges when entering data into FSRS. For 

example, there are times when the system is heavily used and cannot accommodate 

additional users. Also, uploading large amounts of data has been problematic. There 

is a lack of assistance provided to our agency when these problems occur. The state

supports the consolidation of these 2 collections only if problems with the FSRS 

system can be addressed and corrected.

 One state is in the process of developing its FFATA reporting system. 

ED’s Response

See the response to Directed Question #5.

DIRECTED QUESTION #5: GEPA BURDEN

The public was invited to respond to the following question:

Directed Question #5: Would you be supportive of ED eliminating the EDFacts reporting 

requirement (FS035, DG547) in lieu of relying on the FSRS data to fulfill its GEPA Section 424 

requirements? If so, please describe the extent to which this change would result in a burden 

reduction for your SEA. 

Public Comments

 Seventeen states submitted a total of 17 comments in response to directed question 

#5. 

 Twelve states fully support the elimination of the EDFacts reporting requirement 

(FS035, DG547) in lieu of relying on the FSRS data to fulfill its GEPA Section 424 

requirements; one state does not support its elimination; one state indicated it does 

not matter either way; three states support the elimination only if their concerns are 

resolved. 

 The states in support of the elimination noted that the elimination will reduce burden 

by freeing up staff. 
Attachment E – Response to Public Comment

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 One state does not support the elimination, as the burden with the reporting is not 

with EDFacts but with GEPA. The state would prefer a single annual report closer to 

the end of the fiscal year. 

 Two states commented on the reporting challenges when entering data into FSRS and 

would support the elimination if the FSRS system issues were resolved. 

 One state commented that prior to eliminating the EDFacts file, the state would want 

to make sure their internal data are ready for successful submission of FSRS. 

 One state supports the elimination of the EDFacts file, but noted that the EDFacts 

reporting does not represent a large reporting burden, whereas FFATA does represent 

a large and growing reporting burden. The state supports the elimination as it would 

result in not having to double report. 

ED’s Response

The issues raised in response to all four directed questions on GEPA warrant further discussion 

within ED prior to any decision is made regarding the elimination of the EDFacts reporting 

requirement in lieu of relying on FSRS data to fulfill the department’s GEPA Section 424 

requirements. Therefore, ED will continue to collect DG547 in EDFacts until ED has 

(1) been able to determine the comparability and relative quality of the data in EDFacts

versus FSRS (we expect to be able to conduct this analysis with FY2011 data), 

(2) made further investigation into the functionality of FSRS, and 

(3) determined how data could be transferred from FSRS into EDFacts. 

GEPA CHANGES TO THE PROPOSED EDFACTS DATA SET

No changes are proposed at this time.

INDIVIDUALS WITH DISABILITIES EDUCATION ACT (IDEA)

The paperwork clearance package posted during the 60-day public comment period included 

several directed questions regarding the collection of data for IDEA Section 618. A total of 16

states submitted comments related to IDEA section 618 directed questions below. Eleven of the 

states commented on each of the three questions; three states commented on two of the directed 

questions; two states each provided a single response to collectively address the collection of 

IDEA Section 618 data. One state also submitted a comment related to IDEA discipline data. 

States’ comments and ED’s response to them are included, below, in the following sections:

 Directed Question 6: Creation of a Separate School Level File Specification

 Directed Question 7: Auto-calculation of Subtotals

 Directed Question 8: Maintenance of Effort/Continuing Early Intervening Services

 IDEA Discipline Data
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DIRECTED QUESTION #6:

CREATION OF A SEPARATE SCHOOL LEVEL FILE SPECIFICATION

The public was invited to respond to the following question:

Directed Question #6: ED is considering creating a separate file specification for reporting 

children with disabilities (IDEA) at the school level. Currently states report their data in FS002, 

Children with Disabilities (IDEA) School-Age, at all three educational levels (i.e., SEA, LEA, 

and School). School level data are used in the Civil Rights Data Collection (CRDC); SEA and 

LEA level data are used by the Office of Special Education Programs (OSEP). Would it be more 

or less burdensome for states if ED split off the School level into a separate file?

Burden

Public Comments

A total of eight states expressed their concern about splitting off the school level child count in a 

separate file specification from the SEA and LEA levels. These states reported that the proposed 

change would increase rather than decrease the burden, as it would require the SEA to rewrite 

programming code, create additional business rules, change data governance, and accrue 

additional contracting costs. One state shared that such a change would also require changes to 

its longitudinal data system (LDS). 

Five states expressed neutral views about the proposed change saying that maintaining the file 

specifications as currently written or splitting off the school level would “be fine” and create no 

additional burden.

One state thought that splitting off the school level into a separate file would be less burdensome 

for the SEA. Another state noted that if the proposed new file specification maintained the 

current file structure, the additional burden would be minimal.

ED’s Response

ED appreciates the responses. Based on the feedback received through this public comment 

process, we have decided to maintain the current structure of FS002. Please note that reporting 

instructions for SEA and LEA level data will continue to be stewarded by OSEP; reporting 

instructions for school level data will continue to be stewarded by OCR. The instructions may 

differ, depending on the reporting level and stewarding office, but the data elements that are 

reported in FS002 at the SEA, LEA, and school level will be consistent.

DIRECTED QUESTION #7: AUTO-CALCULATION OF SUBTOTALS

The public was invited to respond to the following question:

Directed Question #7: ED is considering the deletion of the reported subtotals and instead autocalculating the subtotals. As an example in FS002, ED is proposing to delete all of the seven 
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subtotals currently required for submission by the states. Do states believe that the quality of 

their IDEA 618 data submissions at the SEA and LEA levels will remain the same if the 

subtotals are auto-calculated instead of reported?

Burden

Public Comments

One state indicated that it would be more burdensome if ED eliminated the required subtotal 

reporting. It stated reasons similar to those cited in Directed Question #6 above. 

Two states expressed no preference. Eight states reported that the quality of their data would 

remain the same whether the subtotals were reported or auto-calculated. One state uses the 

reported subtotals as one means to ensure data quality; another state uses the reported subtotals 

as validation checks and would continue to run the subtotals for that purpose; another state 

expressed concern that if the reported subtotals were eliminated it would no longer have the 

subtotals to use as data checks.

Two states indicated that eliminating the reported subtotals and replacing them with autocalculated values would reduce their reporting burden. Both of these states said such a change 

would not impact their data quality.

ED’s Response

To allow maximum flexibility, ED will allow states to either report subtotals or not report 

subtotals in FS002. This will allow states the choice to maintain their current coding and 

procedures. States will no longer be required to submit subtotals for FS002. For states that 

choose to submit subtotals in FS002, the reported subtotals will not be used by OSEP for data 

quality and public reporting purposes. 

The auto-calculated subtotals will be derived from the detailed counts reported in FS002 based 

on the same calculations previously used in the business rules. We will not have data quality

checks that evaluate the relationship between the detailed counts and the subtotals; however, data 

quality checks may be used to evaluate the relationship among auto-calculated subtotals and 

grand totals.

DIRECTED QUESTION #8:

MAINTENANCE OF EFFORT/CONTINUING EARLY INTERVENING SERVICES

The public was invited to respond to the following question:

Directed Question #8: ED is considering adding two new data elements to the Maintenance of 

Effort/Continuing Early Intervening Services. What benefits will be realized by having this 

information publicly available? How will states and the public use the information reported 

through these new data elements on significant disproportionality and CEIS? What challenges 

do states anticipate in submitting these data through EMAPS?
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Burden

Public Comments

None of the commenting SEAs supported the public reporting of the state definition of 

significant disproportionality and calculation of CEIS. Seven states did not consider it beneficial 

to publicly report their state definition of significant disproportionality and the calculation of 

CEIS. A majority of commenters stated that these data are already available on their state web 

sites or other state documents including their IDEA State Performance Plan (SPP) and Annual 

Performance Report (APR). Five states indicated that the proposed additional information would 

be an increased reporting burden. Several respondents questioned how the proposed new 

information would be useful to the public. One state expressed concern that this information 

could potentially be confusing to the public as to why an LEA was identified. One state 

questioned the statutory basis for collecting this additional information.

Three states expressed no objection to reporting the additional information related to MOE and 

CEIS.

ED’s Response

ED believes that collecting and publicly reporting this information related to CEIS will increase 

transparency and public awareness around significant disproportionality. Though ED agrees that 

reporting the new data elements associated with CEIS may in some states increase burden, we 

believe the increase will be nominal. States should already be using the information needed for 

the proposed data elements to conduct their analysis for significant disproportionality. Though 

some states voluntarily report this information related to significant disproportionality to the 

public, it is not routinely collected from or reported by all states. OSEP offers states the 

opportunity to submit data notes to further explain a state’s data to potential users.

Submission of Data

Public Comments

Two states emphasized the need to be able to upload information into the data collection tool 

rather than manually input it.

ED’s Response

ED agrees that the data collection in EMAPS will need to allow states to enter one or more 

categories under which an LEA is identified for having significant disproportionality. ED is 

working with contractors to examine the possibility of a file upload feature for the submission of 

these data.

ED will explore the possibility of implementing the commenter’s suggestion to collect the 

definition of significant disproportionality in the State Supplemental Survey-IDEA, which 

collects metadata related to the IDEA Section 618 collections.
Attachment E – Response to Public Comment

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IDEA DISCIPLINE DATA

Public Comments

One state submitted a comment on IDEA discipline data. Disciplinary action is required for all 

firearm incidents. The state has some incidents where no disciplinary action occurred.

ED’s Response

ED is not proposing changes to the IDEA discipline data for SY 2013-14.

IDEA CHANGES TO THE PROPOSED EDFACTS DATA SET

ED will allow the reporting of subtotals on an optional basis in FS002. All other proposed 

changes to the IDEA portion of the EDFacts data set will be maintained.

LIMITED ENGLISH PROFICIENT

The paperwork clearance package posted during the 60-day public comment period proposed 

removing the school level collection from DG123, LEP students in LEP program table, and 

adding a school level collection to DG678, LEP enrolled table. Three comments were received 

on this change. In addition, one comment was received concerning ED’s use of “home” vs. 

“native” language in the language category used in DG678 and DG519, Immigrant table. 

Changes to School-Level Collections

Public Comments

One SEA asked whether the definition for DG678 will change for the new school level file that 

has been moved from DG123. Two SEAs commented that the new school-level file will be due 

during a busy period in the reporting year, and one SEA confirmed that they are able to report 

school-level data for DG678. 

ED’s Response

ED’s rationale for the change and the definitions for DG678 and DG123 is grounded in 

improved data usage. DG123 is currently collected at the SEA, LEA, and school levels for use 

by the National Center for Education Statistics (NCES). NCES currently uses only the SEA- and 

LEA-level data. In addition, ED is receiving increased requests for school-level data for Title III 

data groups. To collect more useful data, ED has moved the school-level count of LEP students 

from NCES DG123 to Title III DG678.

The definitions of DG678 and DG123 will remain unchanged. DG678 will continue to collect a 

cumulative school-year count of all LEP students enrolled, while DG123 will continue to collect 

an October 1 count of LEP students enrolled in English language instruction educational 
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programs designed for LEP students. The definition for DG678 will be the same at all three 

levels (SEA, LEA, and school).

While the due date for the school-level file for DG678 will occur during a busy period in the 

reporting calendar, the due date is seven months later than the school-level file for DG123 that is 

being eliminated. In addition, the new file will result in more usable data.

‘Home’ vs. ‘Native’ Language

Public Comment

One SEA asked about the status of changes they have been expecting to the language category

used in EDFacts DG678 LEP enrolled table, and DG519 Immigrant table.

ED’s Response

Based on the comment received, ED has revised the language category used in DG678 and 

DG519 to align with statutory definitions of native language. The revised definition is:

(11) NATIVE LANGUAGE- The term native language means —

(A) the language normally used by such individual; or

(B) the language normally used by the parents of the child or youth.

This definitional change will not require SEAs to revise their data collection systems. SEAs that 

currently report the home language of LEP and immigrant students may continue to do so, as 

allowed under option B in the definition above. States that wish to report the language normally

used by the student may now do so under option A.

LEP CHANGES TO THE PROPOSED EDFACTS DATA SET

ED has replaced the “Language (Home)” category with “Language (Native)” for DG678 and 

DG519. Reporting at the school level has been removed from DG123. Reporting at the school 

level has been added to DG678 

MEMBERSHIP 

(INCLUDING TUITION-IN/OUT)

The paperwork clearance package posted during the 60-day public comment period proposed 

several changes to the membership data reported in the Common Core of Data (CCD). Several of 

those changes related to the collection of data related to free and reduced price lunches (FRPL). 

Comments and responses to those changes can be found in the section above titled, “Free and 

Reduced Price Lunch.” This section summarizes the comments for membership data in three 

other areas and their respective sub-areas:

 Grade 13: The proposed change to the permitted value Grade 13
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o Definition of Grade 13

o Current Reporting Practices

o Burden

 Tuition-in / Tuition-out: The proposed change to determine the number of students 

tuitioned-in or -out of an LEA

o Clarification of Proposed Data Groups

o Burden

o General Recommendation

 Military Connected Student Identifier: A suggestion that student membership include an 

indicator for military dependent students

A total of 14 SEAs and one non-profit submitted comments regarding non-FRPL membership 

data. The comments are summarized, below, and are followed by ED’s response.

GRADE 13

The paperwork clearance package posted during the 60-day public comment period proposed 

changing the permitted value “13/Postgraduate” used in several of the Grade Level and 

Grade/Age data categories to “Grade 13.” An additional data category that uses the amended 

permitted value was also created. The purpose of the proposed change is to better account for 

students who remain in high school beyond grade 12 to jointly complete high school and college 

credit courses. 

A total of nine SEAs submitted comments regarding the proposed change to the Grade 13 

permitted value in one or more of the following topics:

 Definition of Grade 13

 Current Reporting Practices

 Burden

Definition of Grade 13

Each of the nine SEAs commented on the definition of Grade 13. Three of the states confirmed 

their understanding of the proposed Grade 13 and how it would be applied. Seven of the states 

requested additional information.

Public Comments

Four states requested that a definition be provided for the Grade 13 permitted value. Two states 

asked for clarification on what “satisfied grade 12 requirements” means, and whether it is 

equivalent to earning a high school diploma. 

One state requested clarification regarding which students would be counted as “Grade 13.” For 

example, would students have to be taking both high school and college courses to be counted or 
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could they be high school students taking only college courses? Is the count of a student as 

“Grade 13” dependent on whether he or she is taking the college course at the college? Do all 

college credit courses, such as AP courses count as college courses? 

One state commented that the current “Grade13/Postgraduate” permitted value seems to apply to 

students bridging between high school and post-secondary education while the proposed “Grade 

13” permitted value seems to apply to students who need an additional year to meet high school 

requirements. If this logic holds true, the state asks whether “Grade 14” and “Grade 15” 

permitted values are needed for students who take six or seven years to graduate.

ED’s Response

The proposed change to the permitted value “Grade 13” is to clearly differentiate among high 

school students who are beyond grade 12 status. ED has crafted definitions, as noted below, to 

describe students in the following situations: grade 13, ungraded, and adult education. ED 

believes that the new definitions of these permitted values are mutually exclusive and will more 

accurately describe the student population. For purposes of determining which students are 

counted as Grade 13, note that a student who has “completed grade 12” means a student who has 

successfully completed his or her grade 12 school year, and does not necessarily mean a student 

who has completed his or her academic requirements for graduation.

For the SY 2013-14 data collection, we plan to:

a. Modify section 2.1 of the file specifications for FS052 – Membership, to change the 

current definitions for grade 13 and adult education and to add a definition for 

“ungraded”. The revised definitions are to read as follows.

Grade 13: This grade label is used to designate high school students who are enrolled 

in programs where they can earn college credit in an extended high school 

environment, or CTE students in a high school program that continues beyond grade 

12. All students reported under grade 13 must have completed grade 12.

The following students are not counted under grade 13.

i. Students who are repeating grade 12.

ii. Dual credit students who have not completed grade 12; they should be counted 

in the grade to which they are assigned. 

iii. Students pursuing certification in a career and technical education (CTE) 

program while in high school (grade 12 or below); they should be counted in 

the grade to which they are assigned. 

iv. GED participants; they should be counted under adult education (AE).

Adult Education (AE): This grade label is used for those LEAs and schools that 

provide adult education programs. It includes career and technical education (CTE) 
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students who have completed grade 12 and are not enrolled in a high school program. 

GED program participants are also counted under Adult Education.

Ungraded (UG): This grade label is used for an individual assigned to a class or 

program that does not have standard grade designations.

This may also include:

a. Students who remain enrolled in school after completing high school in order to 

earn additional high school credits, 

b. Students with disabilities (IDEA) who are continuing with their education, in 

accordance with their IEP, and who have completed grade 12.

b. Modify the guidance on Grade 13/AE in section 2 of the file specifications for FS039 –

Grades Offered to read as follows.

What is the difference between Grade 13 and AE? 

The grade designated “13” (Grade 13) is included for those LEAs or schools that offer a 

specific program, related to earning post-secondary credit, a CTE degree, or CTE 

certification, that extends beyond the traditional 4 grade high school structure. The AE 

(Adult Education) designation is for Adult Education programs. These programs are 

usually for students who have dropped out and returned to school or entered an Adult 

Education (GED preparation) program. 

The objective is for all reporting to be consistent. Where the SEA has specific 

definitions for Grade 13 and/or Adult Education, the SEA should include this 

information in the new explanation field so that users of ESS data have access to 

information on the SEA’s definition of Grade 13. 

Please note that ESS is not trying to expand the scope of its data collection beyond preK through 12 levels. Some program areas include adult education as part of their 

reporting and therefore those “grade” designators are available for those programs only. 

Adult education programs as a rule are not reported for this collection unless they are 

specifically included in a program area.

c. Modify the CCD to include the above definitions.

d. Add “grade 13” as a permitted value in the following files:

 Membership table (DG39, FS052)

 Dropouts table (DG326, FS032)

 Students involved with firearms (DG596, FS086)

 LEP enrolled (DG678, FS141)

 Title III LEP students served (DG648, FS116)
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 Homeless served (DG560, FS043)

 Homeless enrolled (DG655, FS118)

Additionally, the following information provides further clarification. The grade 13 designation 

is not dependent on where classes are taken. What is essential is that the student is still enrolled 

in high school, beyond grade 12, and taking courses for college and high school credit. Other 

students earning dual credits or AP credits should be designated in the grade to which they are 

assigned. 

The grade 13 designation is intended for students who stay in high school for more than four 

years to participate in a program that bridges the high school and college degree earning 

experience such as an early or middle college program. The grade 13 designation is not to be 

used for students who are repeating courses to meet high school requirements, and are not 

enrolled in college courses. Such students should be reported as grade 12 students – or whatever 

grade it is that they are repeating. Given this logic, it is not necessary to have a “Grade 14” or 

“Grade 15” permitted value.

Public Comments

Two states made comments regarding which data groups would use the Grade 13 permitted 

value. One state recommended that the proposed permitted value be used throughout the 

EDFacts Data Set and not just for select data groups. Another state asked ED to identify all data 

groups that would use the permitted value and noted Attachment B-4 suggested the permitted 

value Grade 13 would only be used for the following data groups:

 DG560 Homeless served (McKinney-Vento) table

 DG655 Homeless students enrolled table

 DG39 Membership table

 DG326 Dropouts table

ED’s Response

The permitted value Grade 13 would be used in the Grade Level (Membership), Grade Level 

(Basic w/13), Age/Grade (All), and Age/Grade (Basic) categories, which will only be used in the 

following data groups and files at this time, as documented in Attachment B-4:

 Membership table (DG39, FS052)

 Dropouts table (DG326, FS032)

 Students involved with firearms table (DG596, FS086)

 LEP enrolled table (DG678, FS141)

 Title III LEP students served table (DG648, FS116)

 Homeless served (McKinney-Vento) table (DG560, FS043)

 Homeless students enrolled table (DG655, FS118)

ED acknowledges that the permitted value Grade 13 may become applicable to additional data 

groups within other program areas in the future. As federal program requirements change, ED 
Attachment E – Response to Public Comment

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will be in position to consider the use of the Grade 13 permitted value in response to new 

requirements.

Current Reporting Practices

Four states provided insight on their current reporting practices for students who remain in high 

school beyond grade 12. A summary of those reporting practices and any related questions 

submitted by the states are included below and followed by ED’s response.

Public Comments

Two states reported that they do not track students who remain in high school after receiving 

their high school diploma. One state reports students as postgraduates if they return to high 

school after receiving a high school diploma. This state would like to know whether 

“Postgraduate” will still be a permitted value. Two states mentioned having five-year programs 

for students to receive both a high school and college degree simultaneously. Both states 

commented that the proposed “Grade 13” permitted value would not apply to students in such 

programs since the students have not completed their high school requirements but are still 

taking at least one high school course during their fifth year.

ED’s Response

As proposed in Attachment B-4, “Postgraduate” will no longer be a permitted vale for age/grade 

categories. If a student returns to high school after receiving a high school diploma, he or she 

would be counted as ungraded (UG) or participating in adult education (AE), as described in an 

earlier response. IDEA students who are continuing with their education, in accordance with 

their IEP, and who have completed grade 12 should be designated UG unless they are 

participants in a program to earn college credits.

The grade 13 permitted value has been proposed particularly for states having five-year 

programs for students to receive both a high school and college degree simultaneously. With the 

grade 13 designation, ED is seeking to identify students in the 5th year of a five-year highschool/college degree program. The guidance that grade 13 students have “satisfied grade 12 

requirements” is intended to make clear that a student is not repeating grade 12, and is 

progressing as expected in their program. ED would welcome suggestions for a clearer 

definition.

Burden

Three states commented on impact the proposed “Grade 13” permitted value would have on their 

data reporting. Their comments and ED’s response follow.

Public Comments

Two states commented that the proposed change would add additional reporting burden. One 

state observed that the permitted value would apply to few students and would require much 

work to report. The other state commented that it would be unable to complete the necessary

programming and training required for including the permitted value for SY 2013-14. 
Attachment E – Response to Public Comment

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One state suggested that the current permitted values be retained and flags be added to capture 

students who need additional years to graduate grade 12.

ED’s Response

ED does not agree that the proposed changes to the Grade 13 permitted value will result in 

significant additional reporting burden since the states which will utilize it are already collecting 

membership data on grade levels. It is anticipated that the Grade 13 permitted value will only be 

used by a subset of states that have a secondary to postsecondary education bridge program for 

which they are already collecting data, thus, requiring no additional data collection. The addition 

of the Grade 13 permitted value to EDFacts does not mandate its use by all SEAs. 

While the suggestion to use flags to identify students needing more than four years to graduate is 

appreciated, it does not meet the intent of having a Grade 13 permitted value.

GRADE 13 CHANGES TO THE PROPOSED EDFACTS DATA SET

Based on the comments submitted, the proposed changes to the Age/Grade categories published 

in Attachment B-4 during the 60-day public comment period will be retained. We regret that we 

did not provide a clearer, more thorough description of the proposed changes related to the Grade 

13 permitted value and its definition. We invite states to provide further comment given the 

additional information provided in this section.

TUITION-IN / TUITION-OUT

The paperwork clearance package posted during the 60-day public comment period proposed 

adding two new data groups to improve the CCD fiscal surveys and allow for more accurate 

calculations of per pupil expenditures, and thereby, more accurate allocation of Title I funds 

under the Elementary and Secondary Education Act (ESEA). The two data groups, “Students for 

whom tuition is paid (tuition-out)” and “Students for whom tuition is received (tuition-in)” were 

proposed to determine the number of students tuitioned-in or tuitioned-out of a local education 

agency (LEA). 

A total of 14 SEAs submitted comments regarding the proposed data groups. The comments fall 

into one of the following topics:

 Use of the Data Groups

 Burden

 General Recommendation

Use of the Data Groups

Public Comments
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Three states asked what the intended use, benefit, and audience are for collecting the proposed 

data groups. One needs to know the intended use and audience to determine whether it collects 

the data needed for the proposed data groups. One state mentioned that if the intent of the 

proposed data groups is to capture more complete financial data on high need or high cost 

students, ED will need to develop additional reporting.

ED’s Response

First and foremost, ED is appreciative of the states’ thorough responses on this proposal. Based 

on these responses, we realize that the originally proposed data groups will not result in the data 

that are needed. ED envisioned the collection of data that could reconcile the differences 

between a district’s membership counts and the aggregate of a district’s schools’ membership 

counts. ED plans to change the name of the data groups to “Students sent to schools outside the 

LEA (students sent)” to replace “Tuitioned-Out” and “Students received from other LEAs 

(students received)” to replace “Tuitioned-In.” The emphasis is not on monetary issues, but on 

reconciling headcounts. The data groups will be redefined as follows:

Students sent to schools outside the LEA (students sent): The number of students for 

whom the LEA is financially responsible, but who are educated in schools outside of the 

LEA. (These are students included in the sending LEA’s reported membership, but not in 

the membership of any of the sending LEA’s own schools.)

Students received from other LEAs (students received): The number of students from 

other LEAs who are educated in schools in the reporting LEA. (These students are 

included in the sending LEA’s reported membership, but not in the membership of any of 

the sending LEA’s own schools. They are not included in the receiving LEA’s reported 

membership, but are included in the membership of the receiving LEA’s school where 

they are instructed.)

Public Comments

A total of 11 states submitted comments seeking clarification on how the proposed tuition-in / 

tuition-out data groups would function or how the data would be used. Six states requested 

clarification on how students would be counted in either data group. Specific questions submitted 

by the SEAs include:

 Does the count include full-time students only or also part-time students? 

 Are the student counts headcounts or full-time equivalents (FTEs)?

 How is “substantial portion of the children’s educational cost” defined and determined?

 Which “applicable state requirements” pertain to the data groups?

 Does the count include

o Students attending school in an open enrollment LEA?

o Students enrolled in public virtual schools outside the LEA?

o Students attending private schools on a voucher?

o Students served by Title I only, all students, or students served by certain 

programs? 
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ED’s Response

Based on states’ responses, ED believes the original proposal put too much emphasis on cost, 

which was not the intention. “Students sent” are counts of students included in district-level 

membership of the sending district (i.e., students the district is responsible for financially) but 

when reporting school-level membership are counted in the membership of schools the students 

are sent to that are not part of the home district. “Students received” are counts of students in the 

district-level membership of another district, but are educated in schools in the receiving district 

and are included in the membership of those schools. These counts are headcounts. It is expected 

that a district’s aggregated school membership, minus the students received count, plus the 

students sent count should equal the district level membership count. Students sent to private 

schools should be included in the students sent count. 

Public Comments

One SEA commented that several of its LEAs have long-standing send-receive relationships in 

which all or some of their students are tuitioned-in or out, for example, a K-8 LEA that tuitions 

all of its students to a regional high school. How would these students be counted versus students 

that the LEA sends under contract to a non-public school to receive certain educational services? 

Are the contract students considered students tuitioned-in or tuitioned-out?

ED’s Response

ED believes these two situations would have the same guidance. The first scenario (K-8 LEA) 

would have a district membership count that includes all students for whom the district is fiscally

responsible, a count of students the district has sent to the regional high school (students sent) 

and a 0 count of students the district is receiving (if they are not receiving any students). It is 

expected that a roll-up of school-level membership counts would differ from the district level 

membership count, since the district does not have any high schools. However, knowing that a 

certain number of students have been sent out will allow for the numbers to be reconciled. For 

the second scenario (contract students), these students would be part of the students sent count, 

since they are receiving educational services at a location outside of the home district. Guidance 

and examples on how to report these students will be provided in the file specification. 

Public Comments

Two SEAs requested additional information on how data from the proposed data groups would 

be used to calculate per pupil expenditure. One of the states expressed concern that the current 

method of reporting LEA membership by the fiscally responsible LEA is burdensome and the 

potential application of data from the proposed data groups could result in a count equivalent to 

that produced by a former method of reporting membership by aggregating the school file to the 

LEA level. Furthermore, a couple states requested additional information on how data from the 

proposed data groups would be used to determine Title I allocations or how they would impact 

the calculation of the allocations. One state asked why low-income status of the reported students 

is not factored into these proposed data groups since the data are intended to impact LEA Title I 

allocations.
Attachment E – Response to Public Comment

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ED’s Response

There is no planned change to the way Title I funds are allocated. Under the present 

methodology, the current expenditure per pupil (CEPP) is a factor in computing LEAs’ 

Education Finance Incentive Grants (EFIG) under Title I. Presently the denominator used in 

computing the CEPP is the LEA membership variable. NCES is conducting an analysis to 

determine whether, for reporting purposes, the aggregate school membership would be a more 

appropriate denominator. A change to the CEPP calculations for NCES reporting would not 

necessarily be carried over into computing Title I grants. 

Burden

Public Comments

Ten SEAs commented on the expected impact on reporting burden the proposed data groups may

have. 

Three states mentioned that they may have the data needed to report the proposed data groups, 

though they need additional information (captured in the questions above) to be certain. One 

state commented that while it has the requisite data, they would require extensive new code to be 

extracted. Another state’s data include students for whom tuition could be charged or paid in 

addition to the count of students for whom tuition is charged or paid.

Several states indicated that including the two proposed data groups would require additional 

programming and training. Four states did not support the collection of the new data groups. 

They commented that they do not currently collect all of the data required to report the two 

proposed data groups, and that collecting and reporting such data would be complex, labor 

intensive and expensive. 

One state commented that the collection of the tuition-in / tuition-out data may interfere extend 

with a pending decade-long lawsuit between the state and its LEAs.

ED’s Response

It is ED’s hope that the change in data group name and definition will relieve concerns about the 

burden of these data groups. ED is purely interested in a headcount of students that are sent to 

other districts for educational services, as well as the headcount of students that are received in a 

district in order to provide educational services. 

General Recommendation 

Public Comments

One state suggested that ED pilot the collection of data for the proposed tuition-in / tuition-out 

data groups. The pilot should include LEAs that have a per pupil expenditure that is markedly 

impacted by funds tuitioned-in or tuitioned-out.

ED’s Response
Attachment E – Response to Public Comment

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Given the change in focus for these new data groups, ED does not plan to implement a pilot. 

TUITION-IN / TUITION-OUT CHANGES 

TO THE PROPOSED EDFACTS DATA SET

ED has changed the names of the data groups, along with their definitions. They are presented 

below:

Students sent to schools outside the LEA (students sent): The number of students for whom 

the LEA is financially responsible, but who are educated in schools outside of the LEA. (These 

are students included in the sending LEA’s reported membership, but not in the membership of 

any of the sending LEA’s own schools.)

Students received from other LEAs (students received): The number of students from other 

LEAs who are educated in schools in the reporting LEA. (These students are included in the 

sending LEA’s reported membership, but not in the membership of any of the sending LEA’s 

own schools. They are not included in the receiving LEA’s reported membership, but are 

included in the membership of the receiving LEA’s school where they are instructed.)

MILITARY CONNECTED STUDENT IDENTIFIER

Public Comments

One non-profit submitted a comment recommending that ED create a report-only student 

subgroup for military connected students. Such data could provide insight on:

 Where military connected students attend school

 The academic performance and graduation rate of military connected students

 The progression of military connected students to postsecondary education and the 

workforce

 Potential best practices used in schools educating a large number of military connected 

students which may be applicable for any agency when students move or experience 

‘disruption to academic continuity or opportunity’

ED’s Response

While ED agrees that the data submitted through the addition of this subgroup for reporting 

purposes would be valuable to help meet the needs of military connected students, such an 

addition at this point in the clearance process for data collection related to the 2013-14 school 

year would impose a significant change upon state education agencies without allowing for 

proper discussion with state education agencies or federal program offices. State education 

agency officials have repeatedly informed ED that they need 2 to 3 years to phase in collection 

of new data groups or new category elements. Other comments received in response to this 

package continued to support that timeline.
Attachment E – Response to Public Comment

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As ED explores options for collecting and reporting data to promote transparency around the 

performance of military connected children, further input from stakeholders would be 

welcome. In particular, ED will find valuable any input regarding the potential burden on 

schools and LEAs to collect, manage and report these data.

MILITARY CONNECTED STUDENT IDENTIFIER CHANGES 

TO THE PROPOSED EDFACTS DATA SET

ED welcomes further input on the proposed subgroup and hopes that through this 30-day

comment period a variety of stakeholders will provide input on the suggestions made by this 

commenter. 

MIGRANT EDUCATION

The paperwork clearance package posted during the 60-day public comment period proposed 

several changes to the migrant data. A total of 10 states submitted comments related to the 

migrant data changes proposed. Two states specifically commented on overall confusion 

regarding the comprehension and justification of the proposed changes. The proposed revision of 

DG102, deletion of DG636 andDG637, and the change to staff category each received comments 

from four states, the most comments received for any of the proposed changes to migrant data. 

This section summarizes the comments for the migrant data:

 Revision of DG102: MEP students served 12-month table

o Duplicate reporting concern

o Manageable change

 Revision of DG634: Migrant student eligible 12-month table

o Confusion over what periods to report

 Deletion of DG636 and DG637: MEP students served regular and summer

o Negative impact on MEP student counts

o Confusion and concern over deletion of summer counts

o Justification requested

 Revision of DG684: MEP services

o Confusion on what to report

o Justification requested

 Revision of staff category: Qualified or non-qualified paraprofessionals 

o Burden

o Definition requested
Attachment E – Response to Public Comment

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GENERAL RESPONSE TO ALL COMMENTS FROM 

THE OFFICE OF MIGRANT EDUCATION

The Office of Migrant Education (OME) has proposed changes to Migrant data collected in 

EDFacts, with the intent to streamline the data collection by gathering data essential to program 

Government Performance Results Act (GPRA) requirements, State Profile elements, and OME 

desktop and on-site monitoring requirements. The program office deployed a process that 

solicited input from the Migrant Education Program (MEP) Coordination Workgroup of nine 

MEP state directors, MEP state directors, the National Association of State Directors of Migrant 

Education (NASDME), and the Interstate Migrant Education Council (IMEC) in the 

development of the program’s GPRA and State Profile elements. 

OME’s proposed changes reduce the burden of data collection for SEAs primarily by focusing 

on collecting data by program year (performance period), and eliminating most data sections that 

collect regular year and summer-intersession data. Finally, OME is currently exploring the use 

of the Migrant Student Information Exchange (MSIX) as a data collection tool, so that states may

concentrate their data efforts on MSIX quality.

The comments are summarized below and followed by ED’s response. 

REVISION OF DG102: MEP STUDENTS SERVED 12-MONTH TABLE

The paperwork clearance package posted during the 60-day public comment period proposed the 

following revisions to DG102, MEP students served 12-month table:

o Add two new Category Sets: 

 Category Set B, Age/Grade (w/o under 3) and Migrant Priority for 

Services (only)

 Category Set C, Age/Grade (w/o under 3) and Continuation (only)

A total of four states commented on the proposed changes.

Public Comments

Two states expressed concern with this change. One state suggested that this change will lead to 

duplicate reporting and may result in programmatic changes. Two states stated they could report 

this data with no problem. 

ED’s Response

Prior to SY 2013-14, ED collected priority for services (PFS) served students by regular year 

(RY) and summer/intersession (SI) session type. ED plans to add performance period (PP) 

session type, PFS served data in SY 2013-14, in order to capture the total unduplicated number 

of PFS students served in the performance period. States will report in DG102 Continuation of 

Service (COS) students in one data set, in order to provide this number by performance period. 

REVISION OF DG634: MIGRANT STUDENT ELIGIBLE 12-MONTH TABLE
Attachment E – Response to Public Comment

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The paperwork clearance package posted during the 60-day public comment period proposed the 

following revisions to DG634, Migrant students eligible 12-month table: 

o Revise Category set E by 

 Changing Mobility Status (Qualifying Moves) to Mobility Status (12 

months)

 Adding Category Set G: Age/Grade (All) and Referral Status

A total of two states commented on the proposed changes.

Public Comments

One SEA expressed concern with the proposed revisions, requesting clarification on whether it 

will still be required to report students served after the 12 month period, and, if so, where to 

report the data. The other state commented on the referral status and stated that it appears to 

clarify that a referral must be received to be counted. 

ED’s Response

ED will continue to use DG634 to collect Category 1 Child Count data, and ED will continue to 

use DG635 to collect Category 2 Child Count data. ED plans to provide technical assistance 

regarding the proposed changes, prior to the SY 2013-14 performance period. 

Summer/intersession child counts will continue to be collected in DG635. States will report in 

DG634 numbers of eligible Migrant children who experienced a last qualifying move during the 

performance period (September 1 – August 31). 

DELETION OF DG636 & DG637: MEP STUDENTS SERVED REGULAR & SUMMER

The paperwork clearance package posted during the 60-day public comment period proposed to 

delete DG636 and DG637.

A total of four states commented on this proposed change. 

Public Comments

All four states expressed concern with the deletion. One state said the change would negatively 

impact MEP student counts. Another state said it is against the elimination of the summer term 

reporting counts because the changes would impact funding. Two states also mentioned the 

increased burden due to adjusting data systems to meet the requirements. All of the comments 

opposed the proposed change. 

ED’s Response

The deletion of these data groups is ED’s response to state MEP directors input to ED 

recommending a reduction of the burden in data reporting and types of data. While these data 

will no longer be reported to ED, they may be very useful at the SEA level, where such studentlevel data may be very informative to a SEA’s comprehensive needs assessment, service delivery

plan, and especially evaluation. ED encourages states that would like to continue to collect these 

data to do so, and to use the data to improve program effectiveness. 
Attachment E – Response to Public Comment

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REVISION OF DG684: MEP SERVICES

The paperwork clearance package posted during the 60-day public comment period proposed the 

following revisions to DG684, MEP services table: 

o Delete the category MEP Session Type from Category Set A

One state commented on this proposed change.

Public Comments

The state requested clarification of whether it will be required to report (by service type) the 

cumulative unduplicated count of migrant students that received services during the performance 

period.

ED’s Response

ED will collect types of services in DG684 by performance period, rather than by regular year 

and summer/intersession. ED is moving referred services to another data group because, by

nature, referred services are not MEP-funded instructional or support services. The inclusion of 

referred services within MEP-funded services was somewhat confusing in the past.

REVISION OF STAFF CATEGORY: 

QUALIFIED OR NOT QUALIFIED PARAPROFESSIONALS

The paperwork clearance package posted during the 60-day public comment period proposed the 

following revisions to Staff Category:

o Revised permitted values by

 Changing “Paraprofessionals” to “Paraprofessionals - Qualified” and 

“Paraprofessionals – Not qualified”

A total of four states commented on this proposed change.

Public Comments

Four states expressed concern with this change. Three states stated they currently do not have 

this data available. Two states commented that this change would induce burden because they

would have to change their data systems to collect it. Two states requested clarification of the 

definition of qualified and non-qualified. 

ED’s Response

Currently, states provide data on “All Paraprofessionals” and “Paraprofessionals - Qualified” in 

DG515 and DG625. The number of headcount or FTE for “Paraprofessionals – Not Qualified,” 

should be the difference between the “Paraprofessionals” headcount or FTE and the 

“Paraprofessionals – Qualified” headcount or FTE.
Attachment E – Response to Public Comment

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MIGRANT CHANGES TO THE PROPOSED EDFACTS DATA SET

No changes are proposed at this time.

NEGLECTED OR DELINQUENT

The paperwork clearance package posted during the 60-day public comment period did not 

propose any changes to the data groups or data categories for the Neglected or Delinquent 

Students Program. One reviewer of the package provided a comment.

Public Comment

One SEA expressed concern that academic achievement reporting for at-risk neglected or 

delinquent programs would be eliminated.

ED’s Response

ED responded by clarifying that “At-Risk” will remain an optional permitted value in the N or D 

academic achievement file FS125 (DG629). ED understands the concern expressed for States 

with a significant number of at-risk programs and long-term (LT) at-risk students. As a result, 

ED has opted to keep academic achievement reporting for long term at-risk students as an 

optional collection item in EDFacts FS125. 

When ED considered changes to CSPR questions over the past two years, several State Title I, 

Part D coordinators commented that their at-risk programs do not explicitly address reading and 

mathematics performance and having to pre- and post- test all long-term students in these areas

may unnecessarily restrict programming to focus on supplemental reading and math instruction. 

ED eliminated the pre- and post-test requirements for at-risk programs as their range of students 

served and services provided is broader and more flexible.

N OR D CHANGES TO THE PROPOSED EDFACTS DATA SET

No changes are proposed at this time.

VIRTUAL SCHOOLS

The paperwork clearance package posted during the 60-day public comment period included a 

proposal for a new data group to identify whether or not a school is a virtual school. The 

package also included a directed question concerning the use of the term ‘virtual school.’

Public Comments

ED received a total of approximately 25 comments from 17 state education agencies (SEAs) plus one 

non-SEA state agency. Eighteen of the comments were in response to the directed question: Is 
Attachment E – Response to Public Comment

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“virtual school” the correct term to be using if the intent is to create a flag for schools that deliver 

only online education? Of the 15 comments that were responding to the question:

 Thirteen agreed that “virtual school” is an appropriate term for schools that deliver only 

online learning. Three of those states provided other commonly used terms, including eschool, online school, distance-learning school, virtual learning school. Concerns were 

raised by two states that the application of the virtual school flag be limited to schools and 

not programs. 

 Two states said virtual school is not the right term and would not capture what is happening 

in those states where students are likely to have a mix of online and traditional coursework. 

Additional concerns raised by states in their comments, both in response to the directed question 

or comments made concerning the proposed flag as it was shown in Attachment B1, included: 

 The need for clear definitions and examples included with the guidance so as to get only 

virtual schools and not virtual programs as well.

 Simplifying the code set to Y/N (four states specifically recommended this).

 One state asked if the proposed EDFacts definition of virtual school will match the definition 

of ‘virtual school’ from the NCES Forum guide. 

ED’s Response

ED appreciates all of the helpful comments on this item. We understand that virtual education is 

rapidly evolving and what we collect may not exactly fit what it is happening in every state. In 

light of the comments received from states, we will refine the definition for “virtual school” and 

confirm that it is in line with what has been published in the Forum guide on 

Elementary/Secondary Virtual Education. We will also change the code set to Y/N. We are 

only seeking information on virtual schools, not programs. The flag will only be applied to 

schools in the EDFacts directory. 

The opportunity for all students, including students with disabilities (IDEA), to participate in a 

public education system through virtual schools for part of or the entire school day is still an

emerging body of knowledge and research. ED is interested in learning more about how states 

are using virtual schools to provide services to all students, including students with disabilities

(IDEA). The proposed addition of virtual school flags will support ED in building an 

understanding of the use of virtual schools. Further guidance for educational environments will 

be considered as the knowledge base about virtual schools improves. In the meantime, states 

should apply the current guidance about educational environments when submitting data for 

FS002 and FS089.

VIRTUAL SCHOOL CHANGES TO THE PROPOSED EDFACTS DATA SET

ED will redefine ‘virtual school’ as a public school that offers only virtual courses, instruction in 

which students and teachers are separated by time and/or location, and interaction occurs via 
Attachment E – Response to Public Comment

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Page	E-38

computers and/or telecommunications technologies, and generally does not have a physical 

facility that allows students to attend classes on site.

ED will change the code set to Yes or No.

GENERAL COMMENTS

Nine states included approximately 15 general comments in their comment submissions. 

Review and Comment Process

Public Comments

 Two states said that they supported the proposed deletions to the data set.

 Three states expressed appreciation for the opportunity to comment as well as their support 

of EDFacts. 

 Two states commented that the package structure led to some confusion on the proposed 

changes, especially in regard to proposed changes for Grade 13, Charter Authorizers, and 

Migrant. 

 Another state requested that the clearance materials identify the EDFacts files that will be 

changed. 

 One state pointed out that the edicsweb.gov site incorrectly directed reviewers to 

Regulations.gov, when in fact, the EDFacts data set had not been migrated to the new 

website. 

ED’s Response

ED greatly appreciates the time taken by commenters to read through the clearance package and 

provide thoughtful comments on how to improve the EDFacts collection as well as the review 

process. ED regrets any confusion caused by the structure of the package. The original intention 

was to keep Attachment C concise and direct reviewers to where the detailed information could 

be found. Changes and revisions were marked throughout the package documentation. 

However, we understand how some of the changes may have been difficult to follow. We have 

revised the structure of Attachment C to provide greater clarity on specific changes. Regarding 

the identification of file specifications that will be impacted by the proposed changes, assignment 

of data groups to specific files occurs after all proposed changes are final and cleared for 

collection. ED regrets the impact of the timing of the migration from EDICS to Regulations.gov. 

The EDFacts collection was already out for the 60-day public comment period when the 

migration occurred. We messaged the appropriate method for submitting comments to our major 

stakeholders.

Burden

Public Comments
Attachment E – Response to Public Comment

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Page	E-39

One state expressed its continued support for EDFacts as a central data collection and reporting 

system, but expressed concern that over the years that EDFacts has been in place, this state has 

seen a net increase in data burden rather than reduction. As an example, the state mentioned the 

addition of ESEA flexibility data to the EDFacts collection. The state urged that Congress and 

ED work to streamline the EDFacts data collection by removing data elements that are no longer 

useful, and pay particular attention to this during the ESEA reauthorization process. This state 

also mentioned the SLDS grant program’s support of state data systems, and encouraged that in 

the reauthorization of ESEA, there be a 5% dedicated funding for maintenance of the state 

systems being developed with these grants. 

ED’s Response

As part of the process for identifying needed changes to the EDFacts data set, the EDFacts Data 

Governance Board (EDGB) reviewed all currently collected data with program offices to 

determine where data were not being used and could be eliminated. Some data groups were 

deleted or changed as a result of this process. As EDFacts has matured into a reliable collection 

and reporting system for ED, it has been increasingly viewed as the appropriate mechanism for 

collecting data required of SEAs. We will continue to work through EDGB to highlight burden 

concerns of states and identify and eliminate any unnecessary data collection. 

Timeline

Public Comments

Several states commented on the necessary timeline for notifying states of changes or additions to the 

EDFacts data collection.

 One state noted that it needs know all final data collection requirements for SY 2013-14 by

December 2012 rather than February 2013 in order to have sufficient time to update state and 

district data collection software and documentation. This state requested that implementation 

of these changes be delayed until SY 2014-15. 

 One state reminded ED that a two-year lead time is generally needed to develop or modify 

data systems to accommodate new data requirements. 

 One state requested that any proposed change that reduces burden and improves data 

collection should be made immediately and not delayed until SY 2013-14. 

ED’s Response

ED understands state concerns on this issue, and in response to repeated requests from states to 

hear of data collection changes earlier, we moved up the timeline on this three-year clearance. 

We expect this three-year package to be cleared approximately six months earlier than the 

previous (SY 2010-11) three-year clearance package. We will continue to work to move up our 

timelines for announcing changes in data collection. We work to implement deletions or 

‘streamlining’ of collection as soon as possible. However, if a new data group or category is 

needed in order to eliminate other data groups or categories, we cannot implement changes until 

the new item has been fully cleared. 
Attachment E – Response to Public Comment

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Data Quality – Postsecondary Data

Public Comments

One state commented that it had undertaken work to collect student-level postsecondary

remediation rates for its K-12 high school graduates attending in-state colleges. Preliminary data 

exchanges with the National Student Clearinghouse indicate that half of the state’s high school 

graduates attend out-of-state postsecondary institutions. Thus, any data it is able to collect from 

its in-state higher education institutions will be skewed in that it will represent less than half of 

the eligible population and be subjected to the self-selection biases associated with a student’s 

decision to remain in state for postsecondary education.

ED’s Response

This information will be shared with the EDFacts Data Governance Board (EDGB), so that 

offices that use the postsecondary data will be aware of these concerns. 

GENERAL COMMENT CHANGES TO THE PROPOSED EDFACTS DATA SET

No changes will be made to the proposed EDFacts data set based on these general comments. 

However, as indicated above, ED will restructure Attachment C of the clearance package in an 

effort to improve clarity on proposed changes.